From January 2024 - update Monitoring Plans and prepare emission reports 

Shipowners, ship managers and charterers need to:

  • Update verified Monitoring Plan information in the THETIS-MRV platform for each vessel.
  • Prepare and submit ship-level Emission Reports to LR for verification. This should cover CO2 emissions only, per the MRV requirements from Regulation EU 2015/757 as published April 2015, based on data collected in 2023. 

By 31 January 2024 - send the monitoring plan for verification

Shipowners, ship managers, and charterers should send the ship's updated monitoring plan to LR for assessment.

LR clients must submit this through Emissions Verifier, which allows the assessed Monitoring Plan to be exported via a .xml file and imported into THETIS-MRV.

From 31 January 2024 - open a MOHA

As per Delegated Regulation (EU) 2023/2904 Article 15a, the shipping company with responsibility for EU ETS compliance must open a Maritime Operators Holding Account (MOHA) in the Union Registry:

  • Within 40 working days for shipping companies, which are included in the published list of assigned AA (Regulation 2024/411).
  • Within 65 working days of the first port of call falling within the scope of the ETS Directive for shipping companies not listed in Regulation 2024/411

Access additional information on MOHA's and the Union Registry here.

From 1 January to 31 December 2024 - first EU ETS monitoring period

At the ship level, shipowners, managers, and charterers must start monitoring voyages, fuel consumption, and CO2, CH4, and N2O emissions as per the MRV requirements from Regulation EU 2015/757, published on 1 January 2024.

At the end of the first monitoring period, start preparing the ship Emissions Report.

From 31 January to mid-March 2024

LR will undertake MRV verification and site visit activities to assess the Monitoring Plan for conformance with Regulation EU 2015/757 (as adopted in 2023). 

A site visit may be physical or virtual if there is sufficient understanding of the monitoring and reporting systems in place, the complexity of the ship allows for a virtual visit, and information can be obtained remotely. Site visits cannot be waived in the event of the development of a new monitoring plan or a modification to an existing one. 

By 1 April 2024

A verified monitoring plan compliant with EU MRV Regulation 2015/757 should be submitted to the assigned Administering Authority:

  • By 1 April 2024 for ships in scope of MRV prior to 1 January 2024; or
  • No later than three months after the first port of call bringing the vessel in scope of MRV (and ETS requirements) from 1 January 2024. 

By 30 January 2025 - submission of emission reports for verification

The annual ship and company-level emission report data is to be uploaded to Emissions Verifier for each vessel, include:

  • LR or other Reporting Template,
  • Relevant Bunker Delivery Note (BDN) & bill of landing for the applicable voyages,
  • for each applicable voyage date & time of departure & arrival,
  • fuel ROBs / consumption,
  • distance travelled,
  • time spent at anchorage,
  • cargo transferred.

Before 31 March 2025 and every year thereafter - verification of emission reports

LR needs to verify the submitted Emissions Report at the ship and company level.

As part of this verification, each company, and possibly the ship, will receive a physical site visit at least once every four years. Site visits in intervening years may be virtual or waived (if conditions allow), but may not be waived for three consecutive periods. This ER verification, including the site visit, must be completed ahead of the 31 March submission deadline.

By 31 March 2025 and every year thereafter - submission of verified emission reports

Shipowners, ship managers, and charterers need to submit the verified Emissions Report to their relevant Administering Authority via THETIS-MRV. 

By 6 June 2025

Administering Authorities will approve the Monitoring Plan submitted by 1 April 2024 for compliance with EU 2015/757 MRV requirements.

By 30 September 2025 and every year thereafter - surrender of EU allowances

Shipowners, ship managers, charterers or shipping companies are to surrender sufficient EU allowances to cover the verified emissions as per the verified ER data at the company level (after applicable derogations as stipulated in Directive 2003/87/EC have been applied). This should all be completed through a Union Registry Account. For more information on Union Registry Accounts, please see FAQ – Maritime transport in EU Emissions Trading System (ETS) (

Information on MOHA's and the Union Registry