EU MRV Regulation 2015/757 for Maritime Shipping: Foundation and Impact
Author: Jeroen Berger • Publication date:
The Monitoring, Reporting and Verification (MRV) Regulation (EU) 2015/757 provides the foundation for emission transparency in European maritime shipping. It requires shipping companies to measure, report and have independently verified, for each voyage, the fuel consumption and the emissions of carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O). This creates one uniform data layer that is not only legally defensible, but also decisive for costs, compliance and competitiveness.
The system is fully standardized, from the onboard measurement method and the assessment by an accredited verifier to the issuance of the Document of Compliance (DoC). Standard formats for monitoring plans, emissions reports and DoCs ensure that reporting is consistent and verifiable. What began as a transparency instrument has now become the legal foundation of the European Emissions Trading System (EU ETS). The same dataset also feeds the calculation of fuel intensity in FuelEU Maritime and the assured sustainability reporting under the Corporate Sustainability Reporting Directive (CSRD).
This interconnection makes MRV data strategic. The figures no longer determine only whether a shipping company meets its reporting obligations, but also which financial liabilities follow, which reductions are recognized and how banks and charterers assess the risk profile of a company. MRV is therefore not merely an administrative duty, but a structural lever in the energy transition of the maritime sector.
This article sets out the building blocks of the system step by step. It begins with the scope of application: which ships and operations are covered and which exemptions apply. It then addresses the monitoring methods, the monitoring plan and the annual cycle of reporting and verification. Next, it discusses the geographical scope, the linkage with the EU ETS and the downstream effects on FuelEU Maritime and CSRD. Finally, it examines quality principles, cargo determination, the audit trail, sanction mechanisms and the implementation by the Dutch Emissions Authority (NEa), supplemented with practical checklists and a reflection on the strategic value of MRV for compliance, efficiency and investment decisions.
Who Falls Under the MRV (2025): Ship Types, GT Thresholds and Scope
Since 2025, in addition to seagoing ships of 5,000 gross tonnage (GT) and above, general cargo ships from 400 to 4,999 GT and offshore ships from 400 GT have also been subject to the obligations of the MRV Regulation (EU) 2015/757. The application remains route-based: every voyage that departs from, arrives in, or takes place entirely between ports in the European Economic Area (EEA) automatically falls within the obligations. This also applies to the outermost regions, such as the Azores, Madeira and the Canary Islands, which are legally fully equated with other EEA ports.
Since Brexit, voyages to and from the United Kingdom (UK) are treated differently. British ports are now designated as non-EEA ports. This means that shipping companies must report the full emissions of such voyages for MRV purposes, while under the EU ETS only 50 percent counts. This dual logic creates a clear distinction between legal reporting and financial settlement. In practice, accurate demarcation of voyage boundaries is therefore not only a compliance issue, but also a direct factor in final ETS costs.
Within this scope, the definition of offshore ship is particularly important. This concerns vessels designed or certified for work on or near offshore installations, including pipelayers, cable layers, drillships, wind turbine installation vessels, dredgers and support vessels. The qualification depends on the nature of the operation. For example, an Anchor Handling Tug Supply (AHTS) vessel that calls at a platform for a crew change is deemed an offshore ship and therefore subject to MRV, even if no cargo is handled. For shipping companies this means that such calls must be fully recorded as port calls so that ETS calculations and charter agreements remain correct.
There are also explicit exemptions. Warships, state-owned vessels without commercial use, fishing vessels and wooden ships of primitive build are excluded. Ships that only bunker, supply or are in drydock also fall outside the scope, because these activities are not regarded as port calls. The same applies to emergency stops. Ship-to-ship (STS) transfers at sea are also not regarded as port calls; in such cases the emissions are allocated to the voyage between the previous and the next port call. These exemptions prevent voyages from being artificially fragmented and improve comparability between ships and years. They also provide clarity for shipping companies when planning operations and allocating costs.
The extension to smaller ships and additional emissions increases the need to define procedures precisely. Shipping companies that updated their monitoring plans in time and explicitly safeguarded the logic for port calls, cargo definitions and emission factors create not only legal certainty but also predictability of future ETS obligations. In this way they reduce the risk of fines or corrections and build datasets that are directly usable for fuel budgeting, contract management with charterers and benchmarking of fleet performance.
With this framework in place, it is clear who falls under the MRV obligations. The focus now shifts to how emissions and transport performance are recorded in practice in a legally verifiable way: the monitoring methods and data fields that form the core of each MRV cycle.
What and How to Monitor Under the EU MRV Regulation
The MRV Regulation (EU) 2015/757 prescribes four methods for determining fuel consumption. Depending on the technical installations on board, these methods may be applied in parallel, provided that the choices are consistently recorded in the monitoring plan (MP) and remain verifiable by an accredited verifier. This flexibility allows the method to be aligned with the operational practice of a ship, but also demands strict discipline and documentation. Monitoring is therefore not only a legal obligation but also a strategic instrument that delivers value for fuel management, cost control and commercial transparency.
Method 1 combines bunker delivery notes (BDNs) with periodic tank measurements. Fuel consumption is calculated on the basis of the delivered quantities, supplemented with inventories of tank levels and density values. Because inaccuracies directly affect the calculation, it is essential that losses and corrections are recorded completely and transparently. This ensures reproducibility for verification, provides shipping companies with better insight into bunkering efficiency and creates a defensible evidentiary record toward suppliers and charterers.
Method 2 is based on daily soundings of all fuel tanks. Bunkerings and debunkerings are recorded and linked to density values. This method can produce high reliability if measurements are performed accurately and consistently. It requires discipline from the crew, but provides the company with a very detailed picture of daily fuel consumption, which significantly increases the value of noon reports and performance analyses.
Method 3 uses certified flow meters that continuously measure mass and volume flows per combustion source. Because the data flows directly into the monitoring stream, timely calibration and correct density values are essential. Incorrect calibration leads not only to legal problems during verification but also to distorted fuel management and inaccurate cost analyses. The strategic advantage of flow meters is that they provide near real-time insight into efficiency and fuel consumption, enabling direct optimization.
Method 4 determines fuel consumption indirectly on the basis of direct emission measurement. Gas concentrations and exhaust flows are continuously monitored. This approach is particularly relevant for ships running on liquefied natural gas (LNG) or alternative fuels such as e-methanol or bio-LNG. The method provides detailed emission profiles but requires strict maintenance, calibration and data quality of the equipment. It is often combined with another method to increase reliability. Its advantage is that direct emission measurement is useful for innovation and validation of new fuels, which is valuable on the path to zero-emission solutions.
Regardless of the method, emissions of CO2, CH4 and N2O must always be calculated with emission factors set by the European Commission. An uncertainty analysis is also mandatory: the accuracy of the data must be quantified. For the verifier this is a hard benchmark, while for shipping companies it makes it possible to better manage risks and estimate ETS costs more predictably.
In addition to fuel consumption, companies must record additional voyage parameters, including departure and arrival port with date and time, distance at sea, time at sea excluding anchorage and cargo carried. The definition of cargo carried differs by ship type and is legally established. For tankers it is the cargo mass in tonnes, for LNG carriers the leading volume in cubic meters discharged and for ro-ro ships (vehicle carriers) a standard weight per vehicle transported. Together these parameters determine transport work: the product of distance and cargo. Transport work is the basis for efficiency indicators such as the Carbon Intensity Indicator (CII) and is increasingly used in commercial benchmarking and charter negotiations.
When data is missing due to technical failures or data loss, the data gap procedure laid down in the monitoring plan must be applied. This may consist of conservative estimates or interpolations based on comparable voyages. For the verifier this ensures dataset completeness, while for shipping companies it creates a transparent system that minimizes reputational and financial risks.
At the end of the calendar year, all data is consolidated in an emissions report that is reviewed by an accredited verifier. This report states the total emissions of CO2, CH4 and N2O and specifies which part falls under the EU ETS: 100 percent of emissions for voyages within the EEA and 50 percent for voyages to or from non-EEA ports. The same dataset also forms the basis for disclosure under the CSRD and for compliance checks under FuelEU Maritime. Monitoring therefore exceeds the role of legal obligation and becomes a strategic instrument that combines compliance certainty, financial predictability and operational optimization.
Monitoring Plan per Ship
The monitoring plan forms the foundation of the obligations under the MRV Regulation (EU) 2015/757. For every ship that falls within the scope of this regulation, a separate plan must be drawn up and submitted via THETIS-MRV, the digital platform of the European Commission and the European Maritime Safety Agency (EMSA). This platform is the central entry point for all monitoring plans, emissions reports and Documents of Compliance (DoCs). The monitoring plan is therefore not merely an administrative formality. It functions as the formal gateway to the annual reporting cycle and determines how emission data are collected, validated and stored. It is thus an anchor point for legal assurance, operational reliability and strategic data quality.
A monitoring plan contains ship-specific basic data such as the IMO number, ship type, technical characteristics and fuels used. It also records which monitoring methods are applied, how data is collected and validated, and which procedures apply when data is missing or incomplete. In addition, the plan explicitly defines how responsibilities are divided between crew, office staff and IT systems. This allocation is legally necessary, but also streamlines internal processes and prevents costly mistakes or duplication in daily practice.
The Dutch Emissions Authority (NEa) identifies six fixed components that must be included in every monitoring plan: ship details, a description of activities and cargo flows subject to MRV, procedures for handling data gaps, allocation of responsibilities, data quality assurance (including calibrations and reconciliation of bunker delivery notes (BDNs), noon reports and flow meter data) and finally a mechanism for continuous improvement. This last element requires companies to evaluate their procedures periodically and update them where necessary. This not only strengthens legal certainty, but also creates opportunities to make data flows more efficient and more valuable for operational and strategic decision-making.
A monitoring plan must be reviewed by an accredited verifier that complies with ISO 17029 and ISO 14065. Only after approval may the plan be submitted via THETIS-MRV to the competent authority. In the Netherlands, this is the NEa. This authority may request additional information or reject the plan if it does not fully meet the requirements. For ships that become subject to MRV from 2025, the monitoring plan must be submitted to an accredited verifier within two months of the first port call within the EEA. After approval, the plan must be submitted to the competent authority via THETIS-MRV within three months, in the Netherlands the NEa. This ensures that new ships are immediately and fully included in the compliance framework.
The monitoring plan is not a static document. Changes such as a retrofit, the installation of new measuring equipment, a change in the monitoring method applied or the appointment of a new operator under the International Safety Management (ISM) Code require revision. Each adjustment must be submitted again within two months and reviewed by the verifier. In this way the monitoring system remains demonstrably up to date not only at the initial submission but also after each operational or technical change.
A carefully prepared monitoring plan also has value beyond MRV compliance. The procedures and datasets it contains directly form the basis for calculations under the EU ETS and, from 2025 and 2026, also for FuelEU Maritime. For shipping companies this means that a solid monitoring plan not only provides legal certainty, but also establishes a consistent data layer that is strategically relevant for investors, banks and charterers.
Once the monitoring plan is operational and the first monitoring cycle is underway, attention shifts to the annual reporting and verification via THETIS-MRV. At that point it becomes clear how the choices set out in the monitoring plan translate into a complete dataset that stands up legally and provides strategic insights.
Geographical Scope and Port Call Rules
The obligations under the MRV Regulation (EU) 2015/757 have from the outset been designed as a route-based system. It is not the flag state or ship type that is decisive, but the departure and arrival point of the voyage. Every voyage that departs from, arrives in, or takes place entirely between ports within the European Economic Area (EEA) automatically falls under the obligations. The EEA includes all EU Member States, together with Norway and Iceland. The outermost regions, including the Azores, Madeira and the Canary Islands, are an integral part of this regime. For ships calling at these regions, the same reporting obligations apply as for those connecting European mainland ports.
Since Brexit, voyages to and from the United Kingdom (UK) have been treated differently. British ports are designated as non-EEA. This means that for MRV purposes, shipping companies must report the full emissions over the voyage distance, while under the EU ETS only 50 percent of those emissions are counted. This results in a clear split between legal reporting and financial obligation. For shipping companies it is crucial to apply this dual logic correctly, since any inaccuracy in voyage demarcation translates not only into compliance risk but also into direct financial consequences.
Central to this demarcation is the concept of port call. This is strictly defined as a port where a ship stops to carry out commercial activities, such as loading or unloading cargo, or embarking or disembarking passengers. Stops without a commercial character, such as bunkering, supply, maintenance, drydocking, waiting offshore or medical assistance, explicitly fall outside this definition. Such intermediate stops therefore do not count as port calls and have no impact on voyage boundaries. This strict distinction prevents datasets from being artificially fragmented and improves comparability between ships and years. For shipping companies this is more than a legal nuance: consistent application of the port call concept also strengthens the reliability of efficiency indicators and benchmarks, which are increasingly decisive in commercial negotiations.
For offshore ships, a specific exception applies. When they call at an installation or nearby port for a crew change, this is considered a port call. This applies only to offshore ships; for other ship types, crew changes without cargo or passenger handling do not count as commercial stops. Even without traditional cargo handling, a crew change qualifies as a commercial stop under the regulation. This provision closely aligns the legislation with the operational reality of the offshore sector, where crew changes are an essential part of the logistical cycle. Strategically, this means that support operations, often outside classical transport logic, also count in emission and cost calculations.
Ship-to-ship (STS) transfer outside port areas is a separate special case. When two ships exchange goods or fuels at sea, this is not regarded as a port call. Emissions during such operations are attributed to the voyage between the last and the next port call. This prevents a single voyage from being artificially divided into multiple segments and safeguards dataset consistency. For shipping companies this means that accuracy in voyage demarcation is not only legally required, but also the basis for reliable efficiency figures, predictable ETS costs and robust reporting under the CSRD.
Through this strict demarcation of geographical scope and port call rules, a uniform framework is created that provides clarity for shipping companies, verifiers and regulators. Companies know exactly when a voyage falls under the MRV obligations and how emissions must be correctly allocated. This chapter is therefore a pivotal point: the legal definitions of routes and stops directly feed into financial obligations under the EU ETS and simultaneously enhance the strategic value of the dataset for efficiency, benchmarking and investment decisions.
Link With the EU ETS
The inclusion of maritime shipping in the EU Emissions Trading System (EU ETS) as of 1 January 2024 marks a turning point in European climate policy. Whereas the MRV Regulation (EU) 2015/757 was until then primarily focused on transparency and verification of emission data, the EU ETS adds a direct financial dimension. Shipping companies must now purchase and surrender emission allowances annually, which makes monitoring and reporting directly linked to costs and risks. Without reliable MRV data, no ETS obligation can be calculated correctly. The two regimes are therefore inseparably linked: MRV provides the legal and data foundation, while the EU ETS makes that same data financially decisive for a company’s bottom line.
The EU ETS uses the same route logic as the MRV Regulation. For voyages between ports within the EEA, 100 percent of emissions are counted. For voyages departing from or arriving at a non-EEA port, 50 percent of emissions are included. Thus the legal demarcation of MRV is translated directly into an economic obligation. For shipping companies this means that any inaccuracy in voyage definition or port call leads immediately to financial losses. Data quality is therefore not only a compliance issue but also a decisive factor in cost control and profitability.
To give the sector time to adjust, implementation is phased in. In 2024, shipping companies must cover allowances for 40 percent of their ETS-liable emissions. In 2025 this rises to 70 percent, and from 2026 full coverage applies. This growth path creates temporary breathing space to stabilize processes, data flows and financial planning, but makes the end goal clear: full compliance. Companies that already link MRV data structurally with financial systems and risk management now gain a competitive advantage through predictable ETS costs and more effective emission reduction strategies.
Not all ships are included immediately. Ships under 5,000 GT remain outside the ETS until the end of 2026. In that same year, the European Commission will assess whether ships between 400 and 5,000 GT, including general cargo vessels, should also be included. Offshore ships of 5,000 GT and above will fall under the ETS from 2027. This phased expansion recognizes the technical and operational challenges of specific ship categories, while also providing a clear growth path to full coverage of the sector. For shipping companies this means that compliance exposure differs by fleet segment: some ships already face direct ETS costs today, while others still have time to prepare.
For now, only carbon dioxide (CO2) is covered under the ETS. From 2026, methane (CH4) and nitrous oxide (N2O) will also be included. This aligns with the MRV obligation to monitor and report these gases since 2024. For shipping companies this means that datasets being built today will soon have not only legal but also direct financial impact. From then on, inaccuracies or data gaps will no longer lead only to corrections but also to ETS costs. Data quality becomes a deciding factor between profitability and loss.
Implementation uses the same infrastructure as MRV. The annual emissions report includes a separate section calculating the ETS-relevant emissions, adjusted for the use of sustainable zero-emission fuels such as e-ammonia or bio-LNG. These adjustments are made in line with the European taxonomy. The competent authority then links this data to the central EU registry in which allowances are managed. Shipping companies must surrender the required number of allowances no later than 30 September each year. The legal reporting chain is thus seamlessly connected to financial compliance.
In this interplay, a triangle emerges that forms the core of European emission policy for shipping: MRV provides the data, the EU ETS assigns financial value to that data, and verification guarantees reliability. For shipping companies this means that investments in data quality, internal controls and audit procedures deliver double value. They limit legal risks, control financial liabilities and strengthen the strategic position of the company in a maritime market increasingly driven by the energy transition.
FuelEU Maritime and the Reused MRV Data Layer
With FuelEU Maritime coming into effect in 2025, the role of the MRV dataset shifts from volumetric emission reporting to the calculation of the greenhouse gas intensity (GHG intensity) of onboard energy use. This intensity is expressed in grams of CO2 equivalent per megajoule and calculated on a well-to-wake basis, from production of the fuel through to combustion on board. This makes the entire chain visible and gives the MRV dataset a new strategic significance that extends beyond compliance alone.
The basis of this calculation remains the same operational data already collected under the MRV Regulation (EU) 2015/757: fuel types, volumes consumed, energy use and sailing times. FuelEU Maritime builds on this with additional dimensions such as fuel-specific emission factors, chain discounts for Renewable Fuels of Non-Biological Origin (RFNBOs) and mass balance requirements to ensure the origin and integrity of sustainable fuels. As a result, the quality of the MRV dataset becomes even more decisive. Inaccuracies in fuel volumes, calorific values (Lower Heating Value, LHV) or fuel classification directly cause deviations in GHG intensity and may result in incorrect compliance assessments with tangible financial consequences.
The implications go beyond fines. Exceeding the standard leads to financial penalties, but companies can partly mitigate this through the pooling mechanism. Several ships or even multiple shipping companies may pool their performance in order to remain below the standard collectively. This creates a new market dynamic: companies with cleaner fleets can use their surplus to support others. In contractual practice this means that fuel clauses, proof of origin and pooling agreements must align seamlessly with the audit trail already required under MRV.
FuelEU Maritime is therefore more than an additional compliance framework. It links obligations directly with fuel procurement, charter negotiations and investment decisions. A fleet strategy aimed at alternative fuels such as e-methanol, bio-LNG or hydrogen carriers can only pay off when the MRV dataset correctly and verifiably records the right volumes, energy values and emission factors. If not, the risk is that investments in sustainable fuels will not be recognized and still result in ETS or FuelEU penalties.
The conclusion is clear: FuelEU Maritime and the MRV Regulation are two sides of the same coin. MRV provides the legal foundation and the data quality, while FuelEU makes that same data decisive for costs, sanctions and competitive position. Companies that see MRV only as a reporting obligation fall behind. Those that use MRV strategically build an integrated dataset that secures compliance, facilitates financing and strengthens commercial negotiation power.
FuelEU Maritime thus demonstrates how the MRV dataset evolves from statutory reporting into a financial and operational lever. But the strategic importance of this data layer goes further still. Where FuelEU ties emission intensity to compliance and pooling, the CSRD places the same data in a wider context: the assured sustainability reporting of the entire company.
CSRD: From MRV Measurement to Assured Reporting
Where FuelEU Maritime translates the MRV dataset into compliance checks and financial incentives within shipping, the Corporate Sustainability Reporting Directive (CSRD) extends the framework to company level. From the 2024 reporting year for listed companies, and from 2025 and 2026 phased in for other businesses, the CSRD requires reporting in line with the European Sustainability Reporting Standards (ESRS). Emission transparency is thus no longer limited to ship or fleet level, but becomes an integral part of a company’s sustainability strategy and reporting.
The strength of the MRV Regulation is that the emission data per ship is legally anchored, independently verified and reproducible. This data layer therefore provides a solid foundation for CSRD reporting. While MRV focuses on operational emissions (scope 1), the CSRD requires a broader inventory. Scope 2 (energy purchases) and scope 3 (supply chain emissions, such as upstream fuel production and downstream use) must also be included where material. MRV data is not replaced but embedded in a broader emission inventory that companies must consolidate fully and consistently.
A key difference from MRV and the EU ETS is the obligation for external assurance. The CSRD requires that sustainability reports be audited by an accountant or other accredited assurance provider. In this respect, the MRV audit trail – with change logs, measurement documentation and reconciliation of BDNs, noon reports and flow meter data – provides immediate added value. Since this chain is already legally robust and verifiable, an auditor can quickly confirm that scope 1 data is accurate and traceable. For companies that have well-structured MRV processes, this means lower audit burden and more credibility with regulators, banks and investors.
The strategic impact of the CSRD goes beyond compliance. Banks, insurers and cargo owners increasingly use CSRD reports as a benchmark for financing, insurance conditions and contract negotiations. Companies that report robust and assured emission data gain better access to capital and stronger market position. Furthermore, the linkage between MRV, the EU ETS, FuelEU Maritime and the CSRD enables emission reductions that already count financially to also be highlighted in the broader sustainability strategy. This avoids fragmentation of reduction efforts and strengthens internal steering on long-term targets.
The CSRD thus transforms the MRV dataset from a ship- and fleet-focused compliance instrument into a cornerstone of the assured sustainability reporting of the entire company. Companies that invest now in data quality, internal controls and a complete audit trail not only lay the groundwork for smooth verification under MRV and the EU ETS, but also build trust with auditors, investors and clients. MRV is evolving into the backbone of climate reporting: legally sound, financially relevant and strategically valuable.
Verification and Accreditation
The link between the MRV Regulation (EU) 2015/757 and the EU ETS makes the reliability of emission data more important than ever. Whereas earlier chapters explained how data is collected and reported, the central question here is how to guarantee that this data is correct, complete and consistent. The answer lies in independent verification, performed by organizations that comply with international quality standards and are accredited by competent accreditation bodies. This not only creates legal assurance but also produces datasets that generate financial predictability and trust among investors and regulators.
Verifiers may perform their role only if accredited under two international standards. ISO 17029 sets out the general principles for validation and verification, while ISO 14065 lays down specific requirements for assessing greenhouse gas emissions. Accreditation bodies, such as the Dutch Accreditation Council (RvA), assess whether verifiers apply these standards correctly and consistently. This involves not only technical expertise but also independence, impartiality and a robust quality management system. Only organizations that pass this assessment are admitted to the European framework and authorized to review monitoring plans and emissions reports. Verification thus functions not only as a control mechanism, but also as a quality filter that strengthens legal defensibility and market reputation.
The verification process has two central checkpoints. First, the verifier reviews the monitoring plan (MP), which records the methods and procedures for data collection. Next, the verifier assesses the annual emissions report, which consolidates the operational data for the calendar year. If both documents meet the requirements, the verifier issues a verification report and the Document of Compliance (DoC). This document is more than an administrative formality: it is tangible proof that the monitoring chain has been independently tested and that the data is both legally sound and financially reliable. For shipping companies, the DoC is therefore not only a compliance requirement but also an operational key. Without a valid document, not only is legal standing compromised, but access to ports in the EEA may be denied.
The verification method is internationally standardized and follows the principle of risk-based sampling. This means that the verifier focuses on parts of the system where the risk of errors or inaccuracies is greatest. Attention is given to cargo data reliability, emission factor accuracy, timeliness and accuracy of calibration of measuring equipment, and the presence of a complete audit trail. That audit trail is more than an archive: it is a structured chain of evidence that allows each calculation and dataset to be traced back to the original source. This gives verification its legal weight and operational credibility.
When significant deviations are found during verification, the shipping company must implement corrective measures. The emissions report cannot be approved until the shortcomings have been demonstrably resolved. Verification therefore functions not only as a retrospective check but also as a mechanism for continuous improvement. The external assessment raises the bar and forces companies to refine their processes structurally. This increases compliance certainty and enhances the confidence of financiers, insurers and charterers who rely on robust emission data in their own decision-making.
Together, the MRV Regulation, the EU ETS and independent verification form an inseparable triangle. MRV provides the data, the EU ETS gives the data financial value, and verification safeguards reliability. For shipping companies this means that investment in data quality, internal controls and audit procedures yields double benefits: legal risks are reduced, financial burdens are controlled and strategic position in a tightly regulated maritime market is strengthened.
Data Quality, Internal Controls and Audit Trail
Independent verification can only function effectively if the underlying data is of impeccable quality. The MRV Regulation (EU) 2015/757 therefore not only requires emission data to be collected, but also that this is done within a robust framework of internal quality assurance. Verification is the external check, but the foundation lies in the control mechanisms that shipping companies and shipowners implement within their own organizations. Data quality is thus not only a legal requirement but also a decisive factor for efficient operations, predictable costs and stakeholder confidence.
The Dutch Emissions Authority (NEa) identifies six principles that guide a well-designed data management system. First is completeness: all emissions and voyage segments within scope must be recorded so that no gaps arise that distort the picture. Linked to this are consistency and comparability. Monitoring methods and calculations must be applied in the same way per ship and per reporting year, so that trends and efficiency developments are clearly visible. This not only prevents legal corrections but also ensures that fleet and route analyses can be reliably used for operational optimization.
Transparency is the third requirement. All assumptions, emission factors and calculation steps must be fully documented so that an independent third party can reproduce the calculations end-to-end. Transparency is inseparable from accuracy. Measuring equipment must be demonstrably suitable for its purpose, calibrations must be timely and correct, and error margins must be explicitly stated. By quantifying uncertainty, companies create legal defensibility and a dataset usable for risk management, fuel strategies and contractual negotiations.
Equally important is integrity. Data must be protected against manipulation or unintentional changes. This requires controlled access rights, secure IT systems and logs that record every change. Finally, the regulation requires a culture of continuous improvement. Procedures must be periodically evaluated and refined so that the reliability of the monitoring system demonstrably grows. This not only increases compliance certainty but also produces structural efficiency gains by aligning data quality more closely with operational reality.
All these principles converge in the audit trail. This is not a loose collection of documents but the full description of the data flow: from the Bunker Delivery Note (BDN) recording fuel use, through noon reports and flow meter data, to the final calculations in the emissions report. Each step must be traceable to the original source and supported by evidence. The audit trail makes data not only reproducible for verifiers but also usable for internal business intelligence and benchmarking.
A robust audit trail also contains a change log, systematically recording each adjustment. Not only the content of the correction is noted, but also the time, the responsible person and the reason. This creates a transparent chain of responsibility that gives regulators, financiers and other stakeholders confidence that datasets are not only technically reliable but also resistant to legal and financial scrutiny.
By safeguarding data quality, internal controls and an audit trail in this way, a system is created that goes far beyond compliance alone. It produces a dataset that meets the letter of the regulation and at the same time unlocks strategic value. For shipping companies this means that investments in data architecture pay off twice: verification becomes smoother, the risk of sanctions is reduced and the company builds a dataset directly usable for financial planning, sustainability reporting and operational optimization.
Cargo Determination and Transport Work per Ship Type
The quality of monitoring data, as emphasized in the previous chapter on the audit trail, depends largely on how cargo carried is determined. Correctly determining cargo carried is not just an administrative step, but the basis for calculating transport work. Since transport work underpins efficiency indicators such as the Carbon Intensity Indicator (CII), accuracy is essential. Implementing Regulation (EU) 2016/1928 therefore defines exactly how to calculate this per ship type, so that results are objectively comparable across ships, routes and years. Correct application is not only a legal requirement but also strategically vital for benchmarking and commercial negotiations.
For general cargo ships, transported cargo is equated to deadweight on laden voyages. When the ship sails in ballast, cargo is set to zero. LNG carriers must record the volume discharged in cubic meters, with transparent corrections for temperature and pressure. This ensures that ballast voyages do not artificially contribute to transport work and that efficiency figures reflect only actual transport. For shipping companies this makes emission intensity transparently linked to real productivity, strengthening credibility with clients and financiers.
For oil and chemical tankers, the cargo mass in tonnes loaded is decisive. LNG and other gas carriers use a volume-based approach, with the number of cubic meters discharged as the leading parameter. Since temperature and pressure directly affect volume, accurate measurement and recording of these conditions is essential. Each correction must be transparently recorded in the audit trail to ensure reproducibility and verifiability. This not only provides legal assurance but also prevents financial surprises: inaccurate volume measurement in LNG transport can cause cost differences of millions of euros in ETS and FuelEU Maritime compliance.
For specialized ship types, additional rules apply. For refrigerated cargo ships, cargo is the actual weight of goods carried. Ro-ro ships (vehicle carriers) use a standard weight per vehicle transported, multiplied by the number of units. Ro-pax ships combine passengers and freight. Their calculation includes two components: the number of passengers, converted using a fixed standard mass per person, and vehicles and freight units weighed separately and added. This approach aligns with mixed transport practice and ensures that both passengers and cargo are fully accounted for. Strategically, this provides consistent efficiency figures usable contractually with charterers and policymakers.
The result of these rules is transport work: the product of distance and cargo. This parameter links emissions to actual transport delivered and is the key indicator for objectively assessing environmental performance. Since it feeds directly into efficiency analyses, CII scores, market benchmarks and negotiations, accurate cargo data is a matter of competitiveness as much as compliance.
Errors in cargo determination can have serious consequences. Overestimating transport work may produce artificially favorable CII scores, while underestimation may unnecessarily place a ship in the red zone. Both scenarios risk regulatory corrections or weakened market position. Thorough documentation of measurement methods, assumptions and calculations in the audit trail is therefore both a legal requirement and a safeguard against reputational and financial losses.
Correct cargo determination and transport work calculation are therefore central pillars of the MRV system, linking daily ship operations with the strategic assessment of emissions and efficiency. For shipping companies, this largely determines how they are judged in the transition to climate-neutral shipping and how they secure their competitive position in a tightly regulated market.
Sanctions and Enforcement
Accuracy of data and care in determining cargo and transport work are not only essential for internal efficiency and market position, but also the foundation on which regulators assess compliance. The MRV Regulation (EU) 2015/757 obliges Member States to impose sanctions for violations. Compliance is thus not a voluntary administrative exercise but a legally enforceable duty monitored systematically across the EEA.
Enforcement follows three consistent lines, comparable across Member States though the type and severity of sanctions may differ.
The first line is port state control (PSC). Inspectors check during port visits whether a valid Document of Compliance (DoC) is present on board in physical or digital form. If it is missing or expired, the ship may be detained or sanctioned immediately. The DoC is therefore not only proof of compliance but also an operational license: without it, daily activity is at risk. For shipping companies, this makes it both a legal and commercial necessity.
The second line is the emissions report. If a verifier identifies material errors or inconsistencies during review, the report cannot be validated until corrective measures are taken. If a ship repeatedly fails to present a valid emissions report, this can lead to a sailing ban or denial of access to EEA ports. The reporting obligation therefore has a direct operational dimension: administrative shortcomings translate into financial losses and logistical delays. For companies, robust data processes are thus an opportunity to demonstrate reliability and secure access to key markets.
The third line concerns correct application of the port call concept. Misclassifying a bunker stop, supply visit or drydock as a commercial port call, or concealing a real cargo handling, is considered a serious violation. Such errors undermine dataset credibility and may result in heavy fines, corrections and reputational damage. Since the reliability of MRV data directly affects financial obligations under the EU ETS and FuelEU Maritime, this is a key focus in both verification and enforcement.
While the principles are the same across the EEA, actual sanctions and measures differ per Member State. Companies must therefore account for varying national regimes. In the Netherlands, the NEa publishes guidelines specifying violation categories and fines. The core principle is clear: incidental administrative errors are usually correctable, but structural negligence or deliberate falsification leads to severe penalties, reputational loss and possible market exclusion.
This layered combination of preventive checks, independent verification and national sanctions makes enforcement the final link in the monitoring and reporting chain. It ensures that data collected through THETIS-MRV is not only technically accurate and legally sound but also enforceable in practice. For shipping companies, compliance is therefore much more than an administrative obligation: it is an operational license to remain active in European waters and a strategic investment in reliability that directly strengthens market position.
NL-Specific Implementation (NEa)
The European frameworks for MRV and the EU ETS are the same in all Member States, but practical implementation differs nationally. In the Netherlands, responsibility lies with the Dutch Emissions Authority (NEa). This body acts not only as regulator but also as a guide, translating European provisions into concrete formats, manuals and reporting requirements. The NEa ensures that the rules are not only legally enforceable but also practical for the Dutch maritime sector.
One of the NEa’s key instruments is the monitoring plan (MP). For each ship under the MRV Regulation (EU) 2015/757, the plan must be prepared in the prescribed format, usually XML or Excel. Since 1 January 2024, the plan must also include methane (CH4) and nitrous oxide (N2O) in addition to carbon dioxide (CO2). This extension ensures that Dutch shipping companies are not confronted with the new scope only during verification. The monitoring plan is therefore not just administrative, but a practical tool for future-proof compliance.
The annual emissions report is equally central. This combines MRV data with ETS corrections and is validated by an accredited verifier. The NEa emphasizes that adding CH4 and N2O from 2026 has direct financial consequences, as these gases then fall fully under ETS. For Dutch companies this means that data streams and IT systems must already be adapted. Strategically this secures compliance, provides control over future ETS costs and builds competitive advantage.
The NEa also requires a company-level report aggregating emissions and transport work of the entire fleet. This company report, also called ETS annual report, bridges individual ship reports and company-wide ETS obligations. The NEa advises developing this report in parallel with the ETS annual report. This creates a consistent dataset that is legally sound, operationally usable and credible for investors, financiers and regulators.
The Dutch approach shows that compliance is not only a European matter. National authorities play an active role in concretization and guidance. For Dutch shipping companies this means that NEa guidelines and formats must be integrated alongside European rules. Those who do this carefully not only reduce sanction risk but also build a reputation of reliability and transparency. NEa’s role is therefore more than oversight: it is a strategic support linking compliance with stronger market position, lower financing risk and better access to capital.
Common Mistakes and How to Avoid Them
Although the MRV Regulation (EU) 2015/757 provides a clear framework, practice shows that companies often encounter the same pitfalls. These errors cause delays and extra costs, and they undermine dataset reliability later used for EU ETS, FuelEU Maritime and CSRD. Preventing them is therefore more than compliance: it directly improves operational reliability, financial predictability and competitive position.
A first frequent mistake is incorrect classification of a port call. Stops such as bunkering, supply, non-offshore crew changes or drydock visits are sometimes wrongly recorded as commercial port calls. According to the legal definition this is incorrect, leading to wrong voyage boundaries and emission reporting. By carefully checking each stop against the MRV definition, companies avoid corrections or sanctions and strengthen dataset consistency, which is later used in efficiency analyses and charter negotiations.
A second problem is incomplete or careless monitoring plans. Verifiers often find missing elements, such as data gap procedures, uncertainty analyses or calibration protocols. In such cases, a plan is rejected and must be revised, causing delays and extra costs. Strictly following the template in Implementing Regulation (EU) 2023/2449 and filling in all sections prevents this. A robust plan also provides a stronger foundation for CSRD assurance.
A third pitfall is missing a valid Document of Compliance (DoC). This must be on board by 30 June at the latest and serves as formal proof of compliance. During port state control, it is often the first document checked. If missing or expired, penalties or detention may follow. By copying the DoC immediately after issuance, monitoring its 18-month validity and keeping both digital and physical versions on board, companies avoid this risk. This safeguards legal certainty and operational continuity.
Inconsistencies between the monitoring plan, emissions report and ETS reporting also occur regularly. Although these documents serve different functions, they must always be based on the same data and assumptions. If sustainable fuels, for example, are processed differently across documents, the verifier may reject the report or the NEa may raise questions. Early alignment of calculations and corrections with the verifier prevents discrepancies. Strategically this yields a dataset verifiable externally and usable internally for bank reports, investment decisions and KPIs.
A final and increasingly relevant mistake is underestimating methane (CH4) and nitrous oxide (N2O). Ships running on bio-LNG or alternative fuels such as methanol may produce significant emissions of these gases. Since 1 January 2024, monitoring and reporting of these gases is mandatory; from 2026 they count fully in ETS. Inaccurate datasets will then translate directly into ETS costs. Companies that adapt measuring systems and data processes now not only prevent compliance problems but also build a strong basis for future fuel strategies and cost control.
By proactively avoiding these pitfalls, shipping companies establish a stable compliance position that extends beyond legal obligation. They reduce legal and financial risks, strengthen strategic data quality and improve credibility with investors and partners. Mistakes thus become opportunities to link compliance with competitiveness and future readiness.
Practical Checklists and Formats
Complying with the MRV Regulation (EU) 2015/757 requires more than theoretical knowledge. It demands a practical plan that translates regulation into daily ship and office practice. A widely used approach is the 30-day sprint to compliance. This groups all necessary steps into logical order and makes compliance achievable within a month. Compliance thus becomes not only a deadline but a structured process that delivers legal certainty, operational efficiency and strategic value.
The sprint begins with a clear fleet scope. Once it is clear which ships are newly subject to MRV – such as general cargo ships from 400 GT and offshore ships from the same threshold – the company collects core data. Class certificates, fuel documentation and ship data are compiled so that monitoring plans are complete and current. This inventory not only forms the basis for compliance but also provides strategic insight useful for fleet planning and contracts.
The next step is updating monitoring plans. Since 2024, these must include CH4 and N2O alongside CO2. It is not about formally ticking boxes but ensuring that procedures are workable for crew and office staff. Only a plan usable in practice yields datasets that are verifiable externally and valuable internally.
In parallel, it is essential to contract an accredited verifier in time. Only organizations accredited under ISO 17029 and ISO 14065 are authorized to review emissions reports. Early involvement avoids time pressure and gives the company scope to improve data streams before the first reporting cycle. This is therefore both a legal and practical investment in more robust systems.
Data architecture must also be set up. BDNs, tank measurements, flow meter data and AIS logs must be linked systematically and supplemented with IT controls and a full audit trail. This infrastructure forms the backbone of credible reporting. Done carefully, it not only prevents sanctions but also creates automated dashboards for fuel management, voyage optimization and commercial decision-making.
The sprint ends with full activation of THETIS-MRV. Once the company is registered, ships are added, the verifier is linked and updated monitoring plans are submitted, a complete system is in place to handle the annual cycle without friction. From that point, the focus shifts to continuity.
Continuity is ensured with an annual calendar structuring the process. In Q1, voyage data is collected and processed into emissions reports, which must be submitted together with the company report by 31 March from reporting year 2025. Q2 focuses on transparency and compliance: emissions data is published, the DoC is issued and placed on board, and the company demonstrates compliance. Q3 shifts to financial compliance: reports are analyzed, monitoring plans updated if needed, allowances purchased and surrendered by 30 September. Q4 provides space for reflection and preparation: internal audits, equipment maintenance and revision of fuel supplier and charterer contracts.
By combining the 30-day sprint with the annual calendar, a robust compliance mechanism emerges. The sprint ensures rapid, error-free initial compliance, while the calendar ensures continuity and improvement. Compliance thus becomes not a last-minute burden but an integrated part of company operations, linking legal certainty with efficiency, predictable costs and strategic value.
Conclusion
The MRV Regulation (EU) 2015/757 forms the backbone of emission transparency in European maritime shipping. By systematically recording and verifying fuel consumption, distance, time at sea and cargo carried per voyage, a dataset is created that is not only legally sound but also valuable for operations and strategy. This data supports voyage optimization, fuel management and investment decisions, while also strengthening internal control and risk management.
The expansion to smaller ships and offshore activities from 2025, the inclusion of CH4 and N2O, and the linkage with the EU ETS all increase the urgency to organize monitoring, reporting and verification in a professional, integrated way. What began as a compliance instrument for the largest ships has become a sector-wide framework that enforces transparency and embeds quality.
In this environment, a robust monitoring plan, a strong data architecture and timely involvement of an accredited verifier are not optional, but prerequisites for continuity. Companies that see MRV only as administrative obligation miss opportunities. The same dataset can be used for efficiency, predictable ETS costs, access to capital and stronger client and charterer relationships.
Shipping companies that embrace MRV strategically build a foundation that extends beyond compliance. It links directly to CSRD reporting, FuelEU Maritime compliance and financing conditions increasingly driven by emission transparency. MRV is not only a legal duty, but also a lever for competitiveness and long-term resilience in a sector shaped by the energy transition and regulation.