Moving into the second half of 2026, the focus of EU ETS maritime compliance has shifted from annual emissions reporting toward EUA surrender preparation.
It is worth highlighting that in 2026 companies are primarily handling their 2025 emissions, which are subject to the 70% compliance ratio, while emissions generated in 2026 will be surrendered in 2027 and will begin to be subject to the 100% ratio.
In other words, 2026 requires companies both to complete the 70% surrender for the previous year and to prepare in advance for the following year's 100% compliance.
1. Key compliance milestones in 2026
Based on the European Commission's arrangements, shipping companies first surrendered EUAs by 30 September 2025 for 2024 emissions at a 40% ratio. In 2026, 70% of 2025 emissions must be surrendered. From 2027 onwards, 100% of emissions from 2026 and later years must be surrendered.
Against this backdrop, the key EU ETS milestones to focus on in 2026 are as follows.
By 31 March 2026: Complete 2025 emissions report and company-level data submission
This milestone covers the consolidation of 2025 vessel emissions data, verification of the annual emissions report, and submission of company-level emissions data. As of the current point in the year, this stage should in principle already be complete. Companies should now be double-checking that the corresponding reports, verifications and system submissions have all been closed out.
July – September 2026: Confirm EUA needs, and complete procurement and surrender preparation
In the second half of the year, companies should calculate the volume of EUAs to be surrendered by 30 September 2026, based on verified 2025 EU ETS applicable emissions.
Unlike the first compliance cycle, 2026 covers 70% of 2025 emissions, rather than 40% of 2024 emissions. If a company's 2025 applicable emissions are broadly in line with 2024, the increase in the compliance ratio alone will drive a meaningful rise in EUA demand.
By 30 September 2026: Complete EUA surrender for 2025 emissions
By 30 September 2026, shipping companies must complete the surrender of EUAs in the Union Registry to cover 70% of their EU ETS applicable emissions for 2025.
It should be noted that completing EUA procurement does not mean compliance is complete. Companies still need to confirm the status of the MOHA account, the authority of authorised representatives, that EUAs have been received into the account, internal approval procedures, and that the final surrender action has been carried out.
If procurement or account checks are only initiated close to the September deadline, market price volatility, payment cycles, account permissions and cross-functional approval requirements can all increase compliance uncertainty.
2. 2026 emissions: preparing in advance for 100% compliance
Starting with 2026 emissions, EU ETS maritime compliance moves into the 100% phase. In other words, EU ETS applicable emissions generated in 2026 will be surrendered against EUAs at 100% in the 2027 compliance cycle.
There is also another important change for 2026 emissions: the scope of greenhouse gases in the maritime part of the EU ETS expands further. From 2026 onwards, CH₄ and N₂O are also brought into the scope of the EU ETS for maritime transport.
For vessels running mainly on conventional fuel oil, CO₂ remains the dominant emissions item. But for vessels using fuels such as LNG, methane emissions and methane slip can meaningfully affect the final CO₂e figure, and need to be factored into 2026 emissions monitoring and EUA demand forecasts.
As a result, EU ETS compliance work in the second half of 2026 has a dual mandate: on one hand, completing the 70% surrender for 2025; on the other, preparing data management and cost budgeting for the 100% compliance ratio and the wider GHG scope that begin with 2026 emissions.
3. Companies entering EU ETS scope for the first time should also watch account-opening deadlines
For companies that have already opened a MOHA account and completed their first compliance cycle, the focus in 2026 is on allowance forecasting, procurement and surrender.
For companies that fall under EU ETS scope for the first time in 2026, however, account setup and confirmation of the responsible entity remain the more fundamental issues.
According to the European Commission's FAQ, shipping companies that are not on the administering-country list should first complete administering-country allocation via THETIS-MRV and then apply to open a MOHA account with the relevant national administrator. Companies not on the list should apply to open a MOHA account within 65 working days of the first EU ETS in-scope voyage.
If a company enters EU ETS scope for the first time in 2026, we recommend that it does not wait until the annual compliance deadline is close to start dealing with account matters. MOHA account opening, confirming the responsible entity, appointing authorised representatives, setting system permissions and preparing compliance documentation should all be arranged well in advance.
Closing thoughts
For shipping companies, early quantification, early planning and early engagement are an important basis for reducing compliance risk and cost volatility. If you have requirements around EUA procurement, allowance-demand forecasting, MOHA account operations or annual compliance planning, we welcome further discussion with Tecway Maritime.
References
- European Commission, Reducing Emissions from the Shipping Sector
- European Commission, FAQ – Maritime Transport in the EU Emissions Trading System
- European Maritime Safety Agency, MRV Regulation
- European Maritime Safety Agency, ETS Extension to Maritime