UK ETS Maritime Sector–Regulatory Developments and Compliance Actions

C26010 | 28 January 2025

Notification to: Ship Owners/ Managers/ Operators/ Verifiers

Introduction

This circular is issued to update stakeholders on the UK Emissions Trading Scheme (UK ETS) and its introduction for maritime emissions. It addresses:

Domestic UK ETS for maritime (effective 1 July 2026)
Proposed expansion to international maritime emissions (from 1 January 2028)
Scope, applicability, and ship thresholds
Monitoring, Reporting, and Verification (MRV) obligations
Allowances and surrender requirements
Exemptions and penalties for non-compliance
Outlook and strategic considerations for shipping companies

Domestic UK ETS – Maritime Sector (Effective 1 July 2026)

Scope and Timing:
Applies to cargo and passenger ships ≥5,000 GT performing intra-UK voyages and port stays in UK ports.
Ships will be subject to an additional layer of carbon-pricing obligations alongside EU ETS and FuelEU Maritime.
Emissions covered include CO₂, with CH₄ (methane) and N₂O (nitrous oxide) also included.

Obligations:
Ships are required to monitor, report, and verify (MRV) emissions in accordance with UK ETS guidance.
Shipowners/operators must purchase and surrender UK Emissions Allowances (UKAs) corresponding to verified emissions.
MRV and surrender deadlines will be communicated by the administering authority; companies should establish procedures in advance.

Implementation Notes:
Some implementation details remain under development, and further guidance from UK authorities is expected.
Processes and procedures may not be fully aligned at the start; a phased and evolving approach is anticipated.
While the UK seeks alignment with EU ETS, no formal integration is planned at this stage.

Practical Steps for Companies:
Prepare monitoring and reporting systems to meet UK ETS requirements.
Open UK ETS trading accounts or Maritime Operator Holding Accounts before the scheme becomes active.
Ensure allowance surrender processes are in place to meet deadlines and avoid penalties.

International UK ETS Expansion – Maritime Sector (Proposed 1 January 2028)

Scope and Timing:
Proposed to include international voyages starting or ending at UK ports.
Companies would report 100% of emissions but surrender allowances for 50% of total emissions, similar to EU ETS.
Applies to ships ≥5,000 GT, including those already covered under the 2026 domestic UK ETS.

Outlook:
Rules for international voyages and additional vessel types are still evolving.
Companies should adopt flexible compliance systems to prepare for:
Changes in voyage scope
Potential linking with EU ETS or other carbon markets
Interaction with upcoming IMO carbon intensity measures and national climate rules in other jurisdictions

Allowances and Compliance

UK ETS Allowances (UKAs):
One UKA corresponds to one tonne of CO₂ equivalent emitted.
Allowances can be purchased through primary market auctions or secondary market transactions once accounts are established.
Surrender of allowances is mandatory for verified emissions; failure to surrender will trigger penalties.

MRV Requirements:
Ships must have approved monitoring plans.
Annual emissions must be verified by accredited verifiers and reported to the UK ETS authority.
Verified emissions determine the number of allowances to be surrendered.

UK ETS Reporting Platform:
Companies and vessels should ensure:
The official “Manage your UK Emissions Trading Scheme reporting” online service is used for UK ETS compliance activities.
Emissions monitoring plans are applied for and managed through the platform.
Verified annual emissions reports are submitted via the platform within the applicable regulatory deadlines.
Relevant personnel are familiar with the platform’s functions and compliance timelines.

Penalties for Non-Conformance:
Publication of the company’s name.
Financial penalties per excess tonne of CO₂ equivalent emitted without surrendered UKAs.
Potential further enforcement or expulsion in cases of repeated non-compliance.

Act now

Ship Owners/ Managers/ Operators/ Verifiers are strongly encouraged to take proactive measures to ensure compliance, including:
Review onboard systems, monitoring, and reporting procedures in line with UK ETS domestic and future international requirements.
Prepare flexible MRV and allowance surrender systems to adapt to evolving guidance.
Open UK ETS trading accounts or Maritime Operator Holding Accounts in advance.
DBS verifiers will verify compliance with UK ETS requirements at the first company-level or shipboard audit.

For further guidance, companies should consult:

https://manage-emissions-reporting.service.gov.uk/landing
https://www.gov.uk/government/publications/participating-in-the-uk-ets/participating-in-the-uk-ets#registry

Share this post:

Related Posts

February 20, 2026

Panama – DMLC Part I