MRV – Monitoring, Reporting and Verification (EU and UK)

As of 1 January 2024, the EU MRV regulation covers the following types of greenhouse gas emission:

- Carbon dioxide (CO2)

- Methan (CH4)

- Nitrous oxide (N2O)

The EU MRV regulation applies the berth-to-berth concept for voyages. Hence, a voyage starts at berth of one port of call and ends at berth of the next port of call.

Sailing with a pilot and/or anchoring while waiting for port entrance are part of the voyage. The time spent at sea shall be calculated based on port departure and arrival information and shall exclude anchoring.

For a voyage to be covered by the EU MRV, at least one of the two ports of call of the voyage must be located in an EU territory, i.e. voyages into, within and out of the EU shall be reported.

No, only ports where cargo is loaded or unloaded or where passengers embark or disembark are considered ports of call. Consequently, stops for the sole purpose of refuelling, obtaining supplies, relieving the crew, going into dry dock or making repairs to the ship and/or its equipment, as well as stops in port because the ship is in need of assistance or in distress, stops for ship-to-ship transfers carried out outside ports and stops for the sole purpose of taking shelter from adverse weather or rendered necessary by search and rescue activities are excluded.

The expression “ports under the jurisdiction of a Member State” refers to ports located in “EU territory”, i.e. to which EU law fully applies: ports in the nine EU outermost regions (Açores, Madeira, Canarias, Guadeloupe, French Guyana, Martinique, Mayotte, Saint Martin and Reunion), and also ports in Norway (except those on Svarbald) and Iceland qualify as EU ports.

EEA member states' overseas countries and territories which do not qualify as EU ports of call: Greenland and the Faroe Islands, French Polynesia, New Caledonia, Saint Barthélemy, Saint Pierre and Miquelon, Wallis and Futuna, Aruba, Bonaire, Saba, Sint Eustatius, Curaçao, Sint Maarten, Anguilla, Bermuda, British Antarctic Territory, British Indian Ocean Territory, British Virgin Islands, Cayman Islands, Falkland Islands, Bailiwick of Guernsey, Isle of Man, Jersey, Montserrat, Pitcairn, Henderson, Ducie and Oeno Islands, Saint Helena, Ascension and Tristan da Cunha, South Georgia and the South Sandwich Islands, Turks and Caico Islands, Akrotiri and Dhekelia, Svalbard.

Source: European Commission "Reducing emission from the shipping sector"

All relevant data need to be monitored on a voyage basis and then aggregated annually.

The EU MRV is neither class nor flag related, so this will have no effect on the EU MRV reporting.

No, DNV can also perform the verification for ships not classed with DNV.

The company shall submit a Monitoring Plan to the verifier (DNV) without undue delay and no later than two months after that ship’s first call at a port under the jurisdiction of an EU member state.

The Owner or ISM company is responsible for EU MRV compliance.

From 5 June 2023, revision to MRV regulation requires that upon change of company, Partial MRV Emission Report (ER) is submitted for verification. The verified partial MRV ER should be submitted to the Administering Authority, Flag State authorities of Member State, the European Commission and to the new company as close as practical to the day of change of company and no later than three (3) months thereafter. The verified data covering previous company's responsibility period should form a part of the MRV ER that will be submitted by the company responsible at the end of the reporting year.

However, previous company's emissions for a vessel which has been taken over by a company will not be a part of the aggregated emissions data at company level for the new company. Therefore, company taking over ship will not be liable to surrender allowances for the period when the vessel was not under the previous management or ownership. Nevertheless, current owner/ manager still needs to request the verified aggregated MRV data for previous company's period to fulfill MRV obligations at the end of the year. This data, combined with the log abstract data, will form a full-year MRV ER. 

No, DNV as verifier only verifies submitted data and issues a DoC based on that report. DNV is in no position to confirm that a vessel has not been compliant within the scope of EU MRV during previous years, without verification.

Movements related to the installation of wind turbines offshore or to carriage of supplies to wind turbines will continue to be not subject to the EU MRV until the reporting period 2024. From reporting period 2025, offshore ships of 400+ GT will have to monitor their emissions according to MRV.

From 2027, units of 5000+ GT will have to also surrender allowances for their emissions according to ETS, for units 400-5000GT this is yet to be decided by EU. The definition of "offshore ship" is also pending, but we would expect that wind turbine installation vessels would fall under that definition.

According to 2015/757 EN, Art. 11.3, the emissions report shall state the technical efficiency, i.e. EEDI/EIV.

If missing, this information must be entered in the DNV fleet status portal prior to submitting the emission report, using the input field "Technical efficiency" available on the ER review page. Please enter the ship's EEDI as given on the Energy Efficiency Certificate, or, in case the ship does not have an attained EEDI, the EIV (Estimated Index Value) should be given instead. The EIV should be calculated according to MEPC.231(65). Data should also be available and consistent in THETIS

The EIV for cruise passenger ships with non-conventional propulsion is calculated according to MEPC.233(65), for all other vessels according to MEPC.231(65). EEDI is calculated according to MEPC.308(73).

The requirements regarding the declaration of EIV or EEDI in the ER for a particular vessel are as follows: If an Energy Efficiency Certificate (EEC) has been issued on the vessel, the EEDI is stated on that EEC and shall be stated in the ER. In all other cases the EIV needs to be stated, except for

• Passenger ships
• Cruise ships with conventional propulsion
• Ship category “other” as defined in the MRV regulation
• Ships with non-conventional propulsion other than LNG-carriers or cruise ships

If in doubt, please contact date@dnvgl.com

EU MRV applies to Windfarm installation jack-ups as such, but as long as they are operating in windfarm installation (and not transporting cargo from one port to the next), those activities are currently not within MRV scope. This means the vessel should have an MRV monitoring plan, but do not need to monitor nor report consumption, time and distance when operating in windfarm installation. If they have been working in this way for an entire year, they don’t need to submit an MRV emissions report for that year.

From reporting period 2025 on, this will change: MRV will introduce the ship type "offshore ships" and has already changed the definition of port of call for offshore ships, so that ports where offshore ships relieve the crew will be considered as ports of call and thus be starting and ending points of MRV-relevant voyages. (The definition of "offshore ship" is pending, but we would expect that wind turbine installation vessels will fall under that definition.)

IMO DCS applies to windfarm installation jack-ups. They are no platforms in the sense of MARPOL Annex VI which would be excluded. They must carry a verified SEEMP II on board (and the related confirmation of compliance) and they must monitor and report their consumption, times and distances at all times and report the annual fuel oil consumption reports.

In case of any change to the monitoring plan, the company shall submit an updated plan to DNV for verification.

Monitoring plans can be amended in the MRV Monitoring Plsn online form found on Veracity / Fleet Status / MRV & DCS / Monitoring Plans

The Monitoring plan can be accepted by DNV only if, the plan is provided in an XML format, according to the the European Commisions template, which can be downloaded from Thetis. 

Preamble 22 of the the MRV regulation states that the new company should receive a copy of the latest monitoring plan and document of compliance, if applicable, from the old company. Hence, this is intended by the regulation, but the preamble is not enforceable in itself and this provision is apparently not repeated in the regulation itself.

Thus, the old company is in our opinion not required to hand over the approved monitoring plan to the new company according to the MRV regulation. It goes without saying that the respective sale and purchase contract might contain an obligation to deliver the ship with all necessary certificates (this is standard in all sale and purchase contracts) and therefore also the MRV monitoring plan. A potential buyer would want to check the monitoring plan in its due diligence before buying a ship and would also include this in the contract.

The new company shall submit the new plan without undue delay, but no later than two months.

Generally, emergency generator engines do not need to be regarded an emission source as per the MRV. Only main engines, auxiliary engines, gas turbines, boilers and inert gas generators and incinerators are regarded as emission sources. If the EG engine is, however, used for operational purposes, the EG engine must be regarded as an auxiliary engine and, as such, that engine has to be listed as an emission source in the MP, its consumption be monitored and its emissions be reported in the ER.

DNV recommends the MP is updated using the MRV MP online form in Veracity to obtain a new compliance document and to avoid issues with third parties, e.g. PSC.

The power to be stated in the MP is the figure stated on the IAPP-certificate.

From 1 January 2024, the reporting period for the EU MRV Regulation is defined as from 1 January until 31 December of any given year. For voyages starting and ending in two different years, the respective data should be accounted under the year concerned

DNV requires that all voyages into, within and out of the EU shall be reported for MRV.  For our clients who have MRV and DCS with DNV, reporting of all voyages is required. 

No, the EU MRV regulation defines voyage using departure-from-berth and arrival-at-berth, therefore reporting of those exact events is required for every single voyage. SoSP and EoSP may be reported additionally (if including consumption) but not instead.

Both the log abstract and the bunker reports shall be submitted as .csv files and according to the interface description. The current version of the interface description is available online > OVD Interface description or through the Fleet Service Portal > Vessel Services > MRV & DCS > Manage data > Upload > Operational Vessel Data (OVD) > OVD Interface description.

The frequency of the updates is up to the user’s preference. Since DNV provides you with a quality check of the data as they come in, we recommend taking advantage of this by submitting the data on a frequent basis in order to fix any issues timely.

No, for the verification of the emissions, we require all events including consumption and nothing more.

The current version of the interface description is available at https://developer.veracity.com/docs/section/datastandards/operationalvesseldata > OVD Interface description or through the Fleet Service Portal > Vessel Services > MRV & DCS > Manage data > Upload > Operational Vessel Data (OVD) > OVD Interface description.

Each file can include single event report, as well as multiple reports – this is up to the user’s preferences.

Yes, single file can include events reported for several different vessels. Service providers shall make sure that they include vessels only for one MRV customer (vessel manager) in the same file.

Yes, a second submission of the same events (identified with exactly the same date, time and IMO number) will overwrite those previously submitted.

Please view the guidance video on this topic here.

Deletion of submitted records can be done at DNV Fleet Status > MRV & DCS > Manage data by selecting the vessel and the relevant period for deletion.

Alternatively, deletion of submitted records can be done via submission of another file with the same name (correct records shall be kept, ones to be deleted shall be omitted).

System-to-system connection, allowing fully automated data transfer, can be established anytime, if requested by sending a query to date@dnvgl.com. We will then provide you with a storage container on the Veracity platform.

The storage container is accessible via a unique key (SAS token). In order to access the storage container, Azure Storage Explorer is needed. The automated data transfer can be done programmatically or using the AzCopy. Further information on the upload possibilities can be found at the following website: https://developer.veracity.com/doc/data-fabric-ingest

The reporting of the fuel type should be according to the ISO 8217 grade:

• Grades RME through RMK, Emission factor 3,114: HFO
• Grades RMA through RMD, Emission factor 3,151: LFO
• Grades DMX through DMB, Emission factor 3.206: MGO

If you have two fuel types falling into the same range of grades, those should be combined into one fuel type reported.

The departure event, including the exact cargo, shall be reported when the cargo amount is reliably known.

The port in Korea is the departure port. Since cargo changed there, voyage starts there. The stops in China and Singapore don’t change the cargo so the emissions there count to the voyage. The port in the EU is the relevant arrival port determining the relevant voyage, since cargo will change there. The voyage ends in that EU port. The whole voyage from Korea to the EU is MRV relevant.

This is no voyage, since it terminates in the same port. Thus, this is regarded a port stay. The anchoring time shall therefore not be reported. Furthermore, it is important to note that the departure out to anchorage shall not be reported as departure from berth, as this would indicate the start of a voyage, which it isn't.

Anchoring events do not have to be reported, but the time at anchor elapsed since the last reported event has to be reported. There is no difference between inner and outer anchorage if coming from outside the port area as in this case.

As per the MRV, drifting and anchoring are two different things. Anchoring is to be reported as anchoring, drifting is part of the voyage.

In this scenario, the 30-minute trip is part of the voyage to port 2, which is starting in b. Going back to berth is just a stoppage in a harbour, “waiting at berth” without cargo operations and therefore not a relevant port call and thus not the end of a voyage.

• The event in b shall be reported as a departure from berth.
• The time the ship is waiting at berth will be regarded as time at sea.
• The departure event in c is not a departure from berth, as it is not the start of an MRV voyage.

One has to distinguish between all moorings and anchorings (including terminals which are floating, so not a “solid berth” as such, e.g. buoys, anchoring areas, etc.) within a port and outside a port, with a port being defined by the port limits.

If within port, there will be a UNLOCODE which ought to be used and the start and end events should be reported as arrival at berth and departure from berth.

If outside (e.g. outer Elbe anchorage at German Bight or oil platform in North Sea on Norwegian continental shelf, etc.) then there is no code, and the cargo operation is to be regarded and reported as ship-to-ship transfer, i.e. the end of the transfer operation is to be reported as an STS event (event name “STS”).

In general, any fuel with a different name but the same emission factor as one of the standard fuels, as per the MRV regulation, should be reported under the corresponding standard fuel. With reference to the EU MRV “Guidance/Best practices document on monitoring and reporting of fuel consumption, CO₂ emissions and other relevant parameters pursuant to Regulation 2015/757 on monitoring, reporting and verification emissions from maritime transport”, please note paragraph 5.1.6 advising that the emissions factor to be applied for “hybrid fuels” within RMA to RMD grades is the same as for light fuel oil and the fuel should be reported as LFO. Hybrid fuels with viscosity above the range indicated for the RMA to RMD grades, i.e. from 80 cSt, should be considered RME or higher grade fuel and reported as HFO.

Any at-sea reports are voluntary, but in case of longer voyages which might be difficult to reproduce without noon reports, the reporting of daily reports such as noon reports can reduce the need for potential follow-up requests.

Generally, emergency generator engines do not need to be regarded an emission source as per the MRV. Only main engines, auxiliary engines, gas turbines, boilers and inert gas generators are regarded emission sources. If the EG engine is, however, used for operational purposes, it must be regarded an auxiliary engine and, as such, that engine has to be listed as an emission source in the monitoring plan (MP), its consumption be monitored and the emissions be reported in the ER.

Yes, but this is automatically done anyway when reporting the required events, arrival at berth and departure from berth.

According to the second answer on the EMSA homepage, carriage of supplies and equipment to/from offshore installations and ships is not subject to the MRV.

It goes without saying that, according to the main MRV regulation, cargo transport between ports, however, needs to be reported.

No, it is voluntary, even for ice-classed vessels. We recommend not reporting those figures separately. Those figures shall, however, not be left out but shall be reported together with the non-ice navigation figures.

No, wind force declaration is voluntary.

Cargo change at a rig, FPSO, offshore field, etc. without UN/LOCODE is to be reported as an STS (event name “STS”).

Also, for a voyage on which STS takes place, the From field is the departure port, the To field the arrival port. The rig, FPSO or offshore field where the STS takes place is not a From/To location and shall not be entered in the From/To field.

Cargo fuel shall be included in the cargo field, i.e. as cargo transported, together with any other cargo.

In case you report the ROBs the ‘fuel type style’, please make sure to report 0t, i.e. please don’t just leave the field blank.
In case you report the ROBs the ‘fuel BDN style’, please report the ROB in any event for every fuel reported to be consumed in this event. There is no need to report the ROB at the beginning of the year.

As per the EU regulation 2015/757, only main engines, auxiliary engines, gas turbines, boilers and inert gas generators are regarded emission sources. Based on the above, it is our understanding that as long as the excavator is not powered by the above-mentioned CO₂ emission sources, the excavator FOC does not need to be reported for the EU MRV.

Like reporting positive BDNs when bunkering bunker tanks, negative BDNs shall be reported when de-bunkering tanks, e.g. for use as cleaner.

The Cf for ethane is 2.931, using the same calculation method as for methane according to the MEPC 59/4/10.

The reporting of the fuel type should be according to the ISO 8217 grade, merely viscosity being decisive:

• Grades RME through RMK, Emission factor 3,114: HFO
• Grades RMA through RMD, Emission factor 3,151: LFO
• Grades DMX through DMB, Emission factor 3.206: MGO

The emissions from the combustion of 0.5% VLSFOs, which, depending on the stock of the bunker supplier, may be of residual (HFOs/LFOs) or distillate (MDO/MGO) type, may be monitored as follows:

1. Either use the correct emission factor according to the viscosity and type
2. Or use the highest Cf of the fuels involved, e.g.:
   a. If mixing HFO, LFO and MDO in one tank: use Cf of MDO
   b. If mixing HFO and LFO in one tank: use Cf of LFO

Taking into account that 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, Annex V, Part C, item 13 – states that CO2 emissions in use of biofuels and bioliquids is zero, DNV accepts a CO2 emission factor of zero for biofuels and bioliquids which are certified as sustainable according to EC-recognized voluntary certification schemes. For blends, the CO2 emission factor shall be based on the weighted average of the emission factors for the respective fuels: e.g. 10% biofuel and 90% MGO will have an emission factor of 0.1 x 0 + 0.9 x 3.206 = 2.885. 

For further details on the reporting and verification requirements for biofuels, please contact HelpdeskDATE@dnv.com.

Please be informed that DNV GL's option for vessels with 300+ scheduled voyages per year to report in a way other than per-voyage, has been phased-out. On average, the overall effort-savings were not justifying the continuation of that approach. We hope that this decision finds your agreement and we trust that our MRV verification service, which is optimized for the event reporting approach, will fully meet your needs for any of your vessels.

THETIS-MRV is the EU MRV system to report CO₂ emissions from ships according to the EU regulation 2015/757. THETIS-MRV is accessible via this link.

EMSA provides information about their THETIS-MRV system, including video tutorials, on their website.

No, there is no need to upload the monitoring plan (MP), and the status of the MP doesn’t need to be updated inside THETIS. This is part of the voluntary module in THETIS-MRV. Approval of MPs can be handled complety outside of THETIS and this is what DNV is applying.

Please note: The MPs submitted to DNV will not appear in THETIS and this is not an issue, even if the note in THETIS may appear like that (“Monitoring Plan for x is not created”).

1. Apply for registration as a company user.
2. Enter MRV company details.
3. If necessary, add additional users under the same company account.
4. Define email notification as appropriate.
5. Request a partnership to a verifier.
6. Wait until the verifier accepts the request.
7. Add ships under the scope of the regulation.
8. Update missing mandatory ship particulars.
9. Generate the yearly Emissions Report at the end of the reporting period.

A request for partnership has to be sent to DNV, and DNV has to confirm it for the company to be able to add/register ships under the company’s account in THETIS-MRV.

On the EMSA website a “Register Now” button is available to create an account.

For further information, we recommend visiting the EMSA website, with special attention to the video tutorial C01 covering the registration process.

By 30 April of each year, companies shall submit to the EU Commission and to the flag states the Emissions Report, which has been verified as satisfactory by a verifier. To ensure timely verification, we therefore recommend that companies submit the ERs for verification no later than 31 March.
From 2025, by 31 March of each year, companies shall, for each ship under their responsibility, submit to the administering authority responsible, to the authorities of the flag States concerned for ships flying the flag of a Member State and to the Commission an emissions report for the entire reporting period of the previous year, which has been verified as satisfactory by a verifier in accordance with Article 13. The administering authority responsible may require companies to submit their emissions reports by a date earlier than 31 March, but not earlier than by 28 February.’

DNV verifies ERs but is not involved in the publication of ERs, neither actively nor indirectly, and cannot influence the EC's practice.

Shipowners associations are supporting their members by providing templates for letters of protest against the publication, so companies might want to contact their associations.

These letters can be uploaded as .pdf files as additional information to the Emissions Reports which the company has to upload to THETIS. The upload of the letter as additional information to the ER can only be done by the company in way of the upload of the ER. DNV will not consider the mentioned letter of protest in any way.

According to MEPC.215(63), the Vref should be the service speed as given in the IHSF database. The database can be found at https://maritime.ihs.com/Account2/Index.

http://www.imo.org/en/KnowledgeCentre/IndexofIMOResolutions/Marine-Environment-Protection-Committee-(MEPC)/Documents/MEPC.215(63).pdf 

Please understand that we cannot support companies with guidance on the processes in THETIS. We kindly ask you to familiarize yourself with the video tutorials on the EMSA homepage. Any questions not clarified by the EMSA video tutorials should be sent to EMSA directly.

Customers will be informed about the completion of the ER verification and the availability of the .xml files for download by way of the respective status at Veracity > Fleet Status > MRV & DCS > Verification > MRV ER status.

According to Article 4 of the implementing regulation 2016/1927, the verifiers shall use the electronic version of the template available in THETIS-MRV when issuing the DoC. The electronic template does not require adding any signature other that the name of the verifier. The document available in THETIS should be considered valid by PSC.

The EEDI, or alternatively EIV, is a mandatory figure for the ER (ref. regulation [EU] 2015/757, Article 11, 3 [v]).

The EEDI, if applicable, can be found on the Energy Efficiency Certificate.

If the EEDI is not applicable, the EIV (Estimated Index Value) should be calculated according to MEPC.231(65).

Data should also be available and consistent in THETIS.

Only the MRV document of compliance (DoC) on the annual Emissions Report must be on board. We also recommend that the MRV monitoring plan (MP) and the corresponding statement of compliance (SoC) are kept on board.

The Emissions Report itself and the verification report (issued by verifier or THETIS) do not need to be on board.

In order to change reports submitted to the Commission, the company must formally withdraw them by clicking the button “Revise report” on the top right of the THETIS window.

Then the report can be amended.

After amending, the report needs to be re-verified by the verifier. The verifier assesses the report and verifies it, makes a new Verification Report and issues a new DoC.

Upon receipt of the the ER from the verifier, the company can then re-submit it to the Commission.

This is covered by the functionality in THETIS, hence there is no need for separate information to the flag administration. Flag administrations have access to THETIS and can also choose to receive alerts if considered necessary.

No, the DoC is issued stating the vessel name and flag at the end of the reporting period and does not need to be changed if those change.

The DoC is not a certificate which states continuous compliance, but a document stating compliance at a given time.

Note that the DoC is not issued on behalf of a flag.

DNV recommends that the greatest deadweight the ship is capable of carrying (corresponding to the greatest summer load line draft assigned to the vessel) is used as deadweight where applicable. The presence of multiple load line certificates should be noted as additional information where available.

Please refer to the table linked in the lower right corner of the EMSA website.

No. According to FAQ no. 11 on the EMSA homepage: A ship which has not carried out any EEA-related voyages during a whole reporting period (calendar year X) will not be required by Member States' authorities to have a Document of Compliance on board showing compliance for that specific reporting period (year X), when calling at EEA ports between 30th June of year X+1 and 29th June of year X+2.

We have received the following information from CLIMA-MRV-SHIPPING-HELPDESK@ec.europa.eu:

1. Is an ER required for the part of the year during which is was still operated?
   Answer: Yes, an ER is necessary in case the ship’s activities fell into the scope of the regulation. 
2. Who would have to submit the ER? Typically vessels are handed over to the scrapping yard just before the last voyage into the scrapping facility.
   Answer: The company in charge of the ship before the scrapping yard. 
3. When would the ER have to be submitted? During the year or at the beginning of the next year?
   Answer: As soon as possible but before the applicable deadlines for ERs.