Monitoring Plan for EU MRV and EU ETS in shipping
The EU MRV (Monitoring, Reporting and Verification) and the EU Emissions Trading System (EU ETS) form important European frameworks for reducing emissions in the maritime sector. A central component of this legislation is the Monitoring Plan (MP).
The Monitoring Plan describes how a shipping company monitors, records and reports the fuel consumption and greenhouse gas emissions of its vessels. This includes emissions of:
- CO₂ (carbon dioxide)
- CH₄ (methane)
- N₂O (nitrous oxide)
The data collected under EU MRV forms the basis for the reporting obligations under EU ETS. Therefore, a correctly prepared and verified Monitoring Plan is essential for compliance with European climate legislation.
Although EU ETS currently only applies to ships of 5,000 GT or larger, it is expected that general cargo and offshore vessels between 400 and 5,000 GT will fall under the system from 2027 onwards.
Our approach
Normec Verifavia supports shipowners and operators in assessing their Monitoring Plan in accordance with the requirements of EU MRV and EU ETS.
During the assessment, we review, among other things:
- The selected emissions monitoring methodology
- Responsibilities and procedures within the organization
- Consistency of data collection and reporting
- Alignment with EU MRV and ETS regulations
Monitoring Plans are prepared and submitted through the THETIS-MRV platform of the European Maritime Safety Agency (EMSA). An accredited verifier must assess the plan before the competent authority can approve it.
Normec Verifavia's expertise
Normec Verifavia is an independent verification body with extensive experience in European and international maritime regulations.
We support shipowners worldwide with compliance including:
A thorough assessment of the Monitoring Plan helps organizations remain compliant with European emissions regulations.
What this delivers for you in practice:
- You comply with EU MRV and EU ETS emission reporting obligations
- You prevent errors in emission data and reporting processes
- You minimize compliance risks and potential penalties
- You improve transparency towards regulators and stakeholders
- You support the EU climate objectives for the maritime sector
When must a Monitoring Plan be updated?
Under the EU MRV Maritime Regulation, a shipping company must evaluate the Monitoring Plan at least once per year to verify whether it still reflects the operational reality of the vessel.
Updates are required when, for example:
- The owner or manager of the vessel changes
- New emission sources or fuels are introduced
- The availability of data or measurement methods changes
- Incorrect monitoring data is identified
- The plan no longer complies with MRV regulations
In such situations, the shipping company must immediately inform the verifier. When changes relate to emission measurements or data quality, the verifier will assess conformity before the revised plan is submitted to the competent authority.
For vessels falling under the EU ETS Directive, both the original Monitoring Plan and any changes must be approved by the competent authority.
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Frequently asked questions about the EU MRV & ETS Monitoring Plan Assessment
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The Monitoring Plan describes how a shipping company monitors, records and reports the emissions of its vessels in accordance with European regulations.
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Monitoring Plans must be submitted through the THETIS-MRV platform of EMSA and are assessed by an accredited verifier before the competent authority approves them.
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For vessels falling under EU ETS, the Monitoring Plan had to be submitted no later than the end of March 2024 or within two months after the vessel's first EU port call.
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Yes. When operational conditions, measurement methods or emission sources change, the Monitoring Plan must be updated and reassessed.
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After assessment by an accredited verifier, the Monitoring Plan is submitted to the Administering Authority, which grants final approval.
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The EU Regulation on Monitoring, Reporting, and Verification (MRV) for shipping (Regulation (EU) 2015/757) applies to ships with a gross tonnage (GT) of 5,000 or more that carry goods or passengers for commercial purposes on voyages to and/or from ports in the European Economic Area (EEA).
Effective January 1, 2025, the scope of the MRV Regulation will be expanded.
The following ships will therefore be subject to the requirements:- Offshore vessels of 5,000 GT or more
- Offshore vessels and general cargo ships between 400 and 5,000 GT
- The regulation applies regardless of the flag under which the vessel sails.
- A limited number of vessel types are exempt, including:
- Warships
- Naval support vessels
- Fishing vessels and fish processing vessels
- Vessels without mechanical propulsion
- Government vessels used for non-commercial purposes
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Starting January 1, 2025, offshore vessels of 400 GT or more will be subject to the MRV Regulation for the maritime sector.
On October 16, 2024, the European Commission adopted a delegated act clarifying Annex I to the MRV Regulation. This amendment confirms that the regulation applies to vessels designed or certified to perform offshore work or operations at offshore installations.
Examples of ships covered by this include:- Offshore support vessels
- Pipe-laying vessels
- Drilling vessels
The delegated act was published in the Official Journal of the EU on December 27, 2024.
In addition, the European Commission has established a special working group within the European Forum for Sustainable Shipping, in which member states, industry associations, and civil society organizations collaborate. Among other things, this working group discusses the further integration of offshore vessels into the MRV system.
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In most cases, emergency generators are not considered a source of emissions under the MRV Regulation.
The MRV Regulation focuses primarily on emissions from:
- Main engines
- Auxiliary engines
- Gas turbines
- Boilers
- Inert gas generators
- Incinerators
However, if an emergency generator is used operationally—for example, for the regular power supply—it must be treated as an auxiliary engine.
In that case, the generator must:
- be included as an emission source in the monitoring plan (MP)
- be included in fuel consumption monitoring
- be listed in the emissions report (ER)
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If a monitoring plan does not meet the EU MRV or EU ETS requirements, this can have various consequences, including:
- Fines or financial penalties
- Delays in emissions reporting
- Potential restrictions on participation in the EU ETS system
Therefore, it is important that the monitoring plan be reviewed and verified by an accredited verifier before it is submitted to the competent authority.