REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the interaction and convergence between the FuelEU Maritime Regulation and the EU MRV Maritime Regulation
Date: 2026-07-28
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: approximation of laws, energy saving, environmental monitoring, greenhouse gas, marine fuel, maritime transport, pollution control measures, pollution from ships, reduction of gas emissions, renewable resources

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 28.7.2026  COM(2026) 409 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the interaction and convergence between the FuelEU Maritime Regulation and the EU MRV Maritime Regulation  
 
 
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND TO THE COUNCIL 

on the interaction and convergence between the FuelEU Maritime Regulation and the EU MRV Maritime Regulation 

I. 

Introduction 

The EU has adopted various legislative acts that drive the decarbonisation of the maritime sector. These acts aim to increase the use of 
low-carbon and sustainable fuels and technologies by ships calling in EU ports. This report primarily focuses on two of these acts: 

1)  Regulation (EU) 2023/18051 of the European Parliament and of the Council of 13 September 2023 on the use of renewable and 
low-carbon fuels in maritime transport and amending Directive 2009/16/EC (‘the FuelEU Maritime Regulation’) entered into force 
on 12 October 2023 and has been fully applicable since 1 January 2025. It requires the gradual reduction of the greenhouse gas 
(GHG)  intensity  of  the  energy  used  on  board  large  ships  and  mandates  the  use  of  on-shore  power  supply  (OPS)  in  selected 
European ports from 2030 onwards. 

2)  Regulation  (EU)  2015/7572  of  the  European  Parliament  and  of  the  Council  of  29 April  2015  on  the  monitoring,  reporting  and 
verification  of  carbon  dioxide  emissions  from  maritime  transport  and  amending  Directive  2009/16/EC  (‘the  MRV  Maritime 
Regulation’)  requires  large  ships  calling  at  European  Economic  Area  (EEA)  ports  to  monitor  and  report  annually  verified 
greenhouse gas (GHG) emissions and other energy efficiency data. The MRV Maritime Regulation was revised in 2023 following 
the extension of the EU Emission Trading System to cover maritime transport emissions. (ETS)3. 

Article 30(1) of the FuelEU Maritime Regulation requires the European Commission to present a report to the Parliament and to the 
Council ‘examining the interaction and convergence’ between that Regulation and the MRV Maritime Regulation. 

The  Commission  has  therefore  performed  a  first  comparative  analysis  of  the  FuelEU  Maritime  Regulation  and  the  MRV  Maritime 
Regulation and the related delegated and implementing acts. The initial experiences gained through the actual implementation of these 
acts have also been considered. 

Given that the MRV Maritime Regulation provides a framework for the monitoring, reporting and verification of data for the maritime 
elements of the EU ETS Directive4, elements of this Directive are also covered by this report where relevant. 

In January 2024, the EU ETS was extended to the maritime sector. Since then, shipping companies have been required to purchase and 
surrender EU ETS emission allowances for each tonne of reported CO2 (or CO2 equivalent) emissions within the scope of the EU ETS 
system. 

During  the  process  of  drafting  the  FuelEU  Maritime  Regulation  and  the  2023  revision  of  the  MRV  Maritime  Regulation,  and  in 
negotiations  with  the  Parliament  and  the  Council,  efforts  were  made  to  align  the  two  acts  to  the  extent  possible  and  to  create  a 
framework  that  provides  for  streamlined  compliance  for  regulated  entities,  verifiers  and  the  administering  authorities  of  Member 
States. 

The  two  Regulations  are  interconnected  because  under  the  FuelEU  Maritime  Regulation  any  data  reported  for  the  purposes  of  the 
MRV Maritime Regulation should be used, when necessary, for verifying compliance with the FuelEU Maritime Regulation in order 
to limit the administrative burden imposed on companies, verifiers and competent authorities. 

However, there are distinct monitoring, reporting and verification aspects in the two Regulations since the drafting of the Commission 
proposals for the FuelEU Maritime Regulation, the revision of the MRV Maritime Regulation and the inclusion of the maritime sector 
in  the  EU  ETS,  and  the  respective  negotiations  with  the  Parliament  and  the  Council,  took  place  separately  albeit  with  partial  time 
overlaps. 

Therefore, further examination and analysis of these acts are merited in order to: 

take stock of differences and discrepancies  between the main provisions of the Regulations, 
assess the challenges that arise from the obligation to comply simultaneously with the two Regulations, and 

- 
- 
-  present possible ways to further align them and improve consistency. 

The findings are intended to provide insights into possible opportunities for streamlining administrative requirements in line with the 
commitments on overall administrative simplification set out stated in the Competitiveness Compass for the EU.  

Scope of the Regulations 

Size thresholds  

Concerning the size of ships that fall withing the scope of the analysed Regulations, the FuelEU Maritime Regulation applies to ships 
above 5000 gross tonnage that serve the purpose of transporting  passengers or cargo  for commercial purposes. Similarly, the MRV 
Maritime Regulation provides that it applies to ships of 5 000 gross tonnage and above and, as of 1 January 2025, to general cargo 

1 Regulation (EU) 2023/1805 of the European Parliament and of the Council of 13 September 2023 on the use of renewable and low-carbon fuels in 
maritime transport, and amending Directive 2009/16/EC, OJ L 234, 22.9.2023, pp. 48-100, ELI: http://data.europa.eu/eli/reg/2023/1805/oj. 
2 Regulation (EU) 2015/757 of the European Parliament and of the Council of 29 April 2015 on the monitoring, reporting and verification of carbon 
dioxide emissions from maritime transport, and amending Directive 2009/16/EC, OJ L 123, 19.5.2015, pp. 55-76, 
ELI: http://data.europa.eu/eli/reg/2015/757/oj. 
3 Regulation (EU) 2023/957 of the European Parliament and of the Council of 10 May 2023 amending Regulation (EU) 2015/757 in order to provide for the 
inclusion of maritime transport activities in the EU Emissions Trading System and for the monitoring, reporting and verification of emissions of 
additional greenhouse gases and emissions from additional ship types, OJ L 130, 16.5.2023, pp. 105-114, ELI: http://data.europa.eu/eli/reg/2023/957/oj. 
4 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, ELI: http://data.europa.eu/eli/dir/2003/87/oj 

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ships below 5 000 gross tonnage but not below 400 gross tonnage and to offshore ships of 400 gross tonnage and above that fall under 
one of the categories listed in Annex I  of the Regulation.5 

Geographical scope 

Reporting  under  the  MRV  Maritime  Regulation  covers  the  fuel  consumption  and  GHG  emissions  of  all  intra-EU  and  extra-EU 
international voyages (voyages between EU and non-EU ports), and those of a ship’s activities within EU ports. The FuelEU Maritime 
Regulation  has  the same reporting scope, but  in  order to  reflect  fairly  the share of  the EU’s emissions, only  half (50%)  of the fuel 
consumption/energy  used  on  extra-EU  international  voyages  is  to  be  accounted  for.  The  same  rule  is  applied  under  the  EU  ETS 
Directive. 

The FuelEU Maritime Regulation treats voyages between the EU and the outermost regions of any EU Member State in the same way 
as international voyages to/from non-EEA countries (hence 50% of the fuel consumption / energy used is considered). Under the MRV 
Maritime Regulation, such voyages are instead treated as intra-EU voyages (hence 100% of emissions fall under the scope). However, 
under  the  EU  ETS  Directive,  shipping  companies  are  not  obliged  to  pay  until  December  2030  for  the  emissions  from  voyages  
between a port located in  an outermost region  of a  Member State and a  port located in  the same Member State, including  voyages 
between ports within an outermost region and voyages between ports in the outermost regions of the same Member State [see section 
on exemptions below]. 

Emissions covered by the Regulations 

Regarding  the  accounting  of  emissions  from  fuels,  the  EU  ETS  Directive  and  the  MRV  Maritime  Regulation  cover  tailpipe  GHG 
emissions, also known as downstream or Tank-to-Wake emissions. This is because upstream emissions (also known as Well-to-Tank) 
linked to  fuel  production are already  covered under other ETS  sectors and counting them as part of the allowances to  the shipping 
sector  could  lead  to  possible  double  issuance,  trading  and  claims. The  FuelEU  Maritime  Regulation  covers  both  Well-to-Tank  and 
Tank-to-Wake emissions to ensure that the full emissions performance of various energy sources is taken into account. 

The  FuelEU  Maritime  Regulation,  the  MRV  Maritime  Regulation  and  the  EU  ETS  Directive  rely  on  the  sustainability  criteria, 
including  minimum  GHG  emissions  thresholds  laid  down  in  the  Renewable  Energy  Directive6,  for  the  conversion  of  renewable 
feedstocks into fuels, including the relevant certification system. The FuelEU Maritime Regulation further limits the eligible fuel pool 
by excluding feedstocks from food and feed crops. Fuels produced from those feedstocks are treated as fossil fuels under the FuelEU 
Maritime Regulation. 

Energy sources 

Ships’  intake  of  certain  energy  sources  other  than  fuel  –  such  as  electricity  from  onshore  power  and  wind  power,  which  cannot  be 
monitored during voyages, but which contribute to a ship’s energy use and therefore its decarbonisation objectives – is covered under 
the  FuelEU  Maritime  Regulation  but  not  under  the  MRV  Maritime  Regulation.  For  electricity  from  onshore  power  and  for  wind 
power, extra monitoring or calculations are therefore required for the FuelEU Maritime Regulation. 

Exemptions 

Regarding  the scope, there are  differences between  the exemptions  permitted by the FuelEU Maritime Regulation  and the  EU ETS 
Directive.  

Both the FuelEU Maritime Regulation and the EU ETS Directive permit Member States to exempt voyages performed by passenger 
ships    to  islands  with  fewer  than  200 000  permanent  residents.  However,  differences  exist.  For  ETS,  the  exemptions  can  apply  to 
voyages  between a port of an island under the jurisdiction of the requesting Member State  with no road or rail link with the mainland 
and  fewer than 200 000 permanent residents, and a port under the jurisdiction of that same Member State.  For the FuelEU Maritime 
Regulation, the exemptions can apply to voyages performed by passenger ships other than cruise passenger ships between a port of 
call under the jurisdiction of a Member State and a port of call under the jurisdiction of the same Member State located on an island 
with fewer than 200 000 permanent residents. These exemptions also apply to the activities within port by relevant ships occurred in 
relation to the exempted voyages.   

Under  both  the  FuelEU  Maritime  Regulation  and  the  EU  ETS  Directive,  Member  States  may  exempt  passenger  ships,  and  ro-pax 
ships  in  the  case  of  the  EU  ETS  Directive,  performing  transnational  voyages  under  public  service  obligations  or  public  service 
contracts for certain voyages. 

Member  States  may  also  exempt  from  the  application  of  the  FuelEU  Maritime  Regulation  passenger  ships  providing  maritime 
transport services under public service obligations or public service contracts for routes between their mainland ports and ports located 
on an island or the cities of Ceuta and Melilla. The EU ETS Directive does not provide for such exemptions. 

Finally,  under  the  FuelEU  Maritime  Regulation  Member  States  may  create  exemptions  for  voyages  undertaken  between  ports  in 
outermost regions. Under the EU ETS Directive, there is a an automatic (i.e. without need for notification) temporary derogation until 
the end of 2030 for voyages between a port located in an outermost region of a Member State and a port located in the same Member 
State, including ports located in the same outermost region and in another outermost region of the same Member State. 

For  all  the  above-mentioned  exemptions,  the  FuelEU  Maritime  Regulation  and  the  EU  ETS  Directive  use  different  end  dates. The 
former permits exemptions that can run until 31 December 2029, while the latter allows them to run until 31 December 2030. 

Provisions on ice class and navigation through ice 

The FuelEU Maritime Regulation, the MRV Maritime Regulation and the EU ETS Directive all contain provisions concerning the ice 
class of the ship and navigation through ice albeit in a different format. To mitigate the additional costs for ice-class ships, the FuelEU 

5 Commission Delegated Regulation (EU) 2024/3214 of 16 October 2024 amending Regulation (EU) 2015/757 of the European Parliament and of the 
Council as regards the rules for the monitoring of greenhouse gas emissions from offshore ships and the zero-rating of sustainable fuels 
OJ L, 2024/3214, 27.12.2024, ELI: http://data.europa.eu/eli/reg_del/2024/3214/oj. 
6 Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy from renewable 
sources, OJ L 328, 21.12.2018, pp. 82-209, ELI: http://data.europa.eu/eli/dir/2018/2001/oj. 

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Maritime Regulation allows companies to apply for the additional energy used due to the ship’s ice class and that used due to sailing in 
ice conditions to be excluded from the calculation of the compliance balance. Under the EU ETS Directive, shipping companies may 
surrender 5 per cent fewer allowances than the total verified emissions released from their ice-class ships until 31 December 2030. 

Neighbouring container transhipment ports 

In order to reduce the risks of evasive port of calls and the relocation of transhipment activities, both the FuelEU Maritime Regulation 
and the EU ETS  Directive require the Commission to  identify and update  the list  of “neighbouring  container transhipment  ports”.  
Stops at these ports are excluded from the definition of “port of call” for MRV purposes. The criteria for identifying these ports in the 
FuelEU Maritime Regulation and the EU ETS Directive are identical. However, the timelines for updating the  lists are not aligned. 
Therefore, the differences in data could result in differences in the lists applied.  

Conclusions: 

-  Most differences in the scope of the Regulations are justified by the choices made by the Parliament and the Council. Any 

adjustments of the scope, such as ship-type, should be further examined, in light of the benefits of further consistency between the 
rules described above. 

-  The possibility of increasing convergence in respect of eligibility, the determination of emissions and GHG intensity of fuels used 

on board under the rules described above could be examined. 

-  For ease of implementation, further alignment of the provisions on the exemptions applicable under the FuelEU Maritime 

Regulation and the EU ETS Directive could be examined. However, this should consider that these differences are specific choices 
made by the co-legislators.   

-  The timelines for revision of the list of neighbouring container transhipment ports could be harmonised to simplify 

implementation. 

II. 

Responsible entities 

The FuelEU Maritime Regulation, the EU ETS Directive and the MRV  Maritime Regulation define the bodies responsible for their 
implementation. These definitions are similar but not identical, which could result in a situation where a shipping company decides to 
have a different responsible entity for the EU ETS and MRV Maritime Regulations compared to the FuelEU Maritime Regulation. 

The responsible entity under the FuelEU Maritime Regulation must always be the ISM company, the legal entity managing the ship in 
compliance with the International Safety Management (ISM) Code. Depending on contractual and operational arrangements, the ISM 
company should be either the shipowner, or any  organisation or person other than the shipowner, which has agreed to take over all the 
duties and responsibilities imposed by the ISM code. Where a shipowner is responsible for the compliance of its ship with the ISM 
Code, the shipowner is both  the ISM company and the entity  responsible for compliance with  the FuelEU Maritime Regulation.  In 
cases where the shipowner has delegated the responsibilities to comply with the ISM Code to any other organisation or person (which 
has agreed to take on such responsibilities), that organisation or person will become the ISM company as well as the entity responsible 
for compliance with the FuelEU Maritime Regulation. 

Under  the  MRV  Maritime  Regulation,  the  same  entity  must  be  responsible  for  both  the  EU  ETS  Directive  and  the  MRV  Maritime 
Regulation. Under the EU ETS Directive and the MRV Maritime Regulation, the entity responsible for compliance in respect of the 
emissions of a given ship can be either the shipowner (i.e. the registered owner) or the ISM Company. If the ISM Company is distinct 
from the shipowner, the registered owner and the ISM Company must agree contractually between them on the entity that will take on 
responsibility  for  complying  with  the  EU  ETS  Directive  and  MRV  Maritime  Regulation  obligations.  In  the  absence  of  an  express 
decision by the registered owner and the ISM Company, the registered owner will be considered to be responsible for compliance with 
the obligations set out in the EU ETS Directive and the MRV Maritime Regulation. 

Responsible authorities 

The ‘administering State’ in respect of a company that is responsible for the enforcement of the FuelEU as defined under the FuelEU 
Maritime Regulation is determined using the same rules as those applied to determine the ‘administering authority responsible’ for the 
EU ETS Directive in respect of a shipping company. However, given the possibility that in certain situations the company responsible 
for a ship may not be the same for the FuelEU Maritime Regulation on the one hand, and the MRV Maritime Regulation and EU ETS 
Directive on the other (see above), it is possible that the same ship is administered by two different Member States, one for the FuelEU 
Maritime Regulation and another for the EU ETS Directive and the MRV Maritime Regulation. 

Within one Member State, different authorities may be appointed to be responsible for administering the FuelEU Maritime Regulation 
on the one hand and the MRV Maritime Regulation and the EU ETS Directive on the other hand, but it is up to the Member State to 
decide if it would be best to grant the same authority that responsibility. 

Conclusions 

-  Further  examination  of  the  responsible  entities  under  the  FuelEU  Maritime  Regulation,  the  EU  ETS  Directive  and  the  MRV 
Maritime Regulation should be carried out to determine if  an aligned interpretation and definition of the regulated entity  would 
bring further simplification and for whom. In that context, it should be taken into consideration that the EU ETS Directive looks at 
compliance at company level and the FuelEU Maritime Regulation provides for obligations in relation to ships.  

III.  Monitoring, recording and reporting 

Monitoring plans 

Under both the FuelEU Maritime Regulation and the MRV Maritime Regulation, companies must submit to the verifier a monitoring 
plan for each of their ships indicating the information needed to meet the reporting requirements. Due to the differing requirements, 
operators  need  to  submit  two  separate  monitoring  plans,  one  in  accordance  with  the  MRV  Maritime  Regulation  and  the  other  in 
accordance with the FuelEU Maritime Regulation. The two plans have a similar structure and can be produced in the THETIS MRV IT 
system. After the two monitoring plans are submitted they follow independent workflow processes. 

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In practice, THETIS MRV  acts  as a one-stop-shop for shipping  companies, allowing for complementary submission  of data for the 
purposes  of both the MRV  Maritime Regulation  / EU ETS Directive and  the FuelEU Maritime Regulation. All  data monitored and 
recorded under the MRV Maritime Regulation will be used for the FuelEU Maritime Regulation calculations, subject to confirmation 
by the FuelEU verifier, if different from the MRV verifier. The same MRV Maritime data can also be used to aggregate data relevant 
for the company-level reports under the EU ETS Directive. 

Reporting on a per-voyage basis 

Under both the FuelEU Maritime Regulation and the MRV Maritime Regulation data are in principle monitored per voyage. However, 
under  the  MRV  Maritime  Regulation  it  is  not  mandatory  to  report  on  a  per-voyage  basis,  meaning  that  companies  can  report  on  a 
yearly  aggregated  basis  the  required  data.  In  practice,  however,  THETIS  MRV  enables  data  to  be  recorded  and  reported  on  a  per-
voyage basis as a voluntary option under the MRV Maritime Regulation. 

Derogations from monitoring per voyage 

By  way  of  derogation,  the  MRV  Maritime  Regulation  allows  companies  to  monitor  the  fuel  consumption  and  GHG  emissions  for 
certain ships on an annual basis only. The derogation applies to ships that only perform intra-EU voyages and undertake more than 
300 voyages each year. Such derogations do not exist under the FuelEU Maritime Regulation. 

Allocation of fuel/energy use by geographical scope 

The  FuelEU  Maritime  Regulation  allows  for  the  free  allocation/redistribution  of  fuel  used  during  the  entire  reporting  period  to  the 
intra-EU or extra-EU part of the distance travelled, irrespective of whether the fuel/energy was actually used on that specific voyage. 
The  MRV  Maritime  Regulation  and  the  EU  ETS  Directive  require  the  reporting  of  the  relevant  fuel  type  to  the  exact  voyage  type 
during which the fuel was consumed. This has an impact on the allocation of the lowest GHG intensity fuels (and zero-rating for the 
EU ETS Directive). 

Conclusions: 

- 

IT solutions applied in THETIS MRV reduce the burden of submitting two separate monitoring plans. However, the feasibility of 
merging of the two monitoring plans could be examined, along with whether such a move could further simplify reporting. 

-  There are differences in terms of reporting requirements on energy used within ports and during voyages. In addition, unlike the 
MRV Maritime Regulation, the FuelEU Maritime Regulation does not include derogations to allow certain ships to monitor their 
fuel  consumption  and  emissions  annually,  instead  of  monitoring  each  single  voyage.  The  possibility  of  further  aligning  these 
elements could be examined. 

IV.  Verification 

The verification system applicable under the FuelEU Maritime Regulation is largely based on the system established under the MRV 
Maritime Regulation, but there are some differences, which are analysed below. 

General obligations and principles for the verifiers and verification procedures 

The  obligations  and  principles  for  the  verifiers  and  verification  procedures  –  as  specified  in  the  implementing  and  delegated  acts 
adopted under the FuelEU Maritime Regulation and the MRV Maritime Regulation – are largely aligned7. One difference is that, in 
contrast to the MRV Maritime Regulation, under the FuelEU Maritime Regulation if the verifier changes, the monitoring plans are to 
be reassessed by the new verifier. 

Accreditation 

Specifications  concerning  rules  for  the  accreditation  of  verifiers  under  the  MRV  Maritime  Regulation  and  FuelEU  Maritime 
Regulation are set out in delegated acts8. The provisions of these acts are identical or largely similar. 

Conclusions 

-  The rules for verification, and the accreditation of verifiers, are laid down  in both regulations in the FuelEU Maritime Regulation 
and in the MRV Maritime Regulation and further specified in separate delegated and implementing acts. Differences in the rules 
are minimal and mostly stem from the different workflows and roles of the verifiers under the different acts. 

V. 

Enforcement 

Expulsion order/detention 

Under both the FuelEU Maritime Regulation and the MRV Maritime Regulation, if a ship fails to comply with its obligations for two 
or more consecutive reporting periods, Member States can issue an expulsion order. However, the flag State may not refuse entry into 
port to ships flying its flag. 

Obligation to hold a valid document of compliance (DoC) 

Under the FuelEU Maritime Regulation, ships that have not carried out any voyages within its scope during a reporting period are still 
required  to  carry  a  valid  DoC  (a  document  specific  to  a  ship,  issued to  a  company  by  a  verifier,  which  confirms  that  that  ship  has 

7 Commission Implementing Regulation (EU) 2024/2027 of 26 July 2024 on verification activities pursuant to 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, 
2024/2027, 29.7.2024, ELI: http://data.europa.eu/eli/reg_impl/2024/2027/oj and Commission Delegated Regulation (EU) 2023/2917 of 20 October 2023 on the 
verification activities, accreditation of verifiers and approval of monitoring plans by administering authorities pursuant to Regulation (EU) 2015/757 of the 
European Parliament and of the Council on the monitoring, reporting and verification of greenhouse gas emissions from maritime transport, and repealing 
Commission Delegated Regulation (EU) 2016/2072, OJ L, 2023/2917, 29.12.2023, ELI: http://data.europa.eu/eli/reg_del/2023/2917/oj. 
8 Commission Delegated Regulation (EU) 2025/192 of 9 September 2024 on procedures for the accreditation of verifiers pursuant to 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 of the European Parliament and of the Council, OJ L, 2025/192, 29.1.2025, ELI: http://data.europa.eu/eli/reg_del/2025/192/oj and Commission 
Delegated Regulation (EU) 2023/2917 as referenced above. 

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complied  with  the  FuelEU  Maritime  Regulation  for  a  specific  reporting  period)  on  board  during  the  verification  period. The  MRV 
Maritime Regulation establishes an obligation to carry on board a valid DoC only for ships having carried out voyages under its scope 
during  the  reporting  period.  In  the  case  of  inactive  ships  (i.e.  no  activity  under  the  scope  of  the  MRV  Maritime  Regulation),  that 
Regulation does not prohibit the submission of a verified emissions report with zero emissions in order to obtain a valid DoC. 

Flag State obligation 

The  MRV  Maritime  Regulation  states  that  each  Member  State  is  to  take  all  the  measures  necessary  to  ensure  compliance  with  the 
monitoring and reporting requirements by ships flying its flag. By contrast, under the FuelEU Maritime Regulation, Members States 
are not obliged to carry out checks on ships flying their flags. 

Issuance of FuelEU document of compliance 

Under  the  FuelEU  Maritime  Regulation  and  the MRV  Maritime  Regulation,  the  verifier  is,  in  principle,  responsible  for  issuing  the 
DoC. However, under the FuelEU Maritime Regulation, if a FuelEU penalty is due, the document needs to be issued by the competent 
authority  of  the  administering  State.  Furthermore,  under  FuelEU  it  is  possible  for  the  competent  authority  to  withdraw  previously 
issued documents of compliance where misstatements or non-conformities in reported data are detected, which is not the case under 
the MRV Maritime Regulation.   

Inspections 

Both the FuelEU Maritime Regulation and the MRV Maritime Regulation require port State control authorities to include DoC checks 
as part of their inspections (as performed in accordance with Directive 2009/16/EC)9. 

Sanctions 

Under both the FuelEU Maritime Regulation and the MRV Maritime Regulation, Member States must lay down a separate set of rules 
on sanctions applicable to infringements of the Regulations. 

Conclusions 

-  The rules of enforcement under both the FuelEU Maritime Regulation and the MRV Maritime Regulation are centred on the ship 
and contain many identical or similar provisions, but there are differences. The setting up of a joint enforcement regime could be 
examined to streamline certain activities and reduce the burden on the Member State’s authorities. 

VI. 

Timing of compliance obligations 

A comparison of the compliance obligations in the MRV Maritime Regulation and the FuelEU Maritime Regulation shows that the 
two regulations are consistent as regards timing. 

If  there  is  a  decision  in  future  to  work  with  one comprehensive  monitoring  plan  for  the  two  Regulations,  timing  would  have  to  be 
aligned on certain points. For example, currently, ships that call at a Member State port for the first time after 31 August 2024 must 
submit a monitoring plan no later than two months after their first port of call under the FuelEU Maritime Regulation, but no later than 
three months after each ship’s first call at a Member State port under the MRV Maritime Regulation. 

By  31 January  of  the  verification  period,  the  FuelEU  report  is  to  be  submitted  to  the  verifier  and  by  31 March  of  the  verification 
period the verifier is under an obligation to record the verified FuelEU report in the FuelEU database. By contrast, the MRV Maritime 
Regulation  states  that,  depending  on  the  rules  of  the  responsible  administering  authority,  the  verified  emissions  report  must  be 
submitted  to  the  relevant  authorities  in  the  period  between  28  February  and  31  March  of  the  verification  period.  It  is  for  each 
administering authority to decide on the exact date they submit the report within that period. 

Conclusions 

-  The timelines and procedures that need to be followed for meeting the requirements of the two regulations have a similar structure, 
but  there  are  differences  in  the  dates  and  the  formulation  of  obligations. A  further  alignment  of  the  monitoring  and  reporting 
process could be considered. 

VII.  Overall conclusions 

The comparison shows that, while the  FuelEU  Maritime Regulation,  the MRV Maritime Regulation and the  EU  ETS  Directive  are 
already well aligned on many aspects, there is room for reducing existing discrepancies through the forthcoming revisions of the acts, 
with the aim of simplifying implementation and reducing administrative burden for operators, verifiers and Member States. 

The greatest benefits would come through the establishment of a single monitoring, reporting and verification system that would serve 
both the FuelEU Maritime Regulation and the EU ETS Directive and ensure that companies can use the data collected, verified, and 
reported under the MRV Maritime Regulation for compliance with the EU ETS Directive and the FuelEU Maritime Regulation. 

Such a system based on the MRV Maritime Regulation should i) cover all monitoring requirements under the EU ETS Directive and 
the  FuelEU  Maritime  Regulation,  ii)  minimise  discrepancies  and  misalignments  between  the  requirements,  iii)  align  and  possibly 
merge  the  reporting  documents  into  one  unique  template  (i.e.  monitoring  plans,  emissions  reports),  iv)  establish  one  unique 
verification  and  accreditation  framework,  and  v)  align  the  concept  of  regulated  entity  under  the  MRV  Maritime  Regulation,  the 
FuelEU Maritime Regulation and the EU ETS Directive. 

Going beyond the monitoring, reporting and verification system, further convergence could in future also be considered between the 
FuelEU  Maritime  Regulation  and  the  EU  ETS  Directive  in  other  areas  such  as  geographical  exemptions,  ship  types,  energy  and 
emission coverage, ice navigation and enforcement measures. However,  achieving greater consistency of these provisions would be 

9 Directive 2009/16/EC of the European Parliament and of the Council of 23 April 2009 on port State control, OJ L 131, 28.5.2009, pp. 57-100, 
ELI: http://data.europa.eu/eli/dir/2009/16/oj. 

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more challenging than aligning the monitoring, reporting and verification systems; moreover, there are legitimate grounds for keeping 
existing differences, which were based on specific choices of the co-legislators.   

All amendments to the above-mentioned issues should be coordinated and take into account the impact of changes across the three 
pieces of legislation. At the same time, any revision should examine the feasibility and economic, environmental and social impacts of 
further convergence, in view of the aim of preserving the environmental integrity and effectiveness of Union climate action, including 
its legally binding commitments. 

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