20 March 2026

EU ETS Maritime

Deadline submitting verified emissions reports on 31 March 2026

Dear contact person for EU-ETS Maritime,

We are reaching out to you in your capacity as a contact person for a shipping company with MRV/ETS obligations. The deadline of 31 March 2026 is approaching fast and you have not yet - according to our administration - submitted a verified (company) emissions report in Thetis-MRV and/or you have not yet applied for a Maritime Operator Holding Account (MOHA). The necessary steps to fulfill your MRV/ETS obligations, are outlined in this message.

As said, by 31 March all shipping companies with MRV/ETS obligations must, at the very latest, submit a verified emissions report for each ship, as well as a verified aggregated emissions report for the company (based on the verified emissions report of all ships). Additionally, the verified emissions figures of the company emissions report must be entered into the Dutch part of the EU registry and confirmed by your verifier. As the administrative authority, we have the task to enforce these obligations. Therefore, failure to comply with the deadlines listed in the table below, will lead to enforcement actions.

Important obligations and deadlines in 2026 are:

Obligation	Deadline	System
Submit a satisfactorily verified emissions report for each ship	31 March 2026	THETIS MRV
Submit a satisfactorily verified aggregated emissions report per company (based on emissions reports of all relevant ships in your fleet)	31 March 2026	THETIS MRV
Enter the verified emissions figures	31 March 2026	EU ETS registry
Have the emissions figures in the registry confirmed by your verifier	31 March 2026	EU ETS registry
Surrender the equivalent number of allowances	30 September 2026	EU ETS registry

Helpful documents and links

On 15 January 2025, the Commission hosted a webinar covering the (new) emissions report functionality in THETIS-MRV and the EU ETS registry. The webinar was recorded and is available on their website. There, you will also find other supporting information, such as links to guidances, webinars and tutorials. We have also attached a checklist to assist you with the steps required for 2025 compliance (please note that this file hasn’t been updated yet, so every instance of 2024 should be 2025 and every instance of 2025 should be 2026). This information is also available on the NEa website.

Check your registrations in THETIS-MRV and the EU ETS registry

It is crucial to ensure your company information, company nature, legal entity (which can be registered owner or ISM company) and contact details are up to date in both THETIS-MRV and EU-ETS registry. This is especially important in case of:

If the registered owner itself is responsible for EU-ETS obligations: the contact person should be working within the same company (the registered owner). In case you want to use a person (outsourced) who is working on your behalf: the contact details of this person should be added separately in Thetis-MRV.
If an ISM company is responsible for EU-ETS obligations on behalf of one or more registered owners: make sure that, in case of a change relevant to the mandate of one or more registered owners, all relevant mandate documents are updated and uploaded in Thetis-MRV.

Apply for a MOHA as soon as possible
Without a MOHA, you won’t be able to surrender allowances or register you emission number in the EU-ETS Registry, which means you won’t be able to comply with EU-ETS regulations. Therefore, if you haven’t applied for a Maritime Operator Holding Account (MOHA) yet, please do so as soon as possible to avoid any unwanted consequences later. Keep in mind that processing your documents can take time.

Submission of monitoring plans
The NEa also urges all companies to submit the monitoring plans for their ships as soon as possible. A monitoring plan, per ship, has to be submitted to the AA no later than within three months after the first port of call in the EEA (see Article 6, paragraphs 6 and 7 MRV Maritime Regulation).

Non-compliance
In case of non-compliance with the surrender obligation, an EU sanction regime applies. Shipping companies that do not surrender allowances, will be subject to an excess emissions penalty of EUR 100 (adjusted for inflation) per tonne of CO2 equivalent, in addition they will still be required to surrender the necessary allowances.

Yours sincerely,

The Dutch Emission Authority,

Maaike Breukels

Deputy Director Dutch Emissions Authority

Questions?

If you have any questions about this letter, please feel free to contact us: NEa Helpdesk.

Questions?

Dutch Emission Authority

PO BOX 91503, The Hague

info@emissieautoriteit.nl