MARITIME FUEL EMISSIONS REGULATIONS - TIMELINES

MARITIME FUEL EMISSIONS REGULATIONS – TIMELINES

Published: 1 May 2025

This page is part of our comprehensive Maritime Fuel Regulations section written in consultation with the law firm HFW.

This timeline page is formed of three sections, showing individual timelines for the EU Emissions Trading Scheme, the FuelEU Maritime Regulation and the Carbon Intensity Indicator (CII) Regulation from the IMO.

TIMELINE – EU EMISSIONS TRADING SCHEME

2024 – reporting period one begins (Reporting Period One)

01 January 2024 –
- monitoring of GHG emissions (CO2, CH4 and N20) by cargo or passenger ships of 5000gt or above on qualifying voyages to EEA ports of call under MRV.
- liability for cargo or passenger ships of 5000gt or above to surrender EUAs for 40% of verified GHG emissions.
31 January 2024 –
- list of shipping companies published attributing administering authorities.
27 March 2024 –
- for shipping companies listed, earliest deadline for opening a Maritime Operator Holding Account (MOHA). For shipping companies not listed, the deadline for opening a MOHA is 65 working days from the first qualifying port call.
01 April 2024 –
- submission of updated verified monitoring plan through THETIS-MRV covering CH4 and N2O emissions.
- Where a ship is yet to make a qualifying port call in 2024, no monitoring plan needs to be submitted until three months after the first qualifying port call.
31 December 2024 –
- end of the Reporting Period One.

2025 – reporting period two begins (Reporting Period Two / Verification Period for Reporting Period One).

01 January 2025 –
- off-shore ships and general cargo ships above 400gt and below 5,000 gt must monitor GHG emissions under the MRV.
- liability for cargo or passenger ships of 5000gt or above to surrender EUAs for 70% of verified GHG emissions.
- the shipping company must start to prepare an emissions report for individual ship’s GHG Emissions and aggregate emissions report for the shipping company’s total GHG emissions, covering Reporting Period One.
By 31 March 2025 (or by 28 February if required by the administering authority) –
- both emissions reports must be verified and submitted to the administering authority.
30 June 2025
- Document of Compliance issued by the verifier (DoC) must be carried onboard the ship.
- the EU Commission shall make publicly available the reported information on GHG emissions
30 September 2025
- the shipping company must surrender EUAs equivalent to 40% of the aggregate shipping company GHG emissions, verified in their Emissions Report.
31 December 2025 –
- update to the list of neighbouring container transhipment ports.
31 December 2025 –
- end of Reporting Period Two

2026 – reporting period three begins (Reporting Period Three / Verification Period for Reporting Period Two)

01 January 2026 –
- liability for cargo or passenger ships of 5000gt or above to surrender EUAs for 100% of verified GHG emissions, which shall include N20 and CH4.
- Monitoring activities from 1 January as described in Reporting Period Two.
- Reporting and verification activities from 1 January to 30 June as described in Reporting Period Two.
1 February 2026 –
- updated list of shipping companies is issued to reattribute the administering authority for shipping companies registered in a Member State or include new shipping companies not previous listed (to be undertaken every two years).
30 September 2026
- the shipping company must surrender EUAs equivalent to 70% of the aggregate shipping company GHG emissions, verified in their Emissions Report.
31 December 2026 – End of Reporting Period Three

2027- reporting period four begins (Reporting Period Four / Verification Period for Reporting Period Three)

From 1 January 2027
- liability for cargo or passenger ships and off-shore ships of 5000gt or above to surrender EUAs for 100% of verified GHG emissions, which shall include N20 and CH4.
- Monitoring activities from 1 January as described in Reporting Period Two.
- Reporting and verification activities from 1 January to 30 June as described in Reporting Period Two.
30 September 2027
- the shipping company must surrender EUAs equivalent to 100% of the aggregate shipping company GHG emissions, verified in their Emissions Report.
31 December 2027 – End of Reporting Period Four
- update to the list of neighbouring container transhipment ports.

2028- reporting period five begins (Reporting Period Five / Verification Period for Reporting Period Four)

From 1 January 2028
- Monitoring activities from 1 January as described in Reporting Period Two.
- Reporting and verification activities from 1 January to 30 June as described in Reporting Period Two.
1 February 2028 –
- updated list of shipping companies covering the updates above and reattributing shipping companies that are not registered in a Member State to another administering authority (to be undertaken every four years).
30 September 2028
- the shipping company must surrender EUAs equivalent to 100% of the aggregate shipping company GHG emissions, verified in their Emissions Report, including for off-shore ships of 5,000 gt and above.

TIMELINE FUELEU MARITIME – Download FuelEU Timeline as a PDF.

2024 – pre-reporting period

31 August 2024
- shipping companies must submit a monitoring plan to the verifier for each cargo or passenger ship of 5,000 gt in their fleet and, for shipping companies that have not made a qualifying port call, the monitoring plan must be submitted no later than two months after the first qualifying port call.

2025 – reporting period one (Reporting Period One)

01 January 2025
- GHG Intensity Limit of -2% compared to the reference value of 91,16 grams of CO2 equivalent per MJ (Reference Value).
- shipping companies must monitor energy used onboard their ships and container and passenger ships must monitor connection to or use of onshore power supply (OPS).
- a multiplier of ‘2’ is applied to GHG Intensity from RFNBOs (RFNBO Multiplier).
By 31 December 2025
- the Commission shall adopt implementing acts establishing a list of neighbouring container transhipment ports.

2026 – reporting period two (Reporting Period Two / Verification Period for Reporting Period One)

01 January 2026
- Monitoring as described in Reporting Period One.
31 January 2026
- a ship-specific ‘FuelEU report’ must be provided to the verifier, covering energy used onboard and where relevant use of OPS.
31 March 2026
- The verifier shall confirm the FuelEU report complies with FuelEU, issue a verification report and provide the compliance balance, the energy used onboard from RFNBO and where relevant the number of non-compliant port calls in respect of OPS.
30 April 2026
- If the shipping company borrows an advance compliance surplus, the shipping company shall record the advance compliance surplus, following approval by its verifier, in the FuelEU database.
- If the shipping company pools the Compliance Balance, this must be recorded in the FuelEU database, verified by the pool verifier and the vessel verifier.
- Verified Compliance Balances must be recorded in the FuelEU database.
30 June 2026
- The shipping company must pay any FuelEU Penalties.
- The verifier shall issue a document of compliance (DoC).
- If the shipping company banks a Surplus, this is the latest possible date assuming the DoC has not been issued at an earlier date.

2027 – reporting period two (Reporting Period Two / Verification Period for Reporting Period Two)

01 January 2027
- Monitoring as described in Reporting Period Two.
- Reporting and verification as described in Reporting Period Two.
01 June 2027
- Where a ship does not have any port call in the Union during the Reporting Period Two and borrowed in Reporting Period One, the administering authority will notify the FuelEU Penalty payable.

2030 – reporting period six (Reporting Period Six / Verification Period for Reporting Period Five)

01 January 2030
- GHG Intensity Limit of -6% compared to the Reference Value.
- Container and passenger ships moored at the quayside in a port of call (covered by Article 9 of Regulation (EU) 2023/1804 unless Member States choose to extend this to ports of call not falling within Article 9) must connect to OPS and use it for all its electrical power demand at berth.

2031 – reporting period seven (Reporting Period Seven / Verification Period for Reporting Period Six)

30 April 2031
- the verifier shall record in the FuelEU database the total number of hours spent moored at the quayside by the ship in non-compliance with the OPS requirements (Non-compliant Port Call).
30 June 2031
- The shipping company must pay any FuelEU Penalties, including for Non-Compliant Port Calls.

2034 – reporting period ten (Reporting Period Ten / Verification Period for Reporting Period Nine)

01 January 2034
- The RFNBO Multiplier shall no longer apply for the calculation of the GHG intensity of the energy used on board.
- The RFNBO sub-target of 2% of the vessel’s yearly energy used on board may be applied.

2035 – reporting period 11 (Reporting Period Eleven/ Verification Period for Reporting Period Ten)

01 January 2035
- GHG Intensity Limit of -14.5% compared to the Reference Value.
- Container and passenger ships moored at the quayside in a port of call (not covered by Article 9 of Regulation (EU) 2023/1804) must connect to OPS and use it for all its electrical power demand at berth.
30 June 2035
- If applied, FuelEU Penalties payable for failure to meet the RFNBO sub-target.

01 January 2040 – GHG Intensity Limit of -31% compared to the Reference Value.

01 January 2045 GHG Intensity Limit of -62% compared to the Reference Value.

01 January 2050 – GHG Intensity Limit of -80% compared to the Reference Value.

TIMELINE FOR CII REGULATION

2023 – reporting period one (Reporting Period One)

From 01 January 2023
- prior to this date, for each qualifying ship, the Administration for a ship shall ensure the SEEMP complies with the CII Regulation. Confirmation of compliance shall be provided to, and retained on board, the ship.
- monitoring of emissions data under CII Regulation for Reporting Period One.
- verification that the ship’s attained EEXI is in accordance with CII Regulation was required to take place at the first annual, intermediate or renewal survey or the initial survey, whichever is the first, on or after 1 January 2023.

2024 – reporting period two (Reporting Period Two / Verification Period for Reporting Period One)

01 January 2024
- monitoring of emissions data under CII Regulation for Reporting Period Two.
31 March 2024
- the ship must aggregate, calculate and report emissions data and the Attained CII for Reporting Period One to its Administration or delegated entity.
30 April 2024
- the Administrator shall verify the Attained CII to determine the CII Rating for the ship, and shall issue a statement of compliance unless a plan of corrective action is required.
- where a plan of corrective actions is required due to the Attained CII, the revised SEEMP including a plan of corrective actions shall be submitted to the Administration no case later than 1 month after the reporting the Attained CII.
- the statement of compliance for these ships shall only be issued once the revised SEEMP including the plan of corrective actions is verified.

2025 – reporting period three (Reporting Period Three / Verification Period for Reporting Period Two)

From 01 January 2024
- Monitoring as described above for Reporting Period Two.
- Reporting and verification as described above for Reporting Period Two.
31 December 2025
- IMO to complete review of the CII Regulations and EEXI.

2026 – reporting period four (Reporting Period Four / Verification Period for Reporting Period Three)

DISCLAIMER
This article is published by THE BRITANNIA STEAM SHIP INSURANCE ASSOCIATION EUROPE (the Association). Whilst the information is believed to be correct at the date of publication, the Association cannot, and does not, assume any responsibility for the completeness or accuracy of that information. The content of this publication does not constitute legal advice and Members should always contact the Association for specific advice on a particular matter.

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