CSRD in Shipping: Obligations for Shipping Companies and Shipowners
Author: Jeroen Berger • Publication date:
The European Union (EU) has established a new foundation for sustainability reporting with the Corporate Sustainability Reporting Directive (CSRD). This directive is part of the broader ESG framework, in which companies report not only on the E of Environmental (climate and environment), but also on the S of Social (labor, human rights and equality), and the G of Governance (management, supervision and internal control). As a result, the CSRD makes sustainability an integral component of the management report and embeds ESG accountability structurally into corporate operations.
Where sustainability reporting largely remained voluntary for years, this changes into a legally binding obligation for companies that already fell under the former Non-Financial Reporting Directive (NFRD) as of reporting year 2024. Large enterprises and listed companies must report in accordance with the European Sustainability Reporting Standards (ESRS). These standards, adopted by the European Commission, specify in detail which information must be disclosed on strategy, governance, risks, opportunities, targets and measurable indicators. The combination of legal enforceability and substantive depth marks a fundamental shift, transparency on sustainability attains the same status as financial reporting.
For the maritime sector the consequences are significant. As one of the most internationally operating and emission-intensive industries, shipping can no longer treat sustainability reporting as a reputational instrument. Under the CSRD, reporting becomes a structural part of fleet management, financing and strategic decision making. That requires a thorough redesign of data, systems and processes, so that compliance is safeguarded and insight arises into both the risks and the opportunities that the energy transition and global decarbonization pressure bring.
The directive, laid down in Directive (EU) 2022/2464, requires companies to systematically explain their business model, strategy, policies and governance structures. This always happens with concrete targets and measurable indicators that make progress visible. The principle of double materiality is central, companies report not only on their impact on climate and society, but also on how sustainability developments affect their continuity and value creation. For shipping this means that shipping companies and shipowners must show both how their fleet contributes to emissions and environmental impact, and how climate risks, stricter regulation and changing market expectations affect operations.
The introduction of the CSRD is phased. Companies with more than five hundred employees report from reporting year 2024 only insofar as they already fell under the NFRD, other large enterprises report on financial year 2027 with publication in 2028 and listed small and medium-sized enterprises on financial year 2028 with publication in 2029. The directive therefore affects both international seagoing shipping and coastal shipping and creates a direct need to prepare for data management, data access and independent assurance.
With the recent approval of the so-called stop-the-clock proposal, the second reporting wave, large enterprises, has shifted to publication in 2028 for financial year 2027, and the third wave, listed SMEs, to publication in 2029 for financial year 2028. Only companies that already fell under the former NFRD remain subject to reporting obligations from 2024. This deferral provides some breathing space, but does not make preparation less urgent. The intervening years must be used to set up systems, data flows and internal controls in a robust way, so that the sector is ready in time for tightened assurance requirements and a strong compliance position.
This article sets out step by step what the CSRD concretely means for the maritime sector. First, the obligations from the European Sustainability Reporting Standards (ESRS) are discussed. Next, the link is made with existing regulation, the European Monitoring, Reporting and Verification Regulation (MRV), the EU Emissions Trading System (EU ETS), the FuelEU Maritime Regulation and the international standards of the International Maritime Organization (IMO) for energy efficiency (Energy Efficiency Existing Ship Index, EEXI) and for carbon intensity (Carbon Intensity Indicator, CII). Together these frameworks form the operational basis on which sustainability reporting in shipping must be built.
The article then addresses the application of double materiality, governance and assurance requirements, as well as the specific challenges by segment and fuel type. The article concludes with an analysis of the most important pitfalls and the strategic next steps. It becomes clear that the CSRD is not merely a legal obligation, but can also grow into a strategic instrument for competitiveness, innovation and access to sustainable finance.
Scope and Obligations for Shipping Companies and Shipowners
Article 29a of Directive (EU) 2022/2464 from the Corporate Sustainability Reporting Directive (CSRD) requires parent companies of large groups to prepare a consolidated management report that includes ESG-compliant sustainability reporting. This report must make visible not only the sustainability impact of the group, but also how sustainability risks affect financial performance and continuity. It therefore goes further than reporting emission figures alone, strategic choices, risks and opportunities that determine the enterprise’s future prospects are explicitly brought into view.
Concretely, this means that companies systematically report on their business model, strategic objectives, policies, risks, opportunities and governance structures. This information must always be supported by key performance indicators (KPIs). The foundation for this is a double materiality analysis, which includes both the impact on society and the environment and the financial consequences for the company. The obligation extends across the full consolidation perimeter, and where necessary beyond it as well, additional information from the value chain must be added to guarantee a complete and consistent picture.
For the shipping sector this is particularly complex. Not only the company’s own fleet falls under the reporting obligation, but also joint ventures, charter arrangements and contract forms that materially contribute to the impact. Under time charters the commercial operation usually lies with the charterer, while under bareboat contracts the technical operation also shifts. Without clear agreements on data access and responsibilities, gaps arise in reporting. Contractual recording of data flows, usage rights and control mechanisms is therefore indispensable to safeguard the continuity and reliability of reporting.
In addition, activities that formally fall outside consolidation but are materially relevant must still be included. This prevents important emission or impact sources from remaining under the radar. The end result must be a verifiable, transparent and complete picture of the entire business operations, including chain effects.
It is noteworthy that companies that formally do not fall directly under the CSRD can voluntarily choose to report in accordance with the European Sustainability Reporting Standards (ESRS). When they apply the same methodology and assurance, a clear advantage arises. Transparency and reliable sustainability reporting are increasingly decisive for access to financiers, shippers and strategic partners. For the maritime sector this applies to an even greater extent, supply chains decarbonize at high speed, and shippers consciously choose shipping companies that demonstrably comply with international standards.
From this framework the focus in this article shifts to the practical translation of these obligations. The question is how the European Sustainability Reporting Standards (ESRS) convert these broad requirements into reporting items and data flows that are directly relevant for shipping companies and shipowners.
ESRS and Maritime Data Points
The Corporate Sustainability Reporting Directive (CSRD) refers directly to Delegated Regulation (EU) 2023/2772, which sets out the first set of European Sustainability Reporting Standards (ESRS). These standards form the substantive foundation of the reporting obligation and consist of three layers. First, there are the so-called cross-cutting standards, two general standards, ESRS 1 and ESRS 2, that apply to all companies and that lay the foundation for the double materiality analysis. Next, there are the ten topical standards, thematically organized around environment, social and governance. Finally, sector-specific standards will be developed over the coming years for individual industries to further deepen reporting.
For shipping, the cross-cutting and topical standards are directly relevant. The cross-cutting standards determine how companies must conduct their materiality analysis and how the reporting structure is set up. Within the topical standards, ESRS E1 Climate change occupies a central position. This standard requires companies to publish a transition plan with timeline, investment plans and reduction targets. In addition, they must fully report on Scope 1, Scope 2 and Scope 3 emissions, respectively the direct emissions from fuel combustion on board, the indirect emissions from purchased energy such as shore power, and the broader chain emissions in the supply and distribution chain. Total energy consumption and the fuel mix must also be recorded, as well as the financial impact of climate risks and opportunities.
For shipping companies and shipowners this means that diverse data points must be made accessible. Core information comes from noon reports and electronic logbooks, which record fuel consumption, speed and routes. These data are supplemented by bunker delivery notes, tank measurements and flowmeters as verification sources. The official datasets from the European Monitoring, Reporting and Verification Regulation (MRV) and the EU Emissions Trading System (EU ETS) provide validated emission figures, including CO2, CH4 and N2O. In addition, Automatic Identification System (AIS) logs and voyage management systems link transport performance to emission calculations, which is crucial for both the IMO Carbon Intensity Indicator (CII) and FuelEU Maritime. Onshore Power Supply (OPS) logs and energy management systems cover Scope 2 emissions, while maintenance and coating records under ISO 19030 provide insight into efficiency gains from technical measures.
However, the European Sustainability Reporting Standards (ESRS) are not limited to figures and datasets. Companies must also report on key performance indicators (KPIs) such as energy intensity per transport unit, reduction targets, internal carbon prices and scenario analyses. This asks for data management systems that are not only broad in scope, but also deep, with strict requirements for transparency, traceability and complete audit trails.
Because sector-specific ESRS for shipping are not yet available, shipping companies are currently filling this gap with so-called entity-specific disclosures. These are tailor-made disclosures that connect to the operational reality of the fleet, but that must ensure consistency and comparability with the ESRS.
This creates a tension. On the one hand the generic structure of the ESRS demands broad and uniform reporting, on the other hand the operational practice of shipping strongly depends on segment, sailing profile and fuel mix. The extent to which shipping companies succeed in connecting these worlds determines not only the credibility and comparability of their reporting, but also the strategic value that these reports deliver in the competitive arena.
Maritime Regulation and Data Flows
Where the European Sustainability Reporting Standards (ESRS) set out what companies must report, maritime regulation and international standards determine where the required data come from and how they must be verified. Together they form the operational backbone on which sustainability reporting in shipping can rest.
Since 2015, the European Monitoring, Reporting and Verification (MRV) Regulation has required ships of 5,000 GT and above that call at European ports to record per voyage data on CO2 emissions, distance traveled, cargo carried and time at sea. Since January 1, 2024, MRV has required CH4 and N2O to be monitored and reported in addition to CO2. As of January 1, 2025, the tonnage threshold will be lowered to 400 GT solely for offshore ships and general cargo ships, for other ship categories the threshold remains 5,000 GT. Fuel consumption can be determined via bunker delivery notes, tank measurements, flowmeters or direct CO2 measurements. Regardless of method, three core principles apply, consistency, transparency and verifiability. The MRV dataset therefore forms not only the basis for compliance, but also a reliable source for broader sustainability reporting under the CSRD.
MRV data feed directly into the EU Emissions Trading System (EU ETS). Voyages within the EU fall fully under the EU ETS, while for voyages to and from non-EU ports 50% of emissions must be attributed. The surrender obligation under the EU ETS is 40% in 2025 for 2024 emissions, 70% in 2026 for 2025 and 100% from 2027 for 2026. CH4 and N2O count under the EU ETS from 2026. This requires accurate voyage segmentation and a seamless link between MRV data and EU ETS obligations, to avoid both compliance risks and financial claims and to safeguard the compliance position.
On top of this, the FuelEU Maritime Regulation introduces from 2025 an increasing cap on the average greenhouse gas intensity of on-board energy use, calculated on a well-to-wake basis. That means that not only the combustion on board, tank-to-wake, is counted, but also the upstream emissions from production and distribution. The reduction path runs from 2% in 2025 to 6% in 2030 and up to 80% in 2050. For passenger and container ships there is moreover, as of January 1, 2030, a mandatory connection to shore power or the use of zero-emission technology in major EU ports, with expansion to all EU ports with facilities from 2035.
At the global level, the International Maritime Organization (IMO) introduced the Energy Efficiency Existing Ship Index (EEXI) and the Carbon Intensity Indicator (CII) in 2023. The EEXI focuses on technical efficiency, where ships are often modified through engine derating, propeller optimization or energy-efficient retrofit measures such as Engine Power Limitation (EPL) or shaft power limitation (ShaPoLi). The CII measures operational carbon intensity in relation to transport performance and assigns ships an annual rating from A through E. Three consecutive D ratings or a single E rating require a corrective plan in the Ship Energy Efficiency Management Plan (SEEMP).
International standards reinforce this framework. ISO 19030 provides a uniform method for monitoring hull and propeller performance, while ISO 14083 standardizes the calculation of logistics emissions on a well-to-wake basis. By linking these standards to EU MRV, EU ETS, FuelEU Maritime and IMO EEXI and CII, an integrated system of data flows emerges that not only supports legal compliance, but also guarantees the verifiability and comparability of CSRD reports.
This is how the bridge is built between daily operations and formal reporting. From bunker delivery note to shore power invoice and from AIS log to maintenance record, every data flow is part of a legally sound and audit-proof whole. At the same time, this system delivers valuable management information for shipping companies, insight into fuel efficiency, route optimization and cost control. Maritime data collection thus becomes not only a means to comply with regulation, but also a strategic instrument for innovation and competitiveness.
Data Architecture and ESRS Data Points
A complete report under the Corporate Sustainability Reporting Directive (CSRD) asks for more than loose datasets and separate records. An integrated data architecture is needed in which operational data are systematically linked to the requirements of the European Sustainability Reporting Standards (ESRS). Only within a transparent, verifiable and audit-proof system can shipping companies meet their legal obligations and create value for operational control and strategic decision making.
The basis lies in noon reports and electronic logbooks, which record crucial information on fuel consumption, speed, position and weather conditions. This forms the core of Scope 1 emissions and of the energy performance of ships. By linking these data to voyage management systems reliability increases and the risk of errors from manual entry is strongly reduced.
A second building block is formed by the datasets from the European Monitoring, Reporting and Verification (MRV) Regulation and the EU Emissions Trading System (EU ETS). Because these data are officially validated, they provide the necessary reliability for both compliance and the financial settlement of emission allowances. Their direct alignment with ESRS E1 Climate change also makes them a key source for sustainability reporting.
On top of this, AIS logs and voyage management systems add an indispensable dimension. They link routes, speeds and time at berth to emission calculations. They are therefore essential for the IMO Carbon Intensity Indicator (CII) and FuelEU Maritime, and for key performance indicators such as emission intensity per transport unit.
For Scope 2 emissions, shore power logs and energy management systems are indispensable. They provide verifiable evidence of electricity use during port stays and link to both ESRS E1 and FuelEU Maritime. Invoices and meter readings strengthen reliability and provide robust substantiation for external auditors.
Finally, maintenance and coating records under ISO 19030 add value. They make visible how technical measures, such as hull cleaning, antifouling or propeller optimization, contribute to fuel efficiency and emission reduction. Combined with fuel consumption data, this creates a complete picture of both operational performance and decarbonization measures.
The key, however, lies not only in data recording, but especially in how this information is managed. Data lineage, version control and authorizations must unambiguously record who entered data, which transformations were applied and how validation took place. Audit trails and verification certificates ensure that auditors assess not only the figures, but also the full chain of evidence behind them.
This creates a robust data architecture in which every information flow, from bunker delivery note to shore power invoice and from AIS log to maintenance record, is logically embedded. The result is a system that is not only legally sound, but also strategically valuable. It provides insight into emission reduction, operational efficiency and cost control. Data management in shipping thus becomes more than a compliance instrument, it becomes a steering tool that guides innovation, investment and competitiveness.
Double Materiality for Seagoing Shipping
One of the core principles of the Corporate Sustainability Reporting Directive (CSRD) is the concept of double materiality. This principle states that companies report not only on their own impact on the environment and society, but also on how sustainability developments affect their financial performance, continuity and value creation. For the maritime sector, which operates at the intersection of global trade, energy transition and geopolitical uncertainty, this principle has a particular significance.
The first dimension concerns the so-called inside-out approach. Here the central question is which influence the fleet and the operations have on climate and society. For shipping companies this includes reporting emissions, fuel mix, waste streams and social factors such as working conditions and safety on board. It is the obligation to make visible the environmental and social footprint of the company, including the effects in the value chain.
The second dimension is the outside-in approach. This looks at how external sustainability developments affect the company itself. For the shipping sector this concerns, for example, the financial and operational consequences of CO2 pricing, stricter IMO and EU standards, changing fuel prices, port restrictions and the increasing pressure from shippers who want to decarbonize their supply chains. Physical climate risks, such as extreme weather and rising sea levels, also fall under this and can have direct impacts on routes, assets and investment decisions.
Combining both perspectives requires a structured materiality analysis. Relevant topics are identified, weighed and prioritized in close dialogue with stakeholders such as financiers, customers, regulators and crews. For shipping companies this means that they must continuously update and refine their materiality matrix. Only then does a complete picture arise of where the greatest risks and opportunities lie.
Double materiality forces the sector to look beyond compliance alone. It makes visible how sustainability becomes intertwined with strategic choices, investment plans and commercial relationships. For shipping companies and shipowners that apply this principle in full, reporting becomes a means to guide innovation, access sustainable finance and gain competitive advantage in an increasingly demanding market.
Governance and Assurance Requirements
The Corporate Sustainability Reporting Directive (CSRD) elevates sustainability reporting to the highest level of corporate governance. Where environmental and performance data were often seen as an operational responsibility, the directive places ultimate responsibility explicitly with the executive board and the supervisory board. They must formally approve the sustainability reports and oversee the reliability and transparency of the underlying data flows. Sustainability reporting thereby attains the same status as financial reporting, a strategic dossier that directly affects reputation, bankability and license to operate.
A solid governance structure is indispensable. In practice this means that different functions must align seamlessly, Health, Safety, Security, Environment and Quality (HSSEQ) teams that oversee safety, environmental and quality data, Fleet Performance departments that monitor operational and fuel data and IT teams that manage the technical infrastructure for data management and reporting tools. Only when these components are brought together in an integrated control framework does a system arise that supports both internal steering and external assurance.
In addition to governance, the CSRD imposes an assurance obligation. From the first reporting year, the sustainability report must be subjected to an independent external review. This starts with limited assurance, the auditor confirms that there are no indications of material misstatements. This review is based on plausibility and sampling. The European Commission will adopt EU-wide standards for limited assurance no later than October 1, 2026, based on International Standard on Sustainability Assurance 5000 (ISSA 5000). Until then, member states may apply national frameworks. By October 1, 2028, reasonable assurance is expected to be possible. Whereas limited assurance primarily checks whether the report is likely correct, reasonable assurance requires a positive opinion based on in-depth examination, detail testing and extensive audit trails. For shipping companies and shipowners this means that their data management and internal controls must already be set up so robustly that they can meet these stricter requirements without major adjustments.
Those who put governance and assurance on the agenda too late run significant risks, compliance risks, reputational damage and loss of access to ESG-driven financing and strategic partnerships. Financiers, insurers and customers attach increasing value to reliable, verifiable sustainability information. Shipping companies that professionalize their governance structure and assurance processes early gain a demonstrable advantage. They show not only compliance but also transparency, reliability and leadership, qualities that make the difference in an increasingly strict and competitive maritime market.
Implementation Roadmap for Shipping
The introduction of the Corporate Sustainability Reporting Directive (CSRD) in shipping asks for more than isolated measures or ad hoc solutions. Only a structured and carefully developed roadmap enables shipping companies to meet their reporting obligations and derive strategic value from them. The roadmap below shows how compliance and value creation can go hand in hand.
Step 1: Baseline Assessment and Gap Analysis
The starting point is a clear baseline assessment. Which entities, ships and joint ventures fall within the consolidation perimeter, which sustainability data are already available and which are still missing. A gap analysis makes visible where systems fall short and which data flows must be opened up. This provides a concrete foundation for further implementation.
Step 2: Double Materiality Analysis
Shipping companies then determine which topics are material. This happens from two perspectives, the impact of the fleet on climate and society on the one hand, and the influence of sustainability developments on financial performance and continuity on the other. This analysis must be tailored to fleet type, sailing profile and fuel mix, and take place in dialogue with stakeholders such as customers, financiers and suppliers. The outcomes provide not only legal certainty, but also direction for investment decisions and innovation.
Step 3: Data Governance and Internal Controls
Attention then shifts to the design of data flows. Noon reports, bunker delivery notes, flowmeters, AIS logs and voyage management systems are integrated into a robust data architecture. Transparency, traceability and verification are key concepts. By systematically linking fuel data to voyage and emission data, a verifiable foundation is created that is not only audit-proof, but also usable for operational optimization.
Step 4: Translation to ESRS Requirements
The collected data must then be linked to the reporting requirements of the European Sustainability Reporting Standards (ESRS). This concerns among other things Scope 1, Scope 2 and Scope 3 emissions, energy intensity per transport unit, reduction targets, transition plans and scenario analyses. Because sector-specific standards for shipping are still under development, shipping companies are temporarily supplementing this with so-called entity-specific disclosures, based on international frameworks such as ISO 14083 and ISO 19030. This keeps reporting consistent, comparable and credible.
Step 5: Process Description and Audit Dossier
In this phase, processes and responsibilities are formally established. Who owns which data, how validation takes place and which controls are applied. These arrangements are embedded in existing management systems such as the Ship Energy Efficiency Management Plan (SEEMP) Part III and the International Safety Management (ISM) Code. By involving an independent verifier at an early stage, the audit dossier can be built up and tested in time. This prevents unpleasant surprises at the first assurance audit.
Step 6: Reporting and Publication
The final step is formal reporting and publication. The sustainability report is prepared in accordance with the ESRS structure and provided with eXtensible Business Reporting Language (XBRL) tagging, so that the information is internationally comparable and machine readable. Publication takes place simultaneously with the annual report and strengthens both the compliance position towards regulators and the communication towards customers, financiers and partners.
Conclusion of This Section
When shipping companies carefully follow this roadmap, the CSRD changes from an obligation into a lever for competitiveness. The result is not only legal compliance, but also stronger operational insight, greater confidence among financiers and a clear position in a market where sustainability and transparency are increasingly decisive for success.
Segments, Routes, Fuels and Systems
Although this roadmap provides a generic framework, practical application differs widely by ship type and sailing profile. The sustainability challenges within seagoing shipping are far from uniform and vary by segment, route profile, fuel mix and supporting systems. Each part of the fleet has its own combination of technical constraints, operational requirements and regulatory pressure. CSRD reporting must therefore be set up not only in a generic way, but also aligned with the specific context of different ship types and markets.
Deepsea Container and Bulk Shipping Companies
This fleet operates with ships above one hundred thousand DWT on intercontinental routes. They typically use heavy fuel oil (HFO), very low sulfur fuel oil (VLSFO), LNG and in pilot projects methanol. For this segment the EU Emissions Trading System (EU ETS) applies fully for intra-EU voyages and for fifty percent on voyages to or from non-EU ports. FuelEU Maritime moreover requires a phased reduction of the greenhouse gas intensity of fuel, which makes investments in dual-fuel engines, shore power facilities and alternative energy carriers unavoidable. The Energy Efficiency Existing Ship Index (EEXI) often forces technical modifications such as engine derating or propeller retrofits. Operational measures, including route optimization and hull cleaning, are crucial to keep the Carbon Intensity Indicator (CII) at an acceptable level.
Tanker, Gas and Chemical Shipping
This segment transports oil, chemicals and LNG and entails significant safety and emission risks. Monitoring therefore focuses not only on fuel consumption, but also on temperature, pressure, liquid levels and leak detection. ISO 14083 provides a methodological framework for emission calculations, while the Greenhouse Gas Protocol classifies upstream emissions from fuel production in Scope 3 category 3 and downstream distribution in category 9. Compliance with the Energy Efficiency Existing Ship Index (EEXI) requires retrofits ranging from slow steaming to wind-assisted ship propulsion (WASP). LNG ships moreover have a reporting obligation for CH4 and N2O emissions since 2024, which directly affects the accuracy and completeness of emission inventories.
Shortsea Shipping Companies, Ro-Ros and Heavy-Lift Shipping Companies
Ships in this segment are generally smaller than forty thousand GT and sail mainly within Europe. They primarily use marine gas oil (MGO), marine diesel oil (MDO) or LNG. Because their routes are largely within the EU, they fall fully under the EU Emissions Trading System (EU ETS). For ro-ros and car carriers, loading and unloading processes play a key role, because shore power use and energy efficiency strongly depend on them. Heavy-lift vessels require precise recording of ballast and stability data, which are indispensable for EEXI calculations and operational safety.
Reefers, Offshore Support and Supply Vessels
These ships are characterized by high energy consumption for auxiliary functions such as cooling, dynamic positioning and specialized equipment. Optimizing these processes is crucial to keep CII ratings within the standard. Tugs and dredgers also have strong fluctuations in load and cyclical fuel consumption. For them, the Monitoring, Reporting and Verification (MRV) focuses primarily on CO2 emissions and transport work, while FuelEU Maritime imposes additional requirements. In addition, between 2025 and 2035 the obligation may arise to use shore power during longer port stays, which has far-reaching consequences especially for port-focused operations.
Passenger Shipping, Ferries and Cruise Ships
The passenger segment has an entirely distinct profile. FuelEU Maritime stipulates from 2030 that passenger ships use shore power or zero-emission technology during port stays in major European ports, with expansion to all ports with facilities from 2035. Cruise ships often work with a complex fuel mix of HFO, LNG and hybrid systems, which means that emission monitoring has multiple dimensions. In addition to fuel-related emissions, wastewater management, waste streams and social indicators play a central role. The presence of thousands of passengers and crew significantly increases the social impact. For Scope 3, passenger travel, provisioning of food and fuels and logistics chain activities must also be fully included.
Conclusion of This Section
This overview makes clear that the application of CSRD, ESRS and maritime regulation can never be a one-size-fits-all approach. Each segment requires its own materiality assessment and a carefully chosen mix of operational measures, technical investments and data collection. This diversity underscores the need for a robust data architecture that not only ensures legal compliance, but also contributes to innovation, cost control and competitiveness in a sector under global scrutiny.
Scope 3 and Value Chain Emissions
The Greenhouse Gas Protocol distinguishes three emission scopes that together form a company’s full emission profile. Scope 1 covers the direct emissions released during the combustion of fuels on board. Scope 2 concerns the indirect emissions arising from purchased energy, for example electricity via shore power during port stays. Scope 3 includes all other indirect emissions in the value chain, both upstream at suppliers and downstream in distribution and the use of services.
For shipping, Scope 3 is crucial. The sector operates in complex international chains in which fuel production, logistics links and customer processes leave a substantial emission footprint. Upstream this concerns emissions from extraction, refining and distribution of bunker fuels, but also the transport and delivery of spare parts and provisions. Downstream includes the further distribution of maritime services, such as intermodal transport, transshipment in ports, storage facilities and the logistics of end users.
This means that shipping companies must not limit their reports to the tank-to-wake emissions of their ships, in other words the direct emissions during sailing. The Corporate Sustainability Reporting Directive (CSRD) requires a broader approach, the full well-to-wake cycle of fuels must be included, as well as the emissions associated with the distribution of transported goods and services. Only then does a complete and reliable picture of the fleet’s actual climate impact arise.
To structure this process, ISO 14083, based on the Global Logistics Emissions Council (GLEC) framework, offers an internationally recognized methodology. This standard prescribes uniform calculation rules and emission factors, which makes the data of different shipping companies mutually comparable. This not only increases transparency for regulators and investors, but also strengthens cooperation within chains.
Structurally including Scope 3 in sustainability reports moreover provides shipping companies with direct strategic advantages. By gaining insight into the emission intensity of different chain links, it becomes visible where the greatest reduction opportunities lie. This can range from stricter requirements for fuel suppliers to collaboration with logistics partners to realize more efficient routes or transshipment processes. For customers and financiers this serves as evidence of proactive climate policy, which builds trust and facilitates access to capital.
Scope 3 thus grows from a complex reporting obligation into a powerful strategic ESG instrument that provides deep insight into value chain impact and optimization opportunities. This enables shipping companies not only to comply with legislation, but also to strengthen their position in decarbonizing supply chains. In a world where chains are increasingly assessed on their total climate impact, this can make the difference between lagging behind or leading the transition.
Pitfalls and Mitigations
Implementing the Corporate Sustainability Reporting Directive (CSRD) in the maritime sector brings substantial challenges. Not only the technical complexity of ship operations, but also the contractual and organizational interweaving of the sector means that reporting pitfalls are lurking. Early identification and mitigation of these risks is crucial to ensure both compliance and strategic value.
A first pitfall is handling multi-fuel bunkers and dual-fuel systems. Ships that operate on a combination of LNG, methanol, ammonia or conventional fuel oil require precise allocation of fuel consumption and emissions. The situation becomes even more complex when ships are part of pooling arrangements, in which revenues and fuel flows are distributed across multiple owners and charterers. Without uniform agreements on calculation methods and allocation, transparency quickly erodes, with risks to both the credibility of reporting and the correct settlement of costs under the EU Emissions Trading System (EU ETS).
A second critical issue is the allocation of responsibilities between owners and charterers. Under time charters and bareboat arrangements, crucial operational data such as fuel consumption and voyage information often reside with the charterer, while the owner remains responsible for reporting. When contracts do not contain clear provisions on data access, usage rights and responsibilities, gaps arise that render reports incomplete or unverifiable. Early contractual definition of data rights and responsibilities is therefore indispensable.
A third risk concerns the allocation of emissions on international voyages. For routes between EU ports and non-EU ports, half of the emissions must be recorded under the EU ETS. This requires precise voyage segmentation and a verifiable methodology to correctly attribute distances and emissions. Misallocation can lead to compliance issues, financial claims or reputational damage.
In addition, there is the tension between well-to-wake and tank-to-wake calculations. For alternative fuels it is insufficient to report only the direct emissions on board. The CSRD requires that upstream emissions from production, transport and distribution also be included. The lack of harmonized emission factors can lead to divergent outcomes, which makes transparency about the assumptions and methodology chosen essential.
Finally, Scope 3 data from customers and logistics partners presents a structural challenge. Downstream emissions require access to data on transport distances, cargo mass, transshipment and storage. These data are often spread across multiple links in the chain and not always standardized. Without digital links, contractual agreements and sector-wide standards, Scope 3 reporting remains fragmented, which undermines the credibility of the sustainability report.
By proactively addressing these pitfalls, an opportunity arises as well. Clear contractual agreements, standardized calculation methods, digital data links and transparent documentation make reporting not only a legal obligation, but also a strategic asset. Shipping companies that lead in this show not only compliance and reliability, but also position themselves as leaders in a sector under global pressure to decarbonize.
Strategic Next Steps and Outlook
The introduction of the Corporate Sustainability Reporting Directive (CSRD) is for international shipping more than a new reporting obligation. It marks a structural turning point, fleet management, data governance and decision making will be durably reformed. Shipping companies that embrace the transition in time and in full distinguish themselves not only through compliance, but above all by creating a sustainable competitive advantage in a market increasingly driven by the demands of shippers, financiers and regulators.
The first step is a double materiality analysis that exposes both the social impact of the fleet and the financial consequences of climate and energy transitions. When this analysis is carried out in collaboration with stakeholders, a clear compass emerges for investments in fuels, efficiency and innovation. In parallel, shipping companies must digitize and integrate their data flows, so that European Monitoring, Reporting and Verification (MRV), EU Emissions Trading System (EU ETS) and IMO data come together in one robust platform. This delivers not only verifiable reports, but also strategic insight for cost optimization and innovation.
From 2030 through 2040, sustainability reporting thus becomes not a burden, but a license to operate and a strategic lever in commercial negotiations and investment decisions. Shipping companies that now invest in alternative fuels, shore power and digital data architectures position themselves as preferred suppliers in supply chains that decarbonize at speed.
The CSRD thus changes from legal obligation into a strategic ESG instrument that contributes to transparency, market positioning and investment decisions. Those who look ahead now will soon gain advantage not only in compliance, but also in innovation, market position and trust. For visionary shipping companies this is a chance to set a course toward nothing less than market leadership in the sustainable maritime economy.
Would you like to delve into the exact legal basis of the CSRD? Consult the official publication of Directive (EU) 2022/2464 on EUR-Lex, so that you have the most up-to-date and complete information. This provides a solid foundation for both strategic and legal decision making.