- Major GHG regulatory deadlines in 2025 include EU MRV reporting (March), EU ETS allowance surrender (September), and IMO DCS Fuel Oil Consumption Report submission (May).
- Ship owners must comply with new EU ETS and FuelEU Maritime regulations while ensuring accurate emissions data for verification and reporting.
- DNV advises early data submission, contractual reviews, and strategic planning to minimize compliance costs and ensure regulatory adherence.
With the EU ETS and FuelEU Maritime regulations adding new layers of complexity, 2025 will be a critical year for GHG compliance in the maritime industry. Ship owners, managers, and other stakeholders must meet strict deadlines for emissions reporting and verification while adapting to evolving environmental policies. DNV reports that it remains committed to guiding companies through these requirements, ensuring compliance and cost efficiency.
Energy Efficiency Compliance After Alterations or Conversions
The drive for decarbonization has made regulatory compliance a top priority. While EU MRV and IMO DCS reporting are now routine, EU ETS and FuelEU Maritime introduce new challenges. Ship managers must ensure accurate emissions data submission and verification to avoid penalties.
Key Deadlines in 2025:
- EU MRV Verification Submission: 31 March
- EU ETS Company Emissions Report Submission: 31 March
- EU ETS Allowance Surrender: 30 September
Union Registry Emissions Data Requirements
The Maritime Operator Holding Account (MOHA) holder or verifier must enter emissions data into the Union Registry. This ensures transparency and aligns with international emission reduction commitments.
Deadline: 1 April 2025
UK ETS and FuelEU Maritime Compliance
While the UK has not yet implemented ETS for shipping, companies must comply with UK MRV reporting. FuelEU Maritime, effective from January 2025, requires vessels to have an approved monitoring plan on board.
DNV urges companies to review commercial contracts and compliance strategies.
Partial FuelEU Emissions Report
If there is a change in ship management, a partial FuelEU Emissions Report must be submitted. DNV will facilitate this process starting Q1 2025.
IMO DCS Fuel Oil Consumption Report (FOCR) Submission
The IMO DCS data contributes to Carbon Intensity Indicator (CII) ratings and SEEMP Part III compliance. Ensuring high data accuracy is crucial.
Deadline: 31 May 2025
SEEMP Part III Compliance for 2026–2028
To ensure long-term compliance, ship operators must:
- Develop a three-year CII reduction plan
- Set annual efficiency improvement targets
- Implement and monitor energy-saving measures
Deadline: 1 January 2026 (Preparation should begin in 2025)
Recommendations from DNV
DNV strongly recommends:
- Early data submission for timely verification and compliance
- Thorough review of contractual agreements to prevent financial and operational risks
- Utilization of My Services on Veracity for performance tracking and regulatory monitoring
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Source: DNV
