UK ETS Maritime came into force on 1 July 2026. For vessels of 5,000 GT and above, UK domestic voyages and relevant emissions within UK ports now fall within the scope of the UK ETS; offshore ships will be brought in from 1 January 2027. Qualifying maritime operators must put an Emissions Monitoring Plan (EMP) in place, monitor and verify emissions annually, submit annual reports and ultimately surrender the corresponding number of UKAs through their MOHA.
On 3 August, the UK Environment Agency's UK ETS Maritime team held an information sharing session focused on EMP applications, regulatory review, EMP variations, MOHA creation and common practical questions.
For shipping companies preparing for UK ETS Maritime compliance, the following points are particularly worth noting.
1. An EMP can be applied for early, but no later than 42 days after the first activity
The EMP sets out how a maritime operator will monitor, record and report its UK ETS maritime emissions, covering vessels, fuels, emission sources, monitoring methods, internal procedures and responsible personnel.
An EMP is applied for at maritime operator level, not one plan per ship. A single EMP can cover several vessels for which the same maritime operator holds UK ETS responsibility.
Companies do not have to wait until their first UK ETS maritime activity takes place before preparing. The session confirmed that an EMP can be applied for in advance where vessels are expected to carry out activity within scope; but once the first applicable activity has occurred, the EMP application must in principle be submitted within 42 days.
One point deserves particular attention: the 42 days is the deadline for submitting the application, not a deadline by which the regulator must approve the EMP.
Provided the application is submitted on time, the company should continue monitoring emissions and respond promptly to any regulator requests for amendments or additional information.
2. Submitting an EMP does not automatically start the two-month clock
Environment Agency guidance provides that the regulator will in principle determine an application within two months of it becoming "duly made", unless a longer period is agreed.
An application is duly made where:
- the EMP application form has been submitted;
- all required information has been provided;
- the applicable application fee has been paid.
In other words, if a company simply clicks submit while information is still missing or the payment task is outstanding, the submission date cannot be treated as the start of the two-month review period.
The session also noted that application volumes are currently high, and that fleet size, EMP complexity and the number of requests for further information all affect actual review times.
3. Once the EMP is approved, the MOHA is created by the system
After the EMP is approved, the company will be notified and can download the approved EMP from METS.
The Maritime Operator Holding Account (MOHA) is then created by the UK ETS Registry. The Registry team contacts the relevant METS contacts and explains the process for account access and for appointing authorised representatives (ARs).
Two things should not be confused: creation of the MOHA does not mean that company personnel automatically have operating rights in the Registry.
The company still needs to complete the nomination of personnel, due diligence and access arrangements as required by the Registry team.
The MOHA is the central account for UK ETS Maritime compliance: it records the emissions to be surrendered and can receive, hold and surrender UKAs. Allowances can be received into the account as soon as it is opened, even before ARs have been appointed.
4. Adding vessels or fuels requires a timely EMP variation
Approval of an EMP does not mean the fleet and monitoring arrangements are fixed.
The Environment Agency distinguishes between significant changes and non-significant changes to an EMP.
Significant changes include:
- adding vessels;
- adding fuels or emission sources;
- changing the monitoring method;
- changing emission factors;
- a change in the name or address of the EMP holder;
- an intention to use eligible fuels that may give rise to an emissions reduction claim;
- other changes that may have a material effect on emissions monitoring and reporting.
A variation for a significant change should in principle be applied for at least 14 days in advance; where that is not objectively possible, it should be submitted as soon as possible after the change occurs.
Removing vessels or updating procedures is normally a non-significant change and should be completed by 31 December of the year in which it occurs; several non-significant changes in the same year can be combined into a single variation application.
The 3 August session further confirmed that no separate application fee is charged for an EMP variation, as the related regulatory costs are covered by the annual subsistence fee.
5. A change of registered owner means the delegation must be redone
Where an ISM company holds UK ETS responsibility, changes of registered owner require particular attention.
Under the UK ETS, the registered owner is by default the responsible party. An ISM company can only become the maritime operator where it also takes on operational responsibility for the vessel and ISM Code responsibility, and assumes UK ETS responsibility under a legally binding written agreement.
The Q&A made a further point clear: if the registered owner of a vessel changes, a new delegation agreement must be signed with the new registered owner, even where the ISM company is unchanged.
The delegated responsibility details should then be updated through an EMP variation.
UK ETS responsibility transfers also cannot be applied retrospectively.
For sale and purchase, finance leases and changes of ship management, therefore, it is not enough to check whether the vessel is still listed in the existing EMP; the registered owner and the delegation documents must be reconfirmed.
6. The official Q&A clarified several easily overlooked practical points
The webinar also addressed a number of questions arising in day-to-day practice.
1. Can an EMP be applied for first and vessels added later?
Yes, an application can be based on the position as confirmed, but METS currently does not support submitting an EMP with zero vessels; at least one vessel must be included. Further vessels can be added later by variation.
2. Will each vessel have its own EMP?
No. The EMP is issued at maritime operator level. At this stage, UK ETS Maritime also does not require vessels to carry a document equivalent to the EU MRV Document of Compliance (DoC).
3. If a fuel listed in the EMP is not used this year, does it need to be removed?
No. Fuels that are not actually used can remain in the EMP. Adding a new fuel later, however, is normally a significant change and requires a timely variation.
4. If a vessel waits at anchor for a berth within UK port limits, do those emissions automatically fall within the UK ETS?
Not necessarily. Where a vessel is simply waiting at anchor for a berth, the emissions normally remain part of the preceding voyage. So if that voyage was international, emissions do not automatically become UK ETS in-port emissions merely because the vessel has entered UK port limits.
If cargo operations, embarkation or disembarkation of passengers, or ship-to-ship transfers take place at anchor, the assessment may change and depends on the specific circumstances.
5. With no UK ETS Maritime activity during the year, is an annual report task still required?
An annual emissions report task may still appear in METS, and the company can select "no maritime activity". For the 2026 reporting year, the submission function opens from 1 January 2027.
Published official guidance similarly confirms that the annual reporting window runs from 1 January to 31 March in the year following the scheme year.
7. Biofuel emissions reduction claims: prepare the evidence in advance
For companies planning to use biofuels or other eligible fuels, the UK ETS provides an emissions reduction claim mechanism.
Where a claim is successfully made for a qualifying eligible fuel, a zero emission factor can be applied, reducing the company's maritime emissions figure and the number of UKAs ultimately to be surrendered.
Under the current published rules, companies must demonstrate that:
- the fuel is an eligible fuel;
- the procurement timing requirements are met;
- delivery to the "point of no return" took place before the prescribed deadline;
- a no double counting declaration is provided;
- supporting material on fuel eligibility, procurement, delivery and quantities is made available to the verifier.
Emissions reduction claims therefore cannot be assembled at the annual reporting stage. Companies planning to use green fuels should start retaining the relevant evidence from the fuel procurement and EMP management stage onwards.
For support with UKA procurement, allowance demand calculations or annual compliance planning, you are welcome to contact Tecway Maritime.
References
- Environment Agency, UK Emissions Trading Scheme for maritime: how to comply, GOV.UK, published 22 June 2026.
- Department for Energy Security and Net Zero, Participating in the UK ETS, GOV.UK.
- Environment Agency UK ETS Maritime Team, UK ETS Maritime Information Sharing Session, 3 August 2026.
Note: this article is compiled from publicly available official material and is provided for reference only.
About Tecway Maritime
Tecway Maritime Technology Limited was established in 2016 as the Tecway Group team dedicated to green shipping and marine consultancy services. The group's parent company, Tecway International Limited, was founded in 1993 and has served the global maritime industry for more than thirty years.
Tecway Maritime focuses on the core needs of shipping companies in their low-carbon transition, providing UK ETS (UKA), EU ETS (EUA) and FuelEU compliance consultancy, green hydrogen project support for shipping, FGSS services, supply and technical support for the Cylinder Liner Diameter Measurement (CLDM) system, and export solutions for Chinese-built marine equipment. Drawing on a global network across Asia, the Middle East and Europe, Tecway Maritime delivers reliable, high-quality and sustainable solutions that help shipping companies respond to regulatory change and capture new opportunities in green shipping.