What 16,784 Ships Reveal About EU ETS Cost in 2026

The EU MRV register’s 2025 emissions, priced under the 2026 EU ETS rules that ships surrender against in 2027, ship type by ship type. Every figure is reproducible from the public EMSA export and this page’s method.

Published 2026-10-28 · CarbonKeel research

Findings

• Priced under 2026 rules, the 2025 activity of the 16,784 ships we calculate costs €7.62 billion in EU allowances at €85, 49% more than the €5.13 billion due under 2025 rules. Most of the rise is the phase-in (70% to 100%); methane and nitrous oxide add the rest.
• Container ships carry 33% of the 2026-rules cost: €2,486 million across 2,375 ships.
• The cost is concentrated: the costliest 10% of ships carry 51% of it. The median ship owes €195,058 a year.
• 4,145 companies file for these ships.

By ship type

Download the table (CSV)

Method

• Emissions: each ship’s verified 2025 EU ETS scope as published in THETIS-MRV (the verifier’s figure), split by voyage type (between EU/EEA ports and at berth 100%, into or out of the EU/EEA 50%).
• 2025 rules: 70% of the scope, CO₂ only. 2026 rules: 100%, with the ship’s reported methane and nitrous oxide at 28 and 265 times CO₂ (Directive 2003/87/EC as amended by Directive (EU) 2023/959).
• Price: €85 per allowance for every ship, an assumption, not a forecast. Cost scales in proportion to the price.
• Same activity: 2026 rules applied to the ships’ reported year; real 2026 activity will differ.
• Ships: 16,784 of the 17,386 full-year reports: every ship in the EU ETS. Offshore ships enter it with their 2027 emissions and are left out. Types without a CII model (container/ro-ro, other, non-cruise passenger) are priced from the verifier's EU ETS figure, CO₂ only. Ships whose owners asked us not to show derived figures are left out.

Coverage. EMSA THETIS-MRV public export thetis_mrv_2025_v67.xlsx (sheets: 2025 Full ERs, 2025 Partial ERs). We use the 17,386 full-year emission reports, one per ship. The file also holds 1,533 partial-year reports from 1,493 ships that changed company during the year (460 of them have no full-year report), with 5.9 million t of CO₂, 3.6 million t of it in EU ETS scope. They are left out, so totals here are slightly lower than a count of every report (17,846 ships). EU ETS scope is the verifier’s figure as published. Download the export from mrv.emsa.europa.eu to reproduce any figure.

For journalists and analysts

Use the figures with the citation above. For a cut we have not published (one segment, one flag, a different price), write to enquiry@carbonkeel.com. How our figures compare with the verifiers’ is on the validation page.