REPORT FROM THE COMMISSION Review of Regulation (EU) 2015/757 on the monitoring, reporting and verification of greenhouse gas emissions from maritime transport in relation to the potential inclusion of ships below 5 000 gross tonnage but not below 400 gross tonnage
Date: 2025-03-18
Institutions: Directorate-General for Climate Action, European Commission
Subjects: EU environmental policy, energy consumption, energy efficiency, environmental impact, environmental monitoring, greenhouse gas, marine fuel, maritime transport, pollution from ships, reduction of gas emissions

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 18.3.2025  COM(2025) 109 final  REPORT FROM THE COMMISSION Review of Regulation (EU) 2015/757 on the monitoring, reporting and verification of greenhouse gas emissions from maritime transport in relation to the potential inclusion of ships below 5 000 gross tonnage but not below 400 gross tonnage  
 
 
REPORT FROM THE COMMISSION 

Review of Regulation (EU) 2015/757 on the monitoring, reporting and verification of 
greenhouse gas emissions from maritime transport in relation to the potential inclusion of 
ships below 5 000 gross tonnage but not below 400 gross tonnage 

1.  Introduction 

Maritime  transport  plays  an  essential  role  in  the  EU  economy  and  is  one  of  the  most  energy-
efficient  modes of transport. However, it is  also a  significant  source of greenhouse gas (GHG) 
emissions. 

Regulation  (EU)  2015/757  on  the  monitoring,  reporting  and  verification  of  greenhouse  gas 
emissions from maritime transport is an essential part of the EU’s action to address climate change 
in  the  maritime  transport  sector.  The  so-called  ‘MRV  maritime  Regulation’  requires  shipping 
companies  to  monitor  their  GHG  emissions,  fuel  consumption  and  other  relevant  information 
linked to EU voyages. Its main objectives are to collect robust and verified GHG emissions data, 
stimulate the uptake of energy-efficiency and low-carbon solutions with more transparency and 
support the implementation of climate mitigation policies, such as the recent extension of the EU 
Emissions Trading System (ETS) to maritime transport. It also plays a critical role in feeding future 
policy discussion, as the first step towards mitigation actions is to understand how much is being 
emitted and where. 

Pursuant to Article 22a of the MRV maritime Regulation, the aim of the present report is to assess 
the possible inclusion of ships below 5 000 gross tonnage but not below 400 gross tonnage (GT) 
within the scope of this Regulation, with a view to a possible subsequent inclusion of such small 
ships within the scope of the ETS Directive1 or to proposing other measures to reduce greenhouse 
gas emissions from such ships. The present report will therefore also serve as an input, as deemed 
relevant, for the planned 2026 review2 of the ETS Directive. 

The present report is structured as follows: 

•  Overview  of  the  implementation  of  the  MRV  maritime  Regulation,  notably  in  light  of 

recent changes; 

•  Review of the current scope of the MRV maritime Regulation; 

•  Assessment  of  scenarios  to  extend  the  scope  of  MRV  maritime  Regulation  to  smaller 

vessels (400 to 4 999 GT). 

1 Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 establishing a scheme for 
greenhouse gas emission allowance trading within the Community and amending Council Directive 96/61/EC (OJ L 
275, 25.10.2003, p. 32). 
2  According to Article 3gg(5) of the ETS Directive, no later than 31 December 2026, the Commission should present 
a report in which ‘it shall examine the feasibility and economic, environmental and social impacts of the inclusion in 
[that] Directive of emissions from ships, including offshore ships, below 5 000 gross tonnage but not below 400 gross 
tonnage, building, in particular, on the analysis accompanying the review of Regulation (EU) 2015/757 due by 31 
December 2024.’ 

1 

 
 
 
The analysis presented in this report builds on a study carried out by a consortium of contractors.3  

2.  Overview of the implementation of the MRV maritime Regulation 

2.1 Presentation of the MRV maritime Regulation and its recent modifications 
Since  1  January  2018,  large  ships  over  5  000  gross  tonnage  loading  or  unloading  cargo  or 
passengers at ports in the European Union (EU)4 must monitor and report related GHG emissions 
(only CO2 emissions between 2018 and 2023, but also nitrous oxide and methane emissions since 
January  2024)  and  other  relevant  information.  Monitoring,  reporting  and  verification  of 
information must be done in conformity with the MRV maritime Regulation. 

The MRV maritime Regulation sets requirements for shipping companies to monitor and report 
their emissions for each of their ships, each calendar year, on a cyclical basis. All ships performing 
voyages within the scope of the MRV maritime Regulation, regardless of their flag state, must 
submit a monitoring plan detailing how they intend to collect emission data within two months of 
their  first  call  to  a  port  in  the  EU.  The  monitoring  plan  must  be  assessed  satisfactorily  by  an 
accredited verifier prior to data collection, and the collected data (compiled in an annual emission 
report) has to be verified at the end of each reporting period. Upon verification, a Document of 
Compliance  is  issued  by  the  verifier  and  the  reports  are  submitted  to  the  Commission  via  the 
THETIS MRV portal. The enforcement of the EU MRV process is done by Member States by 
inspecting ships that enter ports under their jurisdiction and by taking all the necessary measures 
to ensure that ships flying their flag are compliant with the Regulation. 

The  MRV  maritime  Regulation  was  conceived  as  a  first  step  before  the  inclusion  of  these 
emissions  within  the  scope  of  the  EU  Emissions  Trading  System  (ETS).  Such  inclusion 
materialised through the 2023 revision of the EU ETS Directive, which – among others – brought 
maritime transport emissions within its scope as from January 2024.5 

The  MRV  maritime  Regulation  itself  was  amended  in  20236  to  adapt  the  MRV  rules  to  the 
inclusion of maritime transport activities in  the EU ETS.  It  was also  amended to  include other 
emissions  than  CO2,  namely  nitrous  oxide  (N2O)  and  methane  (CH4)  within  its  scope  as  of  1 
January 2024. Furthermore, it was agreed to  extend its scope, from  1 January 2025, to  general 
cargo vessels of 400 GT and above, and to offshore ships of 400 GT and above.7 As such, the 
MRV maritime Regulation  already applies (from 2025) to  two types of smaller vessels; this is 
taken into consideration in the present report. 

3 Ricardo et al., 2025 – “Supporting study for the implementation of the ETS directive and MRV requirements for 
maritime transport”, publication upcoming  
4 References to the EU as a region in this report include non-EU countries that are part of the European Economic 
Area (EEA), unless specified otherwise 
5 For more information on the ETS extension to maritime transport emissions and its overall timeline, please refer to 
the  Commission’s  dedicated  webpage  and  Frequently  Asked  Questions:  https://climate.ec.europa.eu/eu-
action/transport/reducing-emissions-shipping-sector/faq-maritime-transport-eu-emissions-trading-system-ets_en  
6 by Regulation (EU) 2023/957  
7 For more information on the MRV maritime Regulation, please refer to the Commission’s dedicated webpage and 
Frequently  Asked  Questions: 
https://climate.ec.europa.eu/eu-action/transport/reducing-emissions-shipping-
sector/faq-monitoring-reporting-and-verification-maritime-transport-emissions_en  

2 

 
 
 
In addition, the MRV maritime Regulation contributes to supporting the implementation of the 
FuelEU Maritime Regulation8, which enters into application in 2025.  All monitored and recorded 
data under the MRV maritime Regulation can indeed be used for FuelEU calculations, subject to 
confirmation by FuelEU Verifier, if different from the MRV Verifier. 

2.2 Implementation of the MRV maritime Regulation 

The MRV maritime Regulation has applied since 2018 and has delivered robust data and indicators 
on GHG emissions from maritime transport. The 2022 Supporting study for the implementation of 
Regulation (EU) 2015/757 on the monitoring, reporting and verification of CO2 emissions from 
maritime transport9 notably underlined that one of the main advantages of the Regulation is the 
insights gained in the environmental performance of the vessels entering or leaving EU ports, by 
allowing  for  the  systematic  collection  of  vessel  performance  data.  That  study  also  highlighted 
some obstacles in the implementation, such as the persistence of some delays in the submission of 
the emissions reports – with several stakeholders indicating that fulfilling the requirements was 
challenging, especially in the first year (2018). 

To help relevant stakeholders familiarise themselves with the 2023 changes to the MRV maritime 
Regulation and reduce potential implementation challenges, the Commission carried out outreach 
activities and developed guidance and material available online. The Commission has for instance 
published two sets of Frequently Asked Questions10 – on the MRV maritime Regulation and on 
the ETS extension to maritime transport emissions – as well as two main Guidance Documents11. 
Between  September 2023  and  April  2024, the  Commission  has  also  held  five  webinars  on  key 
aspects of the changes brought to the MRV maritime Regulation and ETS Directive (such as on 
updates to the monitoring plans), together with the European Maritime Safety Agency (EMSA)12. 
Besides, a dedicated helpdesk13 was established to address questions from shipping companies and 
other  stakeholders  –  with  more  than  1  400  tickets  closed  between  September  2023  and 
October 2024. 

Preliminary  monitoring  of  compliance  and  implementation  for  the  2024  reporting  year  are 
encouraging. At the time of writing this report, more than 15 000 ships have updated and submitted 
their  monitoring  plans  to  the  administering  authorities  for  approval,  in  line  with  the  new 

8 Regulation  (EU)  2023/1805  on  the  use  of  renewable  and  low-carbon  fuels  in  maritime  transport,  and  amending 
Directive 2009/16/EC 

of 

CO2 

emissions 

verification 

from  maritime 

9 Supporting study for the implementation of Regulation (EU) 2015/757 on the monitoring, reporting  
and 
https://climate.ec.europa.eu/document/download/55b302ef-c819-4a2f-9b83-
c57c2bcfbe7e_en?filename=policy_transport_maritime_study_eu_mrv_en.pdf  
10  See  under 
sector_en#faq  
11 See under ‘Documentation’ section: https://climate.ec.europa.eu/eu-action/transport/reducing-emissions-shipping-
sector_en#documentation  
12  See  recordings  under  the  ‘Events’  section:  https://climate.ec.europa.eu/eu-action/transport/reducing-emissions-
shipping-sector_en#events  
13 Fitfor55@emsa.europa.eu  

section:  https://climate.ec.europa.eu/eu-action/transport/reducing-emissions-shipping-

European  Union, 

transport, 

‘FAQ’ 

2022:  

3 

 
 
 
 
requirements that entered into force in 2023. The next key milestone will be the submission of 
emissions reports at ship-level and at company-level, which are due by end March 2025. 

For additional context, the emissions reported under MRV for 2023 originated from a fleet of over 
12 000 ships. The monitored voyages for the 2023 reporting year emitted 126,7 million tonnes of 
CO2 into the atmosphere. At the time of writing this report, the system encompasses around 5 000 
shipping companies.14  

Every year, the Commission publishes a report to inform the public about the GHG emissions and 
energy efficiency information of the monitored fleet falling within the scope of MRV maritime 
Regulation.15 

3.  Review of the current scope of the MRV maritime Regulation 

This review aims to respond to the general question whether the scope of vessels under the MRV 
maritime Regulation (size thresholds and vessel types) has been appropriate so far and whether 
reasons to exclude certain vessels between 400 and 4 999 GT are still valid. The initial threshold 
of 5 000 GT was selected in 2015 after detailed objective analysis of sizes and emissions of ships 
going to and coming from EU ports. The objective of this non-discriminatory threshold was to 
cover the most relevant emitters, while finding the right balance between administrative burden 
and environmental effectiveness of the MRV maritime Regulation. At that time, analysis suggested 
that  using  a  threshold  of  5000  GT  instead  of  400  GT  would  substantially  reduce  estimated 
administrative costs, with a relatively small decrease of CO2 emissions covered. 

3.1 Effectiveness and relevance 

The MRV maritime regulation aims to establish a standardized system for monitoring, reporting 
and verifying GHG emissions from vessels calling at EU ports, with harmonized rules and public 
access to verified data. The transparency and robustness behind this data are key to help shipping 
companies address existing market failures and unlock the adoption of decarbonisation measures. 
Market failures typically includes informational issues, such as the lack of reliable information on 
GHG savings or asymmetric information between shipowners and charterers that can lead to split 
incentives issues. 

A  2022  EC  study16  asked  shipping  companies  on  their  use  of  MRV  data.  They  reported  that 
systematically  measuring  and  documenting  emissions  provides  a  coherent  baseline  of 
environmental performance, providing the companies with knowledge and insights on their fleet 
emissions. These insights led to easier and simplified communication with their clients (shippers, 
forwarders, etc). Shipping companies reported that they can transfer emissions-related information 
to  their  clients,  which  raises  awareness  on  the  receiving  end  of  the  supply  chain.  However,  a 
previous study (CE Delft, 2014) highlights that these positive effects are most likely to materialise 
if companies invest in accurate and comprehensive monitoring and data analysis systems. 

14 This includes companies registered in THETIS-MRV with active ships in their fleet. 
15  MRV  annual  reports  are  available  under 
https://climate.ec.europa.eu/eu-action/transport/reducing-emissions-shipping-sector_en#documentation  
16 Supporting study for the implementation of Regulation (EU) 2015/757 on the monitoring, reporting and verification 
of CO2 emissions from maritime transport, 2022 

the  ‘Documentation’  section  of 

the  following  webpage: 

4 

 
 
 
In relation to small vessels, the effectiveness analysis aims to understand the extent to which the 
current MRV scope (vessel size and type) may prevent smaller vessels from seizing the various 
benefits coming from the MRV Regulation. 

Based on a stakeholder consultation with public authorities and industry organisations, the analysis 
suggests that MRV data is expected to be highly valuable also for smaller vessels. MRV data is 
indeed key for informing financial and management decisions that could provide further insights 
into fleet emissions and help eliminate market barriers. While several companies operating smaller 
vessels are already voluntarily collecting emissions data, sometimes with the objective to inform 
investment decisions in energy-efficient and low carbon technologies, the analysis shows that these 
companies and third parties could still benefit from MRV in ensuring more consistent and reliable 
monitoring and reporting processes across the board. 

Therefore, with its current scope, the MRV maritime Regulation falls short of enabling emissions 
reductions technology investments on all types of small vessels (i.e. beyond those already within 
MRV scope as  from 2025) and promoting adoption of operational  energy efficiency measures, 
especially for those without existing fuel performance monitoring systems. 

In  terms  of  relevance,  the  MRV  maritime  Regulation  is  an  important  enabler  to  support  the 
adoption of GHG mitigation measures and policies in the maritime sector. This is relevant as all 
sectors of the economy, including small and large vessels, need to contribute to achieving the EU 
climate objectives as well as the objectives of the Paris agreement. By establishing a standardized 
system  for  monitoring,  reporting,  and  verifying  GHG  emissions  from  vessels,  the  regulation 
provides  a  critical  tool  for  shipping  companies  to  inform  financial  and  management  decisions, 
communicate  with  stakeholders,  and  identify  opportunities  for  emissions  reductions  and 
technology investments. 

3.2  Efficiency 

The analysis of efficiency aims to review recent evidence on the trade-off between GHG emissions 
coverage and administrative costs for shipping companies with respect to the EU MRV scope17. 
For this, the potential MRV-related administrative costs have been estimated for smaller vessels 
and compared to those of vessels already reporting under MRV.  

Estimations  of  administrative  costs  comes  from  a  consultation  of  representatives  of  shipping 
companies through tailored interviews, including both ship operators and shipowners. The exercise 
considered both one-off and recurring costs.  Shipping companies were asked to estimate recurrent 
costs  from  vessels  currently  under  the  MRV,  based  on  their  current  experience,  along  with 
expected costs for smaller vessels in the event that these would be included within the scope of the 
MRV maritime Regulation.  

17 The extension of the MRV maritime Regulation to smaller vessels would also lead to additional costs for public 
authorities, which are presented in the assessment of scenarios to extend the scope. The present analysis of efficiency 
looks at the relative ratio of administrative costs and GHG emissions covered, and for this purpose only administrative 
costs for shipping companies are considered as they represent the main cost component. 

5 

 
 
  
 
The analysis reveals that recurrent annual MRV-related administrative costs per vessel for smaller 
vessels (estimated at EUR 3 690 per vessel on average) would be similar or slightly higher than 
those  of  vessels  currently  subject  to  MRV  obligations  (estimated  at  EUR  3  390  per  vessel  on 
average). Staff limitations and increased frequency of voyages of smaller vessels have been quoted 
by some shipping companies as the main reasons for higher monitoring costs.  

Overall,  the  trade-off  between  administrative  costs  for  shipping  companies  and  additional 
monitored  GHG  emissions  would  be  less  favourable  for  smaller  vessels.  The  ratio  between 
administrative costs and coverage of GHG emissions would be on average seven times higher for 
smaller vessels, compared to the larger vessels already reporting under MRV (Figure 1). This is 
because the administrative costs are comparable, while smaller vessels emit much less emission 
than bigger vessels.  

Figure 1 Recurring administrative cost for shipping companies per tonne of CO2 covered for smaller vessels by type 
(calculated as the results of total estimated recurring administrative costs based on average costs reported by consulted 
stakeholders per the total CO2e emissions for each vessel category for 2023)  

4,9

2,5

1,4

1,3

1,2

1,5

2,0

1,7

1,4

1,1

2,7

2,9

2,3

1,3

1,4

0,8

1,7

1,7

6,0

5,0

4,0

3,0

2,0

1,0

0,0

)
R
U
E
(
e
n
n
o
t
e
2
O
C
r
e
p
t
s
o
c
e
v
i
t
a
r
t
s
i
n
m
d
A

i

Vessel type

Source: Ricardo analysis 

Ships included in MRV from 2025 

 ---  Average administrative cost per tCO2e for small vessels (400-4,999 GT) 

Ships not included in MRV 

 ---  Average administrative cost per tCO2e for large vessels (above 5,000 GT) 

The analysis of efficiency also aims to review evidence on the capacity of companies managing 
smaller vessels to accommodate MRV processes, compared to those already reporting under MRV. 
Examined data suggests that companies managing smaller vessels tend to be on average smaller 

6 

 
 
 
 
 
 
 
 
 
 
 
 
(in terms of number of vessels managed per company) than those already reporting under MRV. 
Indeed,  companies  currently  reporting  under  the  MRV  system  (i.e.  for  large  vessels)  are 
responsible for 2,6 vessels on average. For smaller vessels, it is estimated18 that the average number 
of small  vessels per company would be 1,6,  which is  significantly lower. Since the companies 
managing  smaller  vessels  are  expected  to  be  responsible  for  less  ships,  they  would  less  likely 
benefit from economies of scale associated with MRV-related implementation costs. 

In  addition,  the  majority  of  companies  managing  smaller  vessels  would  be  new  to  the  MRV 
system. Only 29% of the ISM companies19 and 3% of the shipowners managing smaller vessels 
are already registered on THETIS-MRV. This suggests that the majority of companies managing 
smaller vessels would need to set up and familiarise themselves with MRV processes as they are 
not already reporting under MRV. 

3.3 Coherence 

Another key objective of the EU maritime MRV Regulation is to support the implementation of 
recently adopted policies to reduce GHG emissions in the EU maritime sector, particularly the EU 
ETS  extension  to  maritime  transport  and  the  FuelEU  Maritime  Regulation20.  The  analysis  of 
coherence therefore looks into whether the current MRV scope is appropriate to contribute to the 
implementation of these specific climate policies, as well as their possible future review. 

In  that  respect,  the  analysis  shows  that  the  MRV  maritime  Regulation  is  already  effectively 
supporting the roll out of these important EU policies. It directly provides the GHG emission data 
needed to implement the EU ETS extension to maritime transport, and it offers a robust reporting 
platform to support the implementation of the FuelEU Maritime Regulation.  

With  regards  to  potential  future  policy  developments,  the  current  scope  of  the  MRV  maritime 
Regulation would already enable the possible extension of the EU ETS scope to GHG emissions 
from small general cargo and offshore vessels (400-4 999 GT). For instance, policy makers would 
know the possible impact of such an extension in terms of the ETS cap increase or the number of 
additional Maritime Operators Holding Accounts to be expected. Shipping companies operating 
these  vessels  would  also  be  in  much  better  position,  being  already  familiarised  with  the  MRV 
process. 

18 As we do not know which of the entity (between the shipowner or ISM company, if different) would take MRV 
responsibility for small ships, the study assumes that the same share of shipowners and ISM companies will endorse 
MRV responsibility for the smaller vessels as for larger vessels (i.e. 53% of shipowners and 47% of ISM companies 
as extracted from THETIS MRV in October 2024). Based on MARINFO database information, the fleet of smaller 
vessels under consideration is related to 1 262 ISM companies and 4 014 shipowners. 
19‘ISM company’ is an organisation or person that has assumed the responsibility for the operation of the ship from 
the shipowner and that, on assuming such responsibility, has agreed to take over all the duties and responsibilities 
imposed by the International Management Code for the Safe Operation of Ships and for Pollution Prevention, set out 
in Annex I to Regulation (EC) No 336/2006 of the European Parliament and of the Council. 
20 Regulation (EU) 2023/1805 of the European Parliament and of the Council on the use of renewable and low-carbon 
fuels in maritime transport, and amending Directive 2009/16/EC (OJ L 234, 22.9.2023, p. 48–100). 

7 

 
 
 
 
 
However, the present MRV maritime Regulation would not enable in the same way the possible 
extension  of  the  ETS  scope  to  GHG  emissions  from  the  other  types  of  small  vessels,  not  yet 
included under the MRV scope.   

Furthermore, the analysis looked at the scope of the EU maritime MRV Regulation in comparison 
to  the  vessels  covered  under  the  current  IMO  Data  Collection  System  (DCS).  The  latter  is  an 
equivalent,  although  simplified,  monitoring  and  reporting  system  at  global  level.  The  analysis 
highlights that the slight differences in scope in terms of vessel size and activity covered were not 
identified as a particular concern in terms of increasing resources needed to complete reporting 
requirements. 

4.  Assessment of scenarios to possibly extend the scope of the MRV maritime Regulation 

to other smaller vessels 
4.1 Overview of activity and emissions from smaller vessels  

This analysis aims to provide information on the activity and emissions from smaller vessels (400 
to 4 999 GT) focusing on the following indicators: 

•  Number of smaller vessels calling at EU ports, by vessel category; 

•  GHG  emissions  for  smaller  vessels  calling  at  EU  ports,  differentiated  by  intra-EU  and 

extra-EU voyages and by vessel category; 

•  Number of port calls by year, differentiated by intra-EU and extra-EU voyages21 and by 

vessel category. 

The analysis shows that 8 525 vessels between 400 – 4999 GT called at EU ports in 2023. When 
excluding general cargo and offshore vessels, which are already incorporated in the MRV maritime 
Regulation from 2025, the number of smaller vessels drops to 5  309. This compares to 12 344 
vessels of or above 5000 GT under MRV in 2023. 

GHG emissions were estimated based on a model relying on ship-tracking data (i.e. Automatic 
Identification System data) and ship technical information. The model estimated CO2, CH4 and 
N2O as CO2-equivalent emissions. The result of this work shows that smaller vessels calling at 
EU  ports  in  2023  are  estimated  to  emit  around  19.28  MtCO2e  (or  18.99  MtCO2,  i.e.  when 
disregarding CH4 and N2O). General cargo and offshore vessels are the highest emitters within this 
segment, as they represent 22% and 18% of GHG emissions from smaller vessels, respectively. 
When  deducting  emissions  from  these  two  categories  already  in  MRV  from  2025,  total  GHG 
22, which 
emissions from the remaining smaller vessel categories are estimated at 11.32 MtCO2
compares to 126.70 MtCO2 from vessels of or above 5 000 GT under MRV in 2023.23  

In terms of activity, analysis of port call data from smaller vessels suggests that  most voyages 
performed  by  smaller vessels  were  intra-EU  in  the  period  2019  –  2023  (around  90%).  Of 

21 For the purpose of this report, ‘intra-EU voyages’ correspond to voyages between two EU ports, while ‘extra-EU 
voyages’ correspond to voyages between an EU port and a non-EU port. 
22 This result is presented in CO2 emissions (rather than the default metric in CO2e) to allow for comparison with 
MRV 2023 data, only available in CO2 emissions. 
23 Disregarding CH4 and N2O emissions facilitates comparisons with 2023 MRV data, since these two GHG emissions 
were not yet falling within MRV scope in that year. 

8 

 
 
 
those, the majority are domestic, that is voyages starting and ending in the same country (around 
75% of total voyages). 

To  sum  up,  this  analysis  shows  that  the  smaller  vessels  not  already  included  in  the  MRV 
Regulation from 2025 (i.e. other than general cargo and offshore ships) are mostly active in 
intra-EU voyages and that they represent 43% of vessels and 9% of CO2 emissions under 
MRV in 2023. 

The table below summarises, by vessel type, the number of vessels and amounts of emissions they 
represent. 

Table 1: CO2 emissions from smaller vessels by vessel type compared to total MRV emissions in 2023 

Type of vessel 

General cargo 

Offshore  

Miscellaneous - fishing 

Chemical tanker 

Ferry-RoPax 

Yacht 

Service – other  

Cruise 

Service - tug 

Liquefied gas tanker 

Oil & Product tanker 

Ferry-pax only 

Bulk carrier 

Refrigerated bulk 

Container 

Miscellaneous - other 

Other liquids tankers 

Ro-Ro 

Number of 
400-4,999 GT 
vessels (2023) 

2,296 

921 

1,065 

756 

571 

896 

349 

217 

385 

143 

256 

253 

111 

53 

38 

154 

42 

20 

Share of 
vessels 
compared to 
number of 
large vessels 
under MRV in 
202324 

18.6% 

7.5% 

8.6% 

6.1% 

4.6% 

7.3% 

2.8% 

1.8% 

3.1% 

1.2% 

2.1% 

2.0% 

0.9% 

0.4% 

0.3% 

1.2% 

0.3% 

0.2% 

Total CO2 
emissions 
(MtCO2) (2023) 

Share of CO2 
emissions 
compared to 
total CO2 
emissions 
under MRV in 
202325 

4.26 

3.41 

2.30 

2.21 

1.57 

1.45 

0.77 

0.56 

0.49 

0.44 

0.38 

0.34 

0.27 

0.14 

0.13 

0.12 

0.11 

0.04 

3.4% 

2.7% 

1.8% 

1.7% 

1.2% 

1.1% 

0.6% 

0.4% 

0.4% 

0.3% 

0.3% 

0.3% 

0.2% 

0.1% 

0.1% 

0.1% 

0.1% 

0.0% 

24 2023 MRV scope, hence excluding smaller (400-4,999 GT) general cargo and offshore vessels to be incorporated 
from 2025. 
25 2023 MRV scope, hence excluding smaller (400-4,999 GT) general cargo and offshore vessels to be incorporated 
from 2025. 

9 

 
 
 
Total vessels 400 – 4,999 GT 

8,525 

69.1% 

18.99 

15.0% 

Total  vessels  400  –  4,999  GT 
excluding general cargo and offshore 

5,309 

43.0% 

11.32 

8.9% 

4.2 Presentation of possible scenarios 

The main scenario under consideration for the present assessment is the possible extension of the 
scope of the MRV maritime Regulation to vessels between 400 and 4 999 GT, for vessel types 
other than general cargo and offshore vessels. This scenario aims to increase the share of GHG 
emissions covered by the MRV maritime Regulation, which would notably allow for a possible 
integration of additional vessels between 400 and 4 999 GT into maritime decarbonisation policies 
such as the EU ETS and Fuel EU. 

Potential variants for the expansion of the MRV scope to smaller vessels are defined  along the 
following dimensions: 

a)  Different smaller vessel categories in scope 

Scenarios A 

Description 

A.1. Including the most 
emitting vessel categories 

Scope expansion to tankers, RoPax ships and passenger ships 
between 400 and 4 999 GT 

A.2. Including all vessel 
categories except the ones 
exempted by MRV 

Expansion to all non-exempt categories26 for vessels between 400 
and 4 999 GT (i.e. all ships transporting cargo/passengers for 
commercial purposes as well as offshore ships) 

A.3. Including all vessel 
categories (including 
categories currently excluded 
from MRV) 

Expansion to all non-exempt categories for vessels between 400 
and 4 999 GT, plus fishing ships, any service and tug vessels not 
already covered, and voyages by yachts not already covered (i.e. 
those not carried out for transporting passengers for commercial 
purposes). 

26 MRV exempted categories are defined in Article 2(2) of the MRV maritime Regulation; those are ‘warships, naval 
auxiliaries,  fish-catching  or  fish-processing  ships,  wooden  ships  of  a  primitive  build,  ships  not  propelled  by 
mechanical means, or government ships used for non-commercial purposes’. 

10 

 
 
 
 
 
b)  Monitoring requirements for smaller vessels 

Scenarios B 

Description 

B.1. Same MRV requirements 

B.2. Lower threshold to be exempted 
from monitoring on a per voyage 
basis 

MRV requirements for small vessels (and other vessel 
types) are the same as those for vessels currently under 
MRV 

Minimum threshold of 300 voyages per year27 would not 
apply to vessels below 5 000 GT, i.e. all ships performing 
intra-EU voyages only during a reporting period would be 
exempted from monitoring on a per voyage basis 
(regardless of the number of voyages). 

4.3 Environmental impacts from scenarios A (different smaller vessels categories in 

scope assuming no changes in MRV requirements) 

Increased GHG emissions coverage 

Expanding  the  scope  of  the  EU  Maritime  MRV  Regulation  would  increase  the  share  of  EU 
maritime emissions captured by the MRV requirements and directly impact GHG emissions data 
availability (Figure 2). The GHG emissions associated with scenario  A.1 represent a 4.2% increase 
(i.e. 5.61 MtCO2) compared to what is included in the revised MRV scope (i.e. including emissions 
from  general  cargo  and  offshore  vessels  between  400  and  4  999  GT  to  be  added  from  2025). 
Scenario A.2 would lead to a marginally higher emissions coverage compared to  scenario A.1, 
with an increase of 4.6% (i.e. 6,19 MtCO2) compared to the MRV revised scope. The option to 
expand also to other categories (scenario A.3) would lead to a more significant expansion in the 
emissions coverage with an 8.4% increase (i.e. 11,32 MtCO2). 

27  Article  9(2)  of  the  MRV  maritime  Regulation  lays down a  derogation according  to  which  a  company  ‘shall be 
exempt from the obligation to monitor the information […] on a per-voyage basis in respect of a specified ship, if: (a) 
all of the ship's voyages during the reporting period either start from or end at a port under the jurisdiction of a Member 
State; and (b) the ship, according to its schedule, performs more than 300 voyages during the reporting period.’ The 
scenario under consideration here would consist in removing the condition under point (b) for smaller vessels. 

11 

 
 
 
 
 
Figure 2 Additional coverage of GHG emissions for scenarios A.1, A.2 and A.3 by vessel category based on 2023 
emissions data 

e
2
O
C
s
e
n
n
o
T

s
n
o

i
l
l
i

M

 14

 12

 10

 8

 6

 4

 2

 -

A.1

A.2

A.3

Oil & Product tanker

Chemical tanker

Other liquids tankers

Liquefied gas tanker

Ferry-pax only

Ferry-RoPax

Cruise

Refrigerated bulk

Container

Yacht

Ro-Ro

Service - other

Miscellaneous - fishing Miscellaneous - other

Bulk carrier

Service - tug

Source: Ricardo analysis 

Direct energy and GHG emissions savings 

Even though the MRV maritime Regulation does not impose direct limits on emissions or mandate 
emission reducing practices, an expansion of the MRV scope would be expected to lead to direct 
energy and GHG emissions reductions due to the potential of MRV data to help overcome some 
of the existing market barriers, which can unlock the adoption of technical and operational energy 
efficiency improvements. A conservative 0.7% cumulative reduction rate was assumed to apply to 
baseline GHG emissions from smaller vessels included in the MRV scope within the period 2025-
2050.28 This would lead to relatively small cumulative GHG emission savings presented below in 
Table 2. 

Table 2: Cumulative GHG emissions savings (2025-2050) from scenarios A.1, A.2 and A.3  

Scenario A.1 

Scenario A.2 

Scenario A.3 

Source: Ricardo analysis 

Cumulative GHG emission savings (MtCO2e) 2025 - 2050 

1.51 

1.67 

3.06 

28    This  assumption  is  based  on  a  study  looking  into  the  benefits  of  MRV  maritime  Regulation  with  its  findings 
assumed to be applicable to smaller vessels (European Commission, 2019) 

12 

 
 
  
 
 
 
 
Indirect environmental impacts from potential inclusion of smaller vessels into 
other climate policies 

While direct GHG emissions savings coming from the expansion of the MRV scope to additional 
smaller  vessels  would  be  relatively  marginal,  the  potential  environmental  impacts  from  the 
possible inclusion of these smaller vessels into other climate mitigation policies, such as the EU 
ETS and Fuel EU maritime, following the MRV scope expansion would be much more significant. 
For instance, including additional GHG emissions in the EU ETS would lead to an environmental 
impact  in  line  with  the  ETS  annual  cap  reduction.  However,  such  additional  benefits  are  not 
considered for the purpose of this assessment as it focusses on the potential inclusion in the MRV 
scope only. 

4.4 Economic impacts from scenarios A (different smaller vessels categories in scope 

assuming no changes in MRV requirements) 

Regulatory costs for shipping companies and authorities  

Additional administrative costs for shipping companies would include both one-off and recurring 
costs relating to preparing and setting up a monitoring system (for companies not already reporting 
under the MRV), along with recurrent monitoring, reporting and verification activities to comply 
with  the  MRV  maritime  Regulation  for  additional  vessels  covered.  Table  3  presents  the  total 
additional one-off and recurrent  administrative costs for shipping  companies for each  scenario,  
based on the outcomes of the stakeholders’ consultation. In addition, it includes information on 
the recurrent administrative cost per tonne of CO2 based on the total GHG emissions added to the 
scope in each scenario. 

Table 3: Additional administrative cost for shipping companies for each scenario, based on 2023 cost data 

Number 
vessels 

of 

One-off 
cost, EUR) 

cost 

(total 

Recurring  cost  (cost 
per year, EUR) 

Recurring  cost  per 
tCO2 (EUR/tCO2) 

Cost per vessel 

- 

Scenario A.1 

Scenario A.2 

Scenario A.3 

2,238 

2,460 

5,309 

Source: Ricardo analysis  

3,193 

7.1 million 

7.9 million 

3,690 

8.3 million 

9.1 million 

17.0 million  

19.6 million 

- 

1.2 

1.2 

1.6 

The  costs  of  enforcement  activities  for  national  authorities  associated  with  the  MRV  maritime 
Regulation include those related to Port State Control activities and Flag State obligations. Cost 
estimates were derived from the outcomes of a questionnaire distributed to Member States, which 
encompassed both administrative and enforcement costs. Recurrent enforcement costs are assumed 
to increase linearly with the number of additional vessels under each scenario both for Port State 
Control  and  Flag  State  obligations.  Table  4  presents  the  resulting  additional  costs  related  to 
enforcement activities. 

13 

 
 
 
 
Table 4: Additional costs related to enforcement activities for national authorities, based on 2023 cost data 

Type of cost 

Scenarios 

Scenario A.1 

Scenario A.2 

Scenario A.3 

Port State Control cost (EUR per year) 

Flag State obligations cost (EUR per year) 

47,307 

58,866 

51,999 

64,705 

112,221 

139,641 

Total estimated cost for national authorities 
(EUR per year) 

106,173 

116,704 

251,862 

The  costs  for  European  authorities  (European  Commission  and  EMSA)  resulting  from  the 
inclusion of additional smaller vessels (400-4 999 GT) in the MRV scope include one-off costs 
related  to  IT  adjustments  and  developments  in  THETIS-MRV  and  recurring  costs  related  to 
additional human resources, from analysing information, helpdesk support and designing/updating 
information material. Resulting additional costs for each scenario are presented below in Table 5. 

Table 5: Additional costs related to enforcement activities for European competent authorities, based on 2023 cost 
data 

Scenario A.1 

Scenario A.2 

Scenario A.3 

Source: Ricardo analysis 

One-off cost (total cost, EUR) 

Recurring  cost  (cost  per  year, 
EUR) 

100,000 

100,000 

100,000 

40,000 

42,89129 

80,000 

Total regulatory costs were estimated by adding administrative costs for shipping companies and 
enforcement costs for competent authorities, as described above. One-off costs were assumed to 
be spent entirely in the first year of the implementation (assumed at 2025), while recurrent costs 
for shipping companies and competent authorities were assumed to proportionally increase with 
the  number  of  vessels  over  the  period  2025-2050.  These  additional  administrative  costs  are 
expected to be too small to generate any significant market distortion with social implications (e.g. 
on consumers or workers). Total regulatory costs are presented in Table 6 with a 3% discount rate. 

Level playing field 

The extension of the MRV scope to additional smaller vessels would be expected to have a positive 
impact on the level playing field by ensuring similar regulatory requirements for vessels just above 
or  below  the  5  000  GT threshold,  which  might  be  competing  for  similar  market  segments.  An 

29 The value for scenario A.2 is calculated as the proportionate value between scenarios A.1 and A.3., considering the 
provided data. 

14 

 
 
 
 
 
 
 
analysis of vessel data segmented by  size suggests that a large proportion of additional vessels 
under policy scenarios considered would be just below the 5000 GT threshold. Indeed, vessels 
between 4 000 and 4 999 GT would represent 32% of the considered fleet under scenario A.1, 31% 
under A.2, and 19% under A.3. 

4.5 Comparison of scenarios A in terms of social net present value (different smaller 

vessels categories in scope assuming no changes in MRV requirements) 

The social net present value (NPV) across all scenarios considered to expand the scope is negative 
over the period 2025-2050 (Table 6). This is because the present value of additional administrative 
costs for companies  and authorities is  higher than the monetised GHG emission savings solely 
attributable to the MRV maritime Regulation.  

However, this NPV calculation should be interpreted cautiously as it does not take into account 
the  possible  indirect  environmental  benefits  that  would  come  from  the  possible  subsequent 
integration of smaller vessels in other GHG mitigation policies, such as the EU ETS and Fuel EU, 
or any other equivalent measures, following their prior inclusion within MRV scope. It is expected 
that including costs and benefits from the integration of smaller vessels into EU ETS and/or Fuel 
EU, in conjunction with MRV, would be showing a very different picture, most likely a positive 
NPV. 

Table 6: Social Net Present Value (NPV) of scenarios A.1, A.2 and A.3 compared to the baseline (million EUR over 
the period 2025-2050) (3% discount rate) 

Scenario A.1 

Scenario A.2 

Scenario A.3 

GHG emission savings  

Regulatory costs  

Social NPV  

Source: Ricardo analysis 

3.7 

-17.6 

-13.9 

4.1 

-17.6 

-13.5 

7.5 

-41.7 

-34.2 

Note:  GHG  emission  savings  have  been  monetised  using  climate  change  avoidance  cost  included  in  the  2019 
Handbook  of  external  costs  (EUR  100/tCO2e)  corrected  to  2023  price  levels  (EUR  133/tCO2e  by  2030  and  EUR 
358/tCO2e post-2030). 

4.6  Impacts  from  scenario  B2  related  to  changes  in  monitoring  requirements  for 

smaller vessels 

Removing the threshold of 300 voyages per year (scenario B.2) would benefit a large proportion 
of  vessels  undertaking  intra-EU  voyages  only  (32%  of  total  smaller  vessels)30,  significantly 
expanding the scope of the exemption to report on a per journey basis.  

Reporting on an aggregate basis, rather than on a per journey basis, could allow companies under 
this exemption to  use simpler monitoring systems (e.g. bunker notes with  limited stocktaking), 
which would be associated with lower monitoring costs. Thus, while no quantitative analysis was 

30 Vessel categories with the highest share of vessels performing intra-EU voyages only include RoPax and passenger 
vessels. 

15 

 
 
 
 
performed in relation to this scenario B.2, a qualitative analysis shows that it could allow for a 
significant  reduction  in  administrative  costs  compared  to  scenario  B.1.  This  reduction  is  not 
quantified due to lack of quantitative evidence of the difference in costs between monitoring on a 
per voyage and on an aggregate basis. 

5.  Conclusions 

The analysis carried out with regard to GHG emissions from ships below 5 000 gross tonnage but 
not below 400 gross tonnage confirms that the two ship categories that will be included under the 
scope of the EU MRV maritime Regulation as from 2025, are actually the ones with the highest 
emissions within this segment. GHG emissions from smaller vessels in the offshore and general 
cargo categories represent respectively 22% and 18% of all GHG emissions from smaller vessels.  

When putting aside emissions from these two categories, total GHG emissions from the remaining 
smaller vessel categories are estimated at 11.32 MtCO2, i.e. 9% of CO2 emissions covered under 
MRV in 2023. At the same time, those represent 5 309 vessels, i.e. 42% of the number of vessels 
that were subject to MRV obligations in 2023.  

Based  on  a  consultation  with  representatives  of  shipping  companies,  the  analysis  reveals  that 
recurrent annual MRV-related administrative costs per vessel for smaller vessels would be similar 
(or slightly higher) than those of larger vessels currently subject to MRV obligations. As a result 
–  and  because  they  emit  less  GHG  emissions  than  larger  vessels  –  the  trade-off  between 
administrative costs for shipping companies and additional monitored GHG emissions would be 
less favourable for smaller vessels. The ratio between administrative costs and coverage of GHG 
emissions  would  be  on  average  seven  times  higher  for  smaller  vessels,  compared  to  the  larger 
vessels currently subject to MRV obligations. 

The analysis also reveals that extending the scope of the MRV maritime Regulation to additional 
categories of smaller vessels would help unlock the implementation of energy efficiency measures 
and low carbon technologies due to the ability of MRV data to inform decision making process. 
However, the direct environmental benefits are estimated to be rather small, based on conservative 
assumptions. 

In turn, the Social Net Present Value (NPV) is negative for all the considered extension scenarios. 
It  shows that the present value of additional administrative costs for companies and competent 
authorities is  higher than the monetised GHG  emission savings  solely attributable to  the MRV 
maritime Regulation. However, the picture would look different, with much higher environmental 
benefits and most likely a positive NPV, when considering the possible indirect benefits that would 
be associated with GHG emission savings from the possible integration of smaller vessels in other 
GHG mitigation policies, such as the EU ETS and FuelEU, following their prior inclusion within 
MRV scope. 

Related  to  this,  it  is  worth  mentioning  that  equivalent  measures  other  than  integration  within 
FuelEU and/or EU ETS scope might be envisaged – notably if this would enable a reduction of 
the administrative burden. Such measures could be taken at national level, including for instance 
taxation-related  measures  or  ‘opt-ins’  within  the  ‘ETS2’  for  buildings,  road  transport  and 
additional sectors. Some Member States, including Austria, the Netherlands and Sweden, have 

16 

 
 
already decided to include within the scope of ETS2 emissions from some smaller vessels and/or 
inland navigation. 

In any case, the additional benefits that could result from integration of smaller vessels in other 
GHG mitigation policies were not considered in this report, which only deals with the potential 
inclusion of additional smaller ships within the scope of the MRV maritime Regulation and the 
direct impacts of such a change. An assessment including such additional benefits will be carried 
out in the context of the 2026 review of the EU ETS Directive. 

17