Four regimes, four calculation chains, one operational dataset.

Plan which data feeds which verification and deadline without collapsing FuelEU, MRV, ETS and CII into one generic “emissions report”.

Written by: Faromo · Product and maritime domain teamReviewed by: Faromo · Technical and regulatory reviewLast reviewed:

2026 is where the first FuelEU verification period meets full ETS phase-in.

FuelEU Maritime has applied since 1 January 2025. The first reporting period was calendar year 2025, and the first ship-specific FuelEU report was due to the verifier by 31 January 2026. The same annual cycle continues with a 31 January deadline in later verification periods. The initial target reduces the 91.16 gCO₂eq/MJ reference value by 2% for 2025–2029.

EU MRV provides a data foundation for FuelEU calculations but is not the same output. MRV has monitored CH₄ and N₂O alongside CO₂ since 2024, with the verified annual ship report due by 31 March. EU ETS applied a 40% and 70% phase-in to CO₂ for 2024 and 2025; in 2026 the obligation reaches 100% and CH₄ and N₂O enter ETS scope. IMO DCS/CII uses a separate flag/Administration chain, thresholds and timeline.

Scope and core capabilities

1. Applicability register

Record GT, vessel type, commercial activity, responsible company, flag, EU/EEA port calls, offshore/general-cargo status and possible exemptions for every ship. Do not reduce FuelEU, MRV, ETS and CII scope to one checkbox.

2. Monitoring plan and method

Document whether fuel consumption is determined from BDNs, tank readings, flow meters or another method, together with data flow, ownership, controls and change management. Verify MRV and FuelEU templates against the authorized system and verifier expectations.

3. Voyage and energy ledger

Reconcile departure-arrival ports, time, berth duration, voyage scope, fuel and electricity, distance, time at sea, cargo/transport work and applicable ice-class data under the same reporting-period identity.

4. Fuel pathway and all GHGs

Manage mass, LCV, WtT and TtW factors, CO₂/CH₄/N₂O, engine/consumer unit, methane slip and sustainability certification for each fuel. Do not mix fossil defaults with verified actual values.

5. Verification and deadline calendar

Track the FuelEU report by 31 January, verified MRV report by 31 March, DCS Statement of Compliance chain by 31 May/30 June and ETS surrender obligation as separate tasks with their own evidence.

6. Compliance-balance decision

After the verifier determines annual average GHG intensity and the compliance balance, manage banking, borrowing or pooling together with contractual, cost and next-period effects.

Workflow

  1. Lock the fleet scope matrix: Set the applicability owner, basis and period for each vessel and regime.
  2. Close data monthly: Reconcile noon, BDN, voyage, port and energy records without waiting for year end.
  3. Run readiness review before verification: Close missing fuel pathway, GHG, voyage-scope and methodology gaps before report delivery.
  4. Link external outcomes back to internal records: Keep verifier outcome, platform submission, compliance balance, allowance and document traceable to source data.

Operational outcomes

  • Avoid losing 31 January, 31 March and DCS/ETS dates under one generic annual-report task.
  • Reduce the risk of treating a CO₂-only internal estimate as a 2026 ETS or FuelEU CO₂eq result.
  • Find gaps among noon reports, BDNs, voyages and verifier output before period close.
  • Make banking, borrowing and pooling decisions only after a verified compliance balance.

Frequently asked questions

Since when has FuelEU Maritime applied?

The Regulation generally applies from 1 January 2025, while Articles 8 and 9 on monitoring plans began applying on 31 August 2024. Current vessel, voyage and country-specific application should be verified with competent sources and the verifier.

Is the FuelEU report the same as the EU MRV emissions report?

No. They draw on shared operational and fuel data but differ in content, calculation and deadlines. The FuelEU report is provided to the verifier by 31 January; the verified MRV ship report is generally submitted to the relevant authority, flag and Commission by 31 March.

Which gases are included in the EU ETS calculation in 2026?

CH₄ and N₂O join CO₂ in maritime ETS scope from 2026. Phase-in reaches 100% for applicable vessels, while voyage, vessel and derogation scope still requires separate assessment.

Can Faromo’s emissions PDF be submitted as the statutory report?

No. The current PDF is an internal period summary. It does not replace accredited verification, statutory templates, complete required GHG and pathway data or processes in THETIS-MRV, the FuelEU Database, Union Registry or Administration/GISIS.

Primary sources