The UK Environment Agency has recently published new official guidance, *UK Emissions Trading Scheme for maritime: how to comply*, setting out the compliance workflow for UK ETS maritime.
Under the current arrangements, UK ETS maritime will apply to relevant UK domestic maritime activities from 1 July 2026. For shipowners, ship management companies and maritime operators with UK port calls and UK domestic voyages, compliance preparations typically begin with several preparatory steps: confirming the responsible regulator, setting up a METS account, applying for an Emissions Monitoring Plan (EMP) and choosing the emissions monitoring method.
Based on the official guidance, this article summarises the preparatory steps for UK ETS maritime compliance for reference.
Step 1: Confirm the regulator
Maritime operators first need to identify the relevant UK ETS regulator based on the location of their registered office or place of residence.
According to the official guidance, UK ETS maritime regulators are broadly divided as follows:
- Maritime operators registered or resident in England or outside the UK: regulated by the Environment Agency.
- Northern Ireland: regulated by the Northern Ireland Environment Agency.
- Scotland: regulated by the Scottish Environment Protection Agency.
- Wales: regulated by Natural Resources Wales.
Companies based in China or other jurisdictions outside the UK should therefore contact the Environment Agency in the first instance.
When contacting the regulator, the following information is typically required:
- Name of the METS primary contact.
- Email address of the METS primary contact.
- IMO Company and Registered Owner Identification Number.
- Legal entity name of the maritime operator.
Step 2: Set up a METS account
UK ETS maritime compliance activities are managed primarily through METS, the *Manage your Emissions Trading Scheme* online system used in the UK for administering ETS reporting and compliance.
To set up an account, the maritime operator needs to contact the Environment Agency and provide:
- IMO Company and Registered Owner Identification Number.
- Operator name.
- Contact name and email address.
The Environment Agency will use this information to create a METS account. Once the account has been created, the company will receive an email and must click the verification link within 72 hours to accept the account. If the verification link expires, the Environment Agency should be contacted to reissue it.
Within METS, maritime operators can carry out a range of UK ETS maritime compliance tasks, including:
- Applying for and viewing an Emissions Monitoring Plan.
- Paying the EMP application fee.
- Requesting changes to an EMP.
- Adding or removing account users.
- Linking a verifier and a data provider.
- Receiving notifications from the regulator.
- Submitting annual emissions reports.
- Submitting an improvement report where applicable.
The METS account is therefore the foundation of the UK ETS maritime compliance workflow. Companies that have not yet set up an account should prepare the required information and contact the regulator as early as possible.
Step 3: Apply for an Emissions Monitoring Plan (EMP)
If a company is already carrying out maritime activities covered by UK ETS as a maritime operator, it should apply for an Emissions Monitoring Plan (EMP) through METS within 42 days of first undertaking such activities.
A key point to note is that under UK ETS maritime, the EMP is an operator-level monitoring plan, not a ship-level plan. It should therefore be submitted by the maritime operator, list the vessels for which that operator is responsible, and explain how greenhouse gas emissions from those vessels will be monitored and reported.
An EMP typically includes:
- Information on the EMP holder, including legal entity details.
- Activity information, including geographic scope and purpose (for example, cargo or passenger services).
- The list of vessels covered by the operator's UK ETS responsibilities.
- Any relevant delegation of responsibility statements, if applicable.
- Fuels, emission sources, emission factors and monitoring methods for each vessel.
- Procedures and systems relating to monitoring, reporting and emissions-reduction claims.
Vessel and emission factor information can be submitted via:
- Manual entry.
- XML file upload.
- API integration with METS via a data service provider.
It is worth noting that even if a vessel has not yet been added to an EMP, the operator remains responsible for that vessel's UK ETS-covered maritime emissions where responsibility rests with them. Companies should therefore keep vessel information in the EMP up to date to avoid mismatches between actual responsibility and system records.
Step 4: Choose and apply a monitoring method
UK ETS maritime covers the following greenhouse gases: CO₂, CH₄ and N₂O, with emissions expressed as CO₂e.
The official guidance sets out several monitoring methods that can be used to monitor fuel consumption or greenhouse gas emissions. Maritime operators must specify the intended method in the EMP and apply it consistently in line with the approved plan.
Method A: BDN and periodic tank stock-take
Fuel consumption is calculated based on Bunker Delivery Notes and periodic fuel tank readings.
Method B: On-board tank monitoring
Fuel consumption is calculated from tank readings obtained through automated systems, sounding or dipping.
Method C: Flow meters
Fuel consumption is calculated from flow meter data on relevant on-board combustion processes.
Method D: Direct emissions measurement
Emissions are calculated directly from the greenhouse gas concentration and exhaust flow measured in the funnel or exhaust system.
Step 5: Pay the EMP application fee and await approval
Once an EMP application has been submitted, METS generates a task to pay the application fee. Payment can be made through GOV.UK Pay by credit or debit card, or by bank transfer. Bank transfer, however, may take longer to process.
The Environment Agency will review the EMP application and may request additional information. Once approved, the EMP is formally issued in METS. According to the official guidance, after the Environment Agency issues the EMP, a Maritime Operator Holding Account (MOHA) is created for the company in the UK ETS Registry. The Registry Administrator will then send the MOHA account information to the relevant METS contacts, together with instructions on how to appoint an authorised representative.
For maritime operators, EMP approval is a critical foundation for subsequent UK ETS maritime compliance activities. Once the EMP has been issued and the MOHA created, the company will need to complete the appointment of authorised representatives, confirm account permissions and carry out other follow-up account tasks as required by the Registry Administrator, while continuing with annual emissions monitoring, verified reporting and UKA surrender.
If you have specific requirements around UKA procurement, allowance demand estimation or annual compliance planning, please feel free to get in touch with Tecway Maritime for further discussion.
References
- GOV.UK official guidance: *UK Emissions Trading Scheme for maritime: how to comply*
*Note: This article is based on publicly available official materials and is provided for general information and industry discussion only. It does not constitute legal, compliance or transaction advice.*