Case Study - What if the registered owner assumes responsibility for MRV and ETS?

Hello Queseanians,

Since the beginning of 2024, many shipping companies have been looking to comply with the EU ETS requirements.

Key principle!
The entity responsible for ETS compliance is necessarily responsible for MRV compliance.

The entity responsible for compliance with ETS and MRV can be either the

  1. registered owner or
  2. ISM company

By default, the registered owner is the entity responsible for compliance with the EU ETS obligations and surrendering the allowances. However, the registered owner and the ISM company can agree, according to which the ISM company is the entity responsible for compliance with the EU ETS obligations. In this case, there is an obligation to have a document signed by the registered owner and the ISM company that clearly shows the existence of a mandate.

Case Study Scenario
But, what if the registered owner wants to maintain the responsibility for ETS and consequently the MRV?

Let’s explore the actions that need to be followed in this scenario which the registered shipowner wants to maintain the responsibility for ETS and consequently the MRV. The owner listed on a ship’s certificate of registry is the registered owner.

Change of company

  • If the registered owner assumes responsibility for MRV (and ETS) during a reporting period (e.g. 2024), the ISM company is required to provide a partial emissions report for each vessel within three months of the change.
    As per the updated MRV Maritime Regulation, when a change of company occurs, the previous company must produce a verified report covering the same elements as the (annual) emissions report but limited to the period corresponding to the activities carried out under the company’s responsibility (referred to as the ‘partial emissions report’).
    Please be aware that a partial emissions report cannot be submitted via THETIS-MRV for a ship once it has been released from the company’s fleet. Therefore, the release of the ship in THETIS-MRV should occur after the submission of the partial emissions report.
  • The number of allowances to be surrendered needs to correspond only to emissions that occurred during the time of responsibility of a particular company for the vessels.
    This means that if there is a change of shipping company from Company A to Company B for example on 1 March 2024, then in 2025, Company A will need to surrender allowances corresponding to emissions from that ship from 1 January to 1 March 2024 [see Article 11(2) of the MRV Maritime Regulation for further details].
  • The requirement to generate a partial emissions report arises only when a change in company ownership occurs during the reporting period.
    1. If the change of shipping company, in your case from ISM manager to Registered Owner occurs during the reporting period, then partial reporting applies.
    2. However, if the change of company occurs specifically on January 1, there is no necessity to provide a partial emissions report. The new company, designated as the Registered Owner in this instance, will bear full responsibility for MRV and ETS throughout the entire reporting period of 2024.
  • Therefore, it is important for the Registered Owner to record the effective date of the company change as January 1, 2024, to avoid the requirement for a partial emissions report.
  • After fulfilling the reporting obligations for the year 2023, meaning once the emissions report for 2023 has been successfully submitted to the Commission, the Registered Owner must establish a THETIS MRV account and claim the responsibility of the relevant vessels starting from January 1, 2024.
  • In compliance with Article 7 of the MRV Maritime Regulation, a company shall modify the monitoring plan when there is a change of company.
    Should the registered owner assume responsibility for MRV (and ETS) duties from the former ISM company without further alterations to the ship’s monitoring plan, reassessment by verifiers is not required. The company needs only submit the updated monitoring plan to the relevant administrative authority for approval.

Register Owner and Verifier

  • The Register Owner shall have an agreement with Verifier, meaning a legal entity accredited by a national accreditation body under Regulation 765/2008, carrying out verification activities to assess the conformity of the documents transmitted by the Company.

Register Owner and Administering Authority (AA)

  • Implementing Decision 2024/411 lists the attributed AA for shipping companies based on information available in THETIS-MRV and the European Union maritime information and SafeSeaNet as of 20 November 2023.
  • Companies who know which AA they are assigned to, I recommend to apply for a Maritime Operator Holding Account as soon as possible.
  • In the case of a shipping company not on the list but covered by the EU ETS, this shipping company will be attributed to a Member State based on the rules under Article 3 gf of the ETS Directive EMSA can help a shipping company to determine its MS (Dedicated Helpdesk:
    a. For EU-registered shipping companies, that Member State will be the administering authority.
    b. For any non-EU registered shipping companies, which are not listed in the list and own vessels that have undertaken a commercial voyage to an EU/EEA port since January 1, 2024, falling under the scope of the EU ETS, the AA shall be, according to EU Regulation 2023/2599:
    i. The MS from which the vessel’s first voyage subject to the EU ETS started or finished; or
    ii. In the instance where two or more Member States had the equal highest number of port calls by their ships in the scope of ETS, the AA will be the first port call to the Member State with the joint highest port calls in the scope of ETS.
  • As per Delegated Regulation (EU) 2023/2904 Article 15a, the shipping company with responsibility for EU ETS compliance must open a Maritime Operators Holding Account (MOHA) in the Union Registry:
    a. Within 40 working days for shipping companies, which are included in the published list of assigned AA (Regulation 2024/411).
    b. Within 65 working days of the first port of call falling within the scope of the ETS Directive for shipping companies not listed in Regulation 2024/411.
  • The registered owner should provide its Administering Authority (AA) with a list of ships for which it assumes responsibility with the MRV and ETS obligations. The registered owner must establish its monitoring system, develop a Monitoring Plan, have it assessed by a verifier (if necessary), and submit it to the AA by 1 April 2024.
  • Irrespective of the assigned AA, the submission of Monitoring Plans and emissions reports is carried out through Thetis MRV. A Thetis account can be created via the Thetis platform at any time for companies (shipowner or any other organization responsible for ship operations), verifiers, and MS. Upon creating an account, the user will receive an email detailing further steps to activate the account. It’s important to note that only one responsible person per Company/Verifier/Flag State is permitted, although this individual can create additional users under the same account. I recommend visiting the EMSA website, paying special attention to the video tutorial C01, which covers the registration process.
  • Companies not included in Implementing Decision 2024/411 are required to request the establishment of a MOHA within 65 working days following the first port call of a voyage subject to the EU ETS. If such companies had an EU port call before the publication of the list, for example on January 15, 2024, the count of 65 working days starts from the date of the first port call, not from January 31, 2024, which is the date of list publication.

Role of a Third Party

  • A third party can carry out operational tasks, such as monitoring and reporting, on behalf of the shipping company. If a third party provides services to a shipping company, they can be authorized to access Thetis MRV as a user. However, regardless of this arrangement between the third party and the shipping company, the shipping company retains responsibility for ensuring compliance with MRV and ETS obligations.
  • If the registered owner assumes responsibility for complying with the MRV and ETS but assigns operational monitoring tasks to the ISM company as a third party, the ISM company can proceed with the monitoring and reporting as usual. However, the Monitoring Plan must be revised to indicate the owner as the responsible entity. It has not yet been determined whether the ISM company will be permitted to submit plans and reports in Thetis MRV on behalf of the owner.

Information for the Registered Owner that maintains the responsibility
List of vessels

  • If the shipping company is the registered owner, it must provide its AA with a document containing the list of the ships under its responsibility for ETS and MRV compliance. The contents of this document for each ship with emissions falling within the ETS scope include the ship’s name and IMO ship identification number. The registered owner is obligated to promptly update the document in the following circumstances:
  1. The registered owner becomes responsible for an additional ship with emissions falling within the ETS scope, in which case the new ship’s name and IMO ship identification number must be provided.
  2. A ship ceases to be under the responsibility of the registered owner (e.g., the registered owner mandates the ISM Company to comply with ETS and MRV obligations; the registered owner sells the ship), in which case the ship’s name, IMO ship identification number, and the name and IMO unique company and registered owner identification number of the new shipping company must be provided.

MOHA documentation

  • The request for opening a MOHA should be accompanied by a set of documents, including
    – IMO number
    – unique company and registered owner identification number
    – mandate (if any) by the registered owner to the ISM company (where the shipping company is the ISM company)
    – list of ships under the responsibility of the registered owner (where the shipping company is the registered owner)
    – document identifying the structure of the group (if the shipping company is part of a group)
    – National administrators may ask for additional documents depending on national rules e. g. bank account details, information on the beneficial owner of the legal entity)
  • When requesting the MOHA, the shipping company must nominate at least two authorized representatives with access to the MOHA. An authorized representative is a natural person over the age of 18, and their role involves acting on behalf of the shipping company (e.g., surrender of allowances). It’s important to note that a third party may serve as the authorized representative (AR) on an MOHA.

Union Registry

  • The Union Registry (UR) is an essential IT system designed to ensure the accurate and secure tracking of ETS allowances, functioning in a manner like online banking.
  • It includes various types of accounts, such as operator holding accounts, such as the Maritime Operator Holding Account (MOHA) and Trading Accounts (TA).
  • The UR maintains records of annual verified greenhouse gas emissions and facilitates the annual reconciliation of allowances and verified emissions.
  • The UR facilitates the transfer of allowances between participants.


FAQ - Monitoring, reporting and verification of maritime transport emissions - European Commission.pdf (705.0 KB)
FAQ – Maritime transport in EU Emissions Trading System (ETS) - European Commission.pdf (796.3 KB)
C01 Registration THETIS Tutorial
Regulation (EU) 2023/957
Directive (EU) 2023/959