EU ETS surrender 2027: what ships owe, and by when
For 2026 emissions, a shipping company surrenders allowances for all its ships’ verified EU ETS emissions, methane and nitrous oxide included, by 30 September 2027.
Updated 2026-10-28
What changes for the 2027 surrender
- 100% surrendered, up from 70% for 2025.
- Methane and nitrous oxide count, at 28 and 265 times CO₂. LNG-fuelled ships with methane slip feel it most.
- Voyage rules unchanged: 100% between EU/EEA ports and at berth, 50% into or out of the EU/EEA.
- Offshore ships of 5,000 GT and above report from 2025 and enter the EU ETS for their 2027 emissions.
Every deadline on the way, for 2026
| Date | Rule | What | Basis |
|---|---|---|---|
| 31 Jan 2027 | FuelEU | Submit the 2026 FuelEU report to the verifier | Regulation (EU) 2023/1805, Article 15(3) |
| 31 Mar 2027 | EU MRV | Submit the verified 2026 EU MRV emissions report through THETIS-MRV to the European Commission and the flag State | Regulation (EU) 2015/757, Article 11(1) |
| 31 Mar 2027 | EU MRV | Submit the verified 2026 emissions data at company level to the administering authority: the figure the EU ETS surrender is based on | Regulation (EU) 2015/757, Article 11a |
| 31 Mar 2027 | FuelEU | The verifier records the verified 2026 FuelEU report, GHG intensity and compliance balance in the FuelEU database and tells the company | Regulation (EU) 2023/1805, Article 16(5) |
| 30 Apr 2027 | FuelEU | Record banking, borrowing and any pool for the 2026 compliance balance in the FuelEU database. The pool's verifier records the final pool and each ship's share. After this date a deficit can no longer be pooled | Regulation (EU) 2023/1805, Articles 20(1), 20(3) and 21(8) |
| 30 Apr 2027 | FuelEU | The verifier notifies the company of any 2026 FuelEU penalty (by 30 April, before 1 May) | Regulation (EU) 2023/1805, Article 23(1) |
| 30 Jun 2027 | EU MRV | EU MRV document of compliance for 2026 issued; it is carried on board | Regulation (EU) 2015/757, Article 17 |
| 30 Jun 2027 | EU MRV | The 2026 emissions of every ship are published in THETIS-MRV (the public register CarbonKeel reads) | Regulation (EU) 2015/757, Article 21 |
| 30 Jun 2027 | FuelEU | Pay any 2026 FuelEU penalty to the administering State | Regulation (EU) 2023/1805, Article 23(2) |
| 30 Jun 2027 | FuelEU | FuelEU document of compliance for 2026 issued (by the administering State where a penalty was paid). From this date the ship must hold it when calling at an EU port | Regulation (EU) 2023/1805, Articles 22 and 24 |
| 30 Sep 2027 | EU ETS | Surrender EU allowances for 100% of the verified 2026 EU ETS emissions (CO2, methane and nitrous oxide). Unsurrendered allowances cost €100 per tonne (indexed) and are still owed | Directive 2003/87/EC, Articles 3gb, 12(2a) and 16(3) |
From the compliance calendar (all rules, both years), with the legal basis of each date.
Buying the allowances
Allowances come from EU auctions (several a week) or the secondary market. Spreading purchases from now to September averages the price; the allowance planner works out how many a company needs, ship by ship, and a buying plan month by month. The registry steps (MOHA, two authorised representatives, trusted accounts, 31 March) are in the MOHA guide.
Your own figure
Enter a ship’s fuel in the EU ETS calculator for 2026, or check any ship in the register by name or IMO number in the app.
Questions
When must shipping companies surrender allowances for 2026 emissions?
By 30 September 2027, from the company's maritime operator holding account (MOHA) in the Union Registry.
How much of the 2026 emissions is surrendered?
100%. It was 40% of 2024 emissions and 70% of 2025 emissions.
Do methane and nitrous oxide count in 2027?
Yes. From 2026 emissions they count as CO₂-equivalent: methane at 28 and nitrous oxide at 265 times CO₂.
What is the figure the surrender is based on?
The verified 2026 emissions aggregated at company level, which must be in the registry by 31 March 2027. Without it, transfers out of the MOHA are blocked.
What if the surrender is missed?
At least €100 for every allowance missing, indexed to inflation since 2013, and the allowances are still owed.
EU ETS, FuelEU, CII and UK ETS for each ship, from the public register or your own data.