Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Effective Dates:  N/A

As the reporting cycle for 2025 emissions approaches, it is essential for all operators to prepare for the upcoming verification milestones. To support timely compliance and ensure that PHRS can complete verification activities without delay, please review the key actions and deadlines outlined below.

This update covers requirements under:

• FuelEU Maritime (FuelEU)
• EU Monitoring, Reporting and Verification (EU MRV)
• EU Emissions Trading System (EU ETS)
• IMO Data Collection System (DCS) & Carbon Intensity Indicator (CII)

Key Submission Deadlines

FuelEU

• 31 January 2026 – Submission of the ship-specific FuelEU report to the accredited verifier.
• 31 March 2026 – Completion of verification.
• 30 April 2026 – Verified FuelEU data must be confirmed in THETIS, including any applicable flexibility mechanism records.

Refer to the FuelEU Timetable for a complete overview of compliance milestones, including issuance of the Document of Compliance and payment of any penalties.

EU MRV

• 31 March 2026 – Ship-level and company-level emissions data must be submitted to THETIS and verified.

Note: Some Administering Authorities may request verified data earlier, but not before 28 February 2026.

EU ETS

• 31 March 2026 – Verified company emissions data (as reported in THETIS under EU MRV) must be entered into the Union Registry via the Maritime Operator Holding Account (MOHA) and validated by the Administering Authority.
• If data is not submitted by 1 April 2026, the MOHA will be blocked.

If a company no longer falls within EU ETS scope (e.g., no EU/EEA port calls in the reporting year), it may request that its MOHA be designated as “excluded.”

IMO DCS & CII

• 31 March 2026 – Submission of annual emissions data.
• 31 May 2026 – Verification completed and Statement of Compliance issued on behalf of the Administration.
• 30 June 2026 – Verified data submitted to the IMO GISIS system by the verifier.