In 2026, shipowners and ship managers are managing EU MRV, EU ETS, FuelEU Maritime, IMO DCS and CII at the same time. Each has its own calculations, data sources, deadlines and verification steps, so maritime compliance is now a connected operational challenge.
The short answer: the EU Emissions Trading System (EU ETS) is a carbon-pricing mechanism that requires covered shipping emissions to be matched with allowances. FuelEU Maritime regulates the greenhouse-gas (GHG) intensity of energy used onboard ships. EU MRV (Monitoring, Reporting and Verification) provides the emissions data, the IMO Data Collection System (DCS) covers fuel consumption, and the Carbon Intensity Indicator (CII) rates operational efficiency.
These regimes overlap in the vessel and fuel data they depend on. That overlap is where most of the operational work sits.
EU Maritime Compliance Regulations at a Glance
- EU ETS: prices covered maritime greenhouse-gas emissions.
- FuelEU Maritime: regulates the GHG intensity of energy used onboard.
- EU MRV: monitors, reports and verifies ship emissions data.
- IMO DCS: collects ship fuel-consumption data.
- CII: measures operational carbon intensity.
What Is EU ETS for Shipping?
EU ETS maritime compliance means monitoring covered emissions, having them verified, and surrendering one allowance per tonne of CO₂-equivalent. The system applies to shipping from 2024 and builds on the EU MRV regulation.
Scope. In the European Commission's description, the system covers 100% of emissions from voyages between EU ports and within EU ports, and 50% of emissions from voyages between an EU port and a port outside the EU. It applies to larger ships (5,000 gross tonnage and above), and the responsible shipping company carries the obligation. europa
EU ETS shipping 2026: what changes. Surrender is phased in, and 2026 is a transition year:
- First surrender covered 40% of 2024 emissions (due by 30 September 2025). In 2026, companies surrender allowances for 70% of emissions reported for 2025. From 2027, 100% of reported emissions must be covered. europa
- From 2026 onwards, the scheme also covers greenhouse gases beyond CO₂, meaning methane and nitrous oxide are included in 2026 emissions. europa
The practical point is that the compliance year and the emissions year differ. The 30 September 2026 surrender relates to 2025 emissions, while 2026 emissions, now including additional gases, are surrendered in 2027.
Because allowances are bought against reported tonnes, the emissions figure creates direct financial exposure. Reliable fuel and voyage data is therefore the foundation of EU ETS compliance.
What Is FuelEU Maritime?
FuelEU Maritime is an EU regulation (Regulation (EU) 2023/1805) that sets limits on the GHG intensity of energy used by ships. It applies a well-to-wake view, counting emissions from fuel production and supply as well as onboard use, so fuel choice matters as much as fuel quantity.
For FuelEU Maritime 2026, the key point is the annual cycle. The first reporting period was 2025, and the first FuelEU report was due to a verifier on 31 January 2026. Later steps follow: verification of the report by 31 March, verification of the compliance balance by 30 April, and issue of the FuelEU Document of Compliance by 30 June. Ships entering EU ports must carry a valid Document of Compliance. Decarbonising maritime transport +2
The regulation also addresses onshore power. Zero-emission-at-berth requirements apply from 1 January 2030 in ports covered by the AFIR regulation, and from 2035 for all EU ports with onshore power. europa
For FuelEU Maritime compliance, teams need accurate fuel types, energy content, emission factors and port-call records for each vessel.
EU ETS vs FuelEU Maritime: What's the Difference?
EU ETS prices emissions; FuelEU Maritime limits the GHG intensity of the energy a ship uses. One asks how much a company emitted and which allowances cover it. The other asks how low-carbon the energy was.
| Regulation | Main purpose | Main focus |
|---|---|---|
| EU ETS | Carbon pricing | Covered greenhouse-gas emissions |
| FuelEU Maritime | Reduce GHG intensity | Energy used onboard |
| EU MRV | Monitor and report emissions | Vessel emissions data |
| IMO DCS | Collect fuel-consumption data | Ship fuel consumption |
| CII | Measure operational carbon intensity | Vessel efficiency |
Measure operational carbon intensity
Vessel efficiency
The systems are distinct but draw on overlapping operational data. FuelEU Maritime does not replace EU ETS, and a ship can be subject to both.
What Are EU MRV, IMO DCS and CII?
EU MRV
EU MRV is the EU framework under which larger ships calling at EU ports monitor emissions, submit reports and have them checked by accredited verifiers. It is also the data foundation for EU ETS reporting.
IMO DCS
The IMO Data Collection System is mandatory under MARPOL Annex VI. It has run since 1 January 2019 and aggregates fuel consumption, distance travelled and hours underway for ships of 5,000 GT and above. dnv
CII
The Carbon Intensity Indicator rates operational efficiency from A to E. The aggregated DCS data forms the basis of the CII rating, and the attained rating is recorded on the DCS Statement of Compliance. dnv
EU MRV, IMO DCS and CII should not be treated as separate data exercises. Shipping companies can face overlapping collection, validation and reporting work across these regimes, and an error in a fuel figure can carry through to every one of them.
What Data Do Shipping Companies Need for Maritime Emissions Compliance?
Typical maritime emissions data includes:
- Noon reports, voyage records and port-call information
- Bunker Delivery Notes (BDNs) and fuel consumption records
- Flowmeter data and vessel operational data
- Fuel types and emission factors
- Supporting documents and verification records
When this data lives in separate emails, spreadsheets and systems, the result is missing information, duplicate records, inconsistent fuel figures, manual reconciliation, verifier queries and reporting delays. The regulation is only part of the challenge; the rest is connecting each reported number to a source record.
How to Manage EU ETS and FuelEU Maritime Compliance
A practical shipping compliance workflow has six steps:
- Collect: gather vessel reports, fuel data, BDNs and supporting documents.
- Check: test completeness, consistency and data quality.
- Reconcile: compare sources and identify discrepancies.
- Follow up: work with vessel and shore teams to obtain missing or corrected information.
- Report: prepare regulatory reports and supporting evidence.
- Verify and submit: coordinate with verifiers, resolve queries and track deadlines.
This is manageable for a few vessels. Across a fleet, shipping compliance software can take on repetitive checking and tracking so people can focus on exceptions. See our guide to comparing maritime compliance software for what to look for.
How Can Shipping Companies Prepare for 2026?
- Identify which vessels and voyages fall under each regulation.
- Map every required data source.
- Standardise vessel reporting.
- Validate fuel and voyage data.
- Reconcile conflicting records.
- Track missing documents.
- Prepare verifier-ready evidence.
- Monitor reporting deadlines.
- Maintain an auditable compliance trail.
- Review the process continuously across the fleet.
Why Maritime Compliance Data Quality Matters
Compliance depends on the quality and traceability of the inputs as well as the calculations. Reliable shipping emissions reporting rests on:
- Completeness: no gaps in voyages or fuel records
- Consistency: the same figures across reports
- Accuracy: correct fuel types and factors
- Traceability: each number linked to a source
- Auditability: a clear record of changes
- Timeliness: data ready before deadlines
A spreadsheet of totals is not enough if the supporting evidence cannot be found when a verifier asks a question. Our overview of what verifiers typically ask for covers this in more detail.
Conclusion
Maritime compliance is becoming a connected operational process rather than a set of isolated reports. Shipowners and managers need a consistent way to collect, validate, reconcile, document and report vessel data across multiple regimes.
Sternbow helps shipping teams manage this compliance workflow around their existing operations, combining people, process and technology so teams can spend less time chasing fragmented data and more time managing the exceptions that require attention.
Ready to take one vessel off your compliance workload? Choose one vessel, introduce Sternbow to your team, and we'll manage the compliance workflow around your existing operation for one month, free.
Frequently Asked Questions
Key regulatory and operational answers related to this analysis.