Shipping carbon compliance remains centred on the EU ETS. Following publication of the EU ETS revision proposal, the market continues to assess its implications for allowance supply, carbon price expectations and low-carbon investment mechanisms in shipping. At the same time, UK ETS maritime has entered its enforcement phase, and FuelEU Maritime's first compliance year has moved into review and preparation for the next cycle. For shipping companies, carbon compliance is shifting further from "understanding the rules" toward cost calculation, account management, contractual arrangements and data traceability.
1. EUA market: analysts trim near-term price forecasts, but stay bullish longer term
The most notable development in the EUA market is a shift in price expectations. Reuters reported on 31 July that, following the European Commission's EU ETS reform package, several analysts lowered their EUA price forecasts for 2026 and 2027. In a Reuters survey of nine analysts, the average EUA price forecast was EUR 79.97/t for 2026 and EUR 89.13/t for 2027 — both below April's levels. Expectations for 2028 and beyond remain higher, with average forecasts of EUR 100.43/t for 2029 and EUR 109.11/t for 2030.
This suggests the market does not read the reform as a weakening of carbon prices, but rather as a possible slowdown in the pace of near-term gains. Reuters also noted that the Commission's 17 July EU ETS reform proposal could give some sectors a longer relative buffer while promoting clean technology investment through new support mechanisms.
Compliance note: For shipping companies, EUA procurement should not be a bet on short-term price swings. A steadier buying rhythm — built around actual emissions, compliance deadlines, allowance holdings and budget planning — is more appropriate. With 2026 shipping emissions to be treated at a 100% surrender ratio, overall compliance cost pressure remains significant even if prices correct in the short term.
2. EU ETS reform: shipping remains a key focus of the negotiations ahead
The European Commission tabled its EU ETS revision on 17 July, and the market and industry are still working through the detail. According to the Commission, the proposal aims to support the EU's 2040 climate target while strengthening the carbon market's role in funding industrial decarbonisation investment; it also touches on further adjustments to aviation and maritime ETS rules.
For shipping, two directions matter most. First, whether the scope of EU ETS shipping coverage widens further — for example, to include more vessels between 400 and 5,000 gross tonnes. Second, whether more ETS revenue can be channelled into alternative marine fuels, clean technology and emissions-reduction investment. The World Shipping Council has said that reinvesting more revenue into shipping decarbonisation in the Commission's EU ETS revision is a positive signal for the development of alternative marine fuels.
Compliance note: These elements remain at the legislative proposal stage and are not final, applicable rules. They still require review, negotiation and amendment by the European Parliament and the Council. For owners, managers and charterers, they are best treated as variables in medium- and long-term fleet planning, fuel strategy and compliance cost modelling — not as rules to implement today.
3. EU ETS shipping: 2026 emissions must be managed at 100% coverage
Beyond the reform proposal, the EU ETS shipping rules already in force remain the immediate priority. The European Commission's FAQ confirms that the surrender ratio is phased in: 40% of 2024 emissions, 70% of 2025 emissions, and 100% of emissions from 2026 onwards.
Two timelines need to be kept apart. What is surrendered by 30 September 2026 relates to 2025 emissions at the 70% ratio; applicable emissions generated from 1 January 2026 will be handled at 100%. In addition, CH₄ and N₂O have been within the MRV monitoring and reporting scope since 2024 and enter the EU ETS scope from 2026.
Compliance note: When modelling 2026 emissions costs, companies should no longer estimate EUA demand on CO₂ alone. For LNG carriers, dual-fuel vessels and ship types where methane slip accounting may apply, the inclusion of CH₄ and N₂O can further affect actual compliance costs.
4. UK ETS maritime: early focus on responsible entity, METS accounts and the EMP
UK ETS maritime has applied since 1 July 2026. UK government guidance confirms that it covers relevant maritime activity by vessels of 5,000 gross tonnes and above, principally voyages between UK ports and activity while at berth in UK ports. The first maritime compliance year runs from 1 July to 31 December 2026.
The immediate priorities are the responsible entity, the METS account and the emissions monitoring plan (EMP). UK guidance requires maritime operators to submit an EMP application within 42 days of first carrying out UK ETS maritime activity, and to submit a verified annual emissions report by 31 March following the end of each compliance year. For companies already operating relevant maritime activity from 1 July, the EMP deadline is counting down: account opening, vessel lists, emission source identification and verification arrangements should be confirmed as soon as possible.
Compliance note: On the responsible entity, a registered owner may delegate UK ETS compliance responsibility to the ISM Company through a legally binding written agreement. Where a ship manager carries operational responsibility in practice, it is advisable to confirm early that the responsibility transfer documentation, METS account holder, EMP vessel list and subsequent UKA procurement arrangements are consistent.
5. FuelEU Maritime: after year one, attention turns to review and contracts
For FuelEU Maritime, the key milestones of the first compliance year have now passed. As set out by DNV, companies had to confirm compliance balances and record banking or pooling intentions by 30 April; by 30 June, where a ship has no compliance deficit, the verifier issues the FuelEU Document of Compliance (DoC); where a ship has a deficit and a FuelEU penalty is due, the DoC is issued by the administering state or authority once the company has paid the penalty.
At this stage, companies can usefully review their 2025 FuelEU outcomes: whether each ship has obtained its DoC, whether the compliance balance is negative, whether penalties are involved, whether pooling arrangements were executed as planned, and whether more suitable pooling resources or low-carbon fuel options should be secured early for 2026.
Compliance note: For companies operating regularly on European trades, FuelEU affects more than single-ship compliance; it shapes commercial arrangements between owners, managers, charterers and fuel suppliers. Contracts should set out FuelEU cost sharing, ownership of pooling benefits, low-carbon fuel arrangements and responsibility for providing data.
6. IMO: second-half meetings continue to focus on the Net-Zero Framework
At IMO level, the second-half meeting schedule is worth noting in advance. In its post-MEPC 84 information, the IMO confirmed two intersessional working group meetings on greenhouse gas reduction ahead of MEPC 85, from 1 to 4 September and from 23 to 27 November 2026. MEPC 85 is scheduled for 30 November to 3 December, and the previously postponed second extraordinary session of the MEPC is planned to resume on 4 December, subject to discussions during MEPC 85.
Compliance note: From a carbon compliance perspective, these meetings will continue to focus on the Net-Zero Framework and its implementing arrangements, including well-to-wake fuel emissions, chain-of-custody tracking, emissions pricing mechanisms and coordination with regional schemes. In the near term, EU ETS, FuelEU Maritime and UK ETS remain the regional compliance priorities; the IMO framework is better treated as important background for fleet renewal, fuel strategy and commercial contracting.
7. Further watch: onboard carbon capture starts to show compliance value
Beyond the traditional ETS, FuelEU and IMO topics, onboard carbon capture has seen noteworthy regulatory progress. The Global Centre for Maritime Decarbonisation (GCMD) announced on 22 July that Project CAPTURED had achieved two regulatory milestones: onboard-captured CO₂ recognised for deduction under EU ETS compliance, and IMO support in principle for treating carbon mineralisation as permanent CO₂ storage.
According to GCMD, the project previously completed an end-to-end demonstration of transferring and mineralising onboard-captured CO₂. Where such CO₂ is permanently chemically bound in a qualifying product, it can — once certified — be deducted from emissions requiring EUA surrender.
Industry view: This shows onboard carbon capture moving from technical trials toward validated compliance value. Commercially, however, OCCS must still address equipment cost, energy consumption, port reception, CO₂ transfer, long-term liability and certification rules.
References
- Reuters, Analysts lower EU carbon price forecasts for 2026, 2027 on market reform proposals
- European Commission, Market Stability Reserve / EU ETS revision information
- European Commission, FAQ – Maritime transport in EU Emissions Trading System (ETS)
- World Shipping Council, ETS rightly reinvests more into maritime decarbonisation
- UK Government, UK Emissions Trading Scheme for maritime: how to comply
- DNV, FuelEU Maritime: Regulation insights & support
- IMO, MEPC 84th session
- GCMD, Project CAPTURED advances regulatory pathways for onboard captured CO₂
Disclaimer: This article is compiled from publicly available information for reference and discussion only. It does not constitute legal, financial, investment or trading advice.
For EUA/UKA procurement or FuelEU pooling compliance, please contact Tecway Maritime.