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EU ETS Maritime: Obligations and Options for Action for Maritime Transport (Part 2)

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In the first part of this series on emissions trading in the maritime sector, we outlined the principles of the obligations. In this second part, we explain market developments in the EU ETS and the complementary FuelEU Maritime Regulation on reducing greenhouse gases in fuels.

Market and price developments for emission allowances

The European Energy Exchange (EEX) based in Leipzig and the ICE based in London act as central marketplaces for the procurement and trading of emission allowances in the EU ETS (EUAs). The EEX handles both primary and secondary market transactions, while the ICE serves the secondary market. In the primary market, all new EUAs are issued through standardised auctions, while in the secondary market there are spot and futures contracts for EU ETS obligations, intermediaries, traders and financial investors. The average EUA price in 2024 was around EUR 67/tCO2 (source: DEHSt). Analysts forecast an increase to up to EUR 200/t in the coming years (Figure 1). Price dynamics are determined by five structural drivers:

  • Stricter cap reduction: The linear reduction factor of 4.3% (2024–2027) and 4.4% (from 2028) will lead to a constant annual reduction of around 88 million EUAs from 2024 onwards
  • The gradual inclusion of shipping will bring up to 78.4 million additional EUAs into the system
  • Market Stability Reserve (MSR): If a threshold for surplus EUAs is exceeded, the MSR will withdraw and delete part of the surplus
  • REPowerEU auctions: The programme will weigh on price developments in the short term due to additional auction volumes of around 267 million EUAs between 2023 and 2026, but will lead to a correspondingly sharper supply reductions from 2027 onwards
  • Geopolitical factors: The war in Ukraine and energy price volatility are influencing EUA prices via temporarily very high correlations between gas and EUA prices, while the adoption of the ‘Fit for 55’ package has strengthened market confidence in long-term price increases

Historische Preisentwicklung und Prognosen für EU-Emissionszertifikate (EUAs) bis 2030 (Grafik carboneer)

Figure 1: Historical price development and price scenarios for EUAs until 2030 (source: carboneer, data source: EEX)

Impact of emissions pricing and possible hedging

In 2024, the financial impact of the EU ETS on shipping was still limited, despite administrative burdens. As only 40% of emissions were covered by the EU ETS, the average price per tonne of CO2 actually emitted by ships was just over EUR 25. For a ship fuelled with bunker oil, the costs for intra-Community voyages (100% coverage) increased by around 15% for entries into or exits from the EU/EEA area (50% coverage) by 7.5% (assumptions for bunker oil, price: EUR 500/t and emission intensity: 3.1 tCO2/t) Thus, the additional EU ETS costs probably did not have a major impact on the route choices made by shipping companies. Detours via Africa to avoid the Suez Canal or increased tensions in the Strait of Hormuz leading to higher insurance costs probably posed a greater economic challenge for many companies.

In 2025, the emissions covered by the EU ETS will rise to 70%. With bunker oil prices remaining constant and an assumed EUA price of EUR 70/t, CO₂ costs will double. Similarly, the coverage of all emissions from 2026 onwards will be accompanied by a further significant increase in the financial burden. Systematically hedging these price risks by purchasing emission allowances via spot or futures market contracts can both reduce price risk and secure future EUA requirements for shipping companies. The optimal strategy depends on the individual risk profile, emission volatility and available financing resources. In view of the forecast price increases for EUAs, tailor-made procurement and hedging approaches are becoming increasingly important for affected shipping companies.

With the expansion of the EU ETS to maritime shipping, charter agreements along the entire charter party chain must be redesigned. The decisive factor is who assumes operational responsibility for cargo, route or speed (often the charterer), as only this party can be held liable by the shipping company for the costs of emission allowances. Charter contracts should therefore clearly stipulate who is liable for emission costs during the various phases of the voyage and how any deviations are to be settled.

FuelEU Maritime: Complementary rules for fuels

On 1 January 2025, the FuelEU Maritime Regulation (EU) 2023/1805 came into force (source: EU) and supplements the EU ETS for ships over 5,000 gross tonnage. While the EU ETS prices absolute CO₂ quantities via a cap-and-trade system, FuelEU Maritime aims to gradually reduce the greenhouse gas intensity of on-board energy, in particular fuels. The binding reduction targets are 2% by 2025, 6% by 2030, 14.5% by 2035 and 80% by 2050. FuelEU Maritime uses a well-to-wake approach that evaluates emissions from raw material extraction to combustion on board. Alternative fuels such as biofuels or e-fuels are accounted for in a comparable manner using standardised emission factors. If a ship falls short of its annual intensity target, penalties of 2,400 EUR per tonne of VLSFO equivalent deficit will be imposed. Bunker oil or Very Low Sulphur Fuel Oil (VLSFO) serves as the basis for calculation due to its market dominance. From 1 January 2030, container and passenger ships in TEN-T (Trans-European Transport Network) ports must use shore power during layovers, with violations costing 1.50 EUR per unused kWh.

Both systems complement each other: the EU ETS limits and prices emissions, while FuelEU creates incentives for lower-emission fuels. In a further article, we will take a detailed look at the fundamentals and implications of FuelEU Maritime.

Conclusion and recommendations for action

Inclusion in the EU ETS presents shipping companies with complex challenges in the areas of emissions measurement, procurement of emission allowances and cost pass-through. The gradual introduction and supplementation with FuelEU Maritime is intended to effectively reduce emissions in maritime transport.

Risks due to administrative burdens, penalties or volatile prices in the EU ETS can be minimised through proactive and strategic planning and actions. A possible guide for action for shipping companies subject to the scheme is shown in Figure 2.

Action guide for shipping companies under EU ETS and FuelEU Maritime, outlining compliance steps, risk management and strategic options.

Figure 2: Action guide for shipping companies in the EU ETS and FuelEU Maritime (source: carboneer)

Contact carboneer for personalised advice and we will assist you with implementation and risk analysis.

Sources

DEHSt, 2025, VET-Bericht 2024, URL: https://www.dehst.de/SharedDocs/downloads/DE/publikationen/VET-Bericht-2024.pdf?__blob=publicationFile&v=7

EEX, 2025, EU ETS Auctions, URL: https://www.eex.com/en/market-data/market-data-hub/environmentals/eu-ets-auctions

EU, 2023, FuelEU Maritime Regulation, URL: https://eur-lex.europa.eu/eli/reg/2023/1805/oj/eng

EU ETS Maritime: Obligations and options for action for maritime transport (Part 1)

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Since 2005, the EU Emissions Trading System (EU ETS) has been the European Union’s (EU) central market-based climate instrument. Since 2018, the maritime transport sector has been required to measure, report and verify emissions in accordance with EU ETS rules (monitoring, reporting, verification – MRV), and emissions pricing began on 1 January 2024. In this first part of a series on the EU ETS for maritime transport, the basics of the obligations for affected companies are explained.

This extension of the EU ETS to maritime transport was part of the ‘Fit for 55’ package and covers all ships with a gross tonnage (GT) of 5,000 or more that call at ports in the EU or the European Economic Area (EEA), regardless of their flag. Shipping companies were therefore assigned to national administrative authorities on 30 January 2024 (source: EU). This assignment list is not exhaustive, as companies may still be subject to regulation after the deadline and are obliged to comply despite not being listed. The shipping sector already contributed around 6% of EU ETS emissions in its introductory year 2024 (source: EEA) and caused around 13% of all transport-related greenhouse gases in the EU in 2021 (source: EMSA).

The first evaluation of the integration of shipping into the EU ETS by the EU Commission in March 2025 shows that over 5,000 shipping companies are registered on the European MRV platform THETIS-MRV and that verified monitoring plans for more than 15,000 ships are available (source: EU Commission). Figure 1 illustrates the geographical scope of the EU ETS for maritime transport: 100% of emissions for intra-EU/EEA voyages are covered, while 50% of emissions are subject to taxation for voyages to/from third countries. This regulation aims to prevent carbon leakage and minimise avoidance behaviour.

 

 

Scope of EU ETS Maritime

Figure 1: Example illustration of the scope of the EU ETS maritime with the 100/50% rule (source: carboneer)

Gradual inclusion of shipping

The EU ETS operates on a cap-and-trade principle with an annually decreasing emissions cap. Shipping companies must purchase corresponding emission allowances (European Union Allowances (EUA)) for each tonne of CO₂ equivalent emitted and surrender them in the Union Registry each year. Companies with low CO₂ abatement costs can sell their EUAs to companies with high abatement costs. This means that CO₂ is avoided where it is most efficient and cost-effective.

The inclusion of shipping in the EU ETS is taking place in stages. While only CO₂ emissions are subject to pricing for the time being, methane and nitrous oxide will also be priced from 2026. From 2027, the system will also cover offshore vessels with a GT of over 5000. While smaller ships between 400 and 5,000 GT have been part of the MRV since 2025, it is still unclear whether and when the emissions of these ships will also be priced. This is expected to be decided in 2026 as part of a major EU ETS review.

In addition to the gradual introduction of several ship and emissions categories, pricing will also be phased in over a three-year period. From 2024, affected shipping companies will have to surrender EUAs for 40% of their verified emissions, 70% in 2025 and 100% from 2026 (Figure 2).

EU ETS maritime implementation period

Figure 1: EU ETS maritime implementation period (source: carboneer according to EU Commission)

Responsibilities and ISM delegation

The obligated ‘shipping company’ within the meaning of the EU ETS Directive is, by default, the registered shipowner. The shipowner may contractually delegate the EU ETS obligations to the company that is responsible for ship operations under the International Safety Management (ISM) Code. A prerequisite for delegation is that a proper and complete mandate agreement in accordance with the detailed requirements of Implementing Regulation (EU) 2023/2599 has been submitted to the competent authority (source: DEHSt). The mandate agreement must document the assumption of all EU ETS obligations and be submitted to both the administrative authority and the verification body. Bareboat charters can only act as shipping companies if they are also ISM companies. The company responsible for MRV of emissions and the obligations under the EU ETS must always be identical. In practice, this requirement poses considerable challenges, as many shipping companies operate their fleets through multiple ISM managers who use different management and emission measurement procedures.

Annual obligations

The annual compliance cycle of the EU ETS for shipowners and ISM companies follows a clearly structured annual rhythm that begins even before the first port call. Before operations commence, an approved monitoring plan must be in place, which is reviewed by an accredited verifier and approved by the competent administrative authority (source: EU Commission). The verified plan must be submitted to the competent administrative authority via the THETIS MRV portal by 1 April 2024 at the latest or within three months of the first port call under EU jurisdiction. Throughout the reporting year, ships continuously record their greenhouse gas emissions using the methods defined in the monitoring plan.

By 31 March of the following year at the latest (Figure 3), this data must be verified and include both a ship-level emissions report and a company-level emissions report, which are generated via the THETIS-MRV portal.

Compliance cycle in the EU ETS (source: carboneer)

Figure 3: Compliance cycle in the EU ETS (source: carboneer)

 

A Document of Compliance can then be created via THETIS-MRV, which must be carried on all affected ships of the relevant company. In order to have sufficient buffer for any corrections, verification should begin promptly after the start of the year. Once the shipping company has assigned the verifier to the Union Registry, the verifier can confirm the verified emissions directly in the Maritime Operator Holding Account (MOHA) in the Union Registry.

At the same time, affected companies use the MOHA to purchase, trade and submit EUAs. The central compliance deadline for the year is 30 September. By this date, sufficient EUAs must be submitted via the MOHA in the Union Registry to cover the verified company emissions. To ensure that the reporting, verification and submission processes run smoothly, a tight internal schedule is recommended: continuous monitoring, early data validation by verification bodies, timely entries in THETIS-MRV and the Union Registry, and timely procurement and provision of the required EUAs.

Sanctions and measures by authorities

In the EU ETS, violations of the obligation to surrender EUAs by 30 September of each year are subject to a fine. The penalty payment is €100 per tonne of CO₂ equivalent for emissions caused in the previous year for which no EUA was submitted. Since 2012, the value has been increasing annually in line with inflation, meaning that violations in 2024 will incur a penalty of €132.06 per tonne of CO₂ equivalent (source: DEHSt). Regardless of the penalty payment, the obligation to retroactively purchase and submit the missing EUAs remains. Similarly, if EUAs are not submitted, the names of the defaulting shipping companies are for exampled published in the Federal Gazette of Germany once the decision has become final; at EU level, the Commission also maintains an annual list of non-compliant operators.

This ‘naming and shaming’ increases the reputational risk, and in the event of repeated violations in two or more reporting periods, the flag or port state authorities may, as the most severe measure, deny access to EU ports or also detain ships in the home port of an EU state. Since liability applies company-wide, a single ship violation can affect the operator’s entire fleet (source: DEHSt). Consistent measurement of emissions, timely verification and timely procurement and submission of EUAs therefore remain essential to avoid financial penalties and operational restrictions. In the second part of our series, we will look at price and market developments in the EU ETS, the cost implications for shipping companies and the complementary rules under the FuelEU Maritime Regulation.

Sources

DEHSt, 2025, EU Emissions Trading 1 for Maritime Transport, URL: https://www.dehst.de/EN/Topics/EU-ETS-1/Maritime-Transport/EU-ETS-1-Maritime-Transport/eu-ets-1-maritime-transport_node.html

DEHST, 2025, EU ETS 1 Sanctioning, URL: https://www.dehst.de/EN/Topics/EU-ETS-1/EU-ETS-1-Information/Sanctioning/sanctioning_node.html

DEHSt, 2025, Maritime Transport-FAQ, URL: https://www.dehst.de/SharedDocs/FAQ/EN/maritime-transport/FAQList-SV.html#faq-id-299956

EEA, 2025, EU Emissions Trading System data viewer, URL: https://www.eea.europa.eu/en/analysis/maps-and-charts/emissions-trading-viewer-1-dashboards

EMSA, 2025, Facts and Figures, URL: https://emsa.europa.eu/publications/item/4515-emter-facts-and-figures.html

EU, 2024, Kommission Implementing Decision EU) 2024/411, URL: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202400411

EU Kommission, 2025, FAQ – Maritime transport in EU Emissions Trading System (ETS), URL: https://climate.ec.europa.eu/eu-action/transport-decarbonisation/reducing-emissions-shipping-sector/faq-maritime-transport-eu-emissions-trading-system-ets_en

EU Kommission, 2025, Report from the Commission: Review of Regulation (EU) 2015/757 on the monitoring, reporting and verification of greenhouse gas emissions from maritime transport in relation to the potential inclusion of ships below 5 000 gross tonnage but not below 400 gross tonnage  , URL: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52025DC0109

EU Kommission, 2025, Monitoring, reporting and verification URL: https://climate.ec.europa.eu/eu-action/eu-emissions-trading-system-eu-ets/monitoring-reporting-and-verification_en

Emission trading in Germany: Revenue, key developments and prospects

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Germany’s emissions trading systems are undergoing fundamental changes. The EU emission trading system (EU ETS 1) faced declining revenues, while the national system (nEHS) sets new revenue records. What drives these developments, and how will upcoming regulatory shifts – from CBAM to the EU ETS 2 – shape Germany’s carbon pricing landscape?

EU ETS 1: Declining revenue with potential upside

The EU ETS 1, which regulates emissions from energy-intensive industrial plants, intra-European aviation, and maritime transport, saw a significant decline in German auction revenue in 2024. The total revenue from auctioning the EU ETS 1 emission allowances (EUA) amounted to approximately EUR 5.5 billion marking a 28% decrease from the EUR 7.7 billion recorded in 2023 (Figure 1). This decline was driven by two main factors: a reduction in the number of EUAs auctioned and a fall in the average EUA price in 2024 compared to 2023 (UBA, 2025).

Figure 1: Auction revenues from the EU ETS 1 in Germany 2023-2025 (source: DEHSt, 2025a)

To reinforce climate goals, the EU continues to reduce the quantity of available EUAs. In 2024, the auctioned amount for Germany dropped to 85 million, down from 92 million in 2023. Additionally, the average price per EUA decreased from 83.66 EUR/tCO2 in 2023 to 65.00 EUR/tCO2 in 2024, reflecting lower demand from the energy and industrial sectors due to higher shares of renewables in the electricity grid and weaker economic conditions. Despite this, the 2024 average price remained 24% higher than the 2021 level, showcasing the long-term strengthening of emissions pricing.

Since the end of 2024, the allowance price in the EU ETS 1 has rallied amid the expectations of lower supply of allowances and thus higher prices during 2025. While the price stood at 65 EUR/tCO2 mid December 2024, it has risen by almost 25% and sometimes traded at above 80 EUR/tCO2 in February 2025. The EUA price expectations for the year 2025 ranges between 80-90 EUR/tCO2 indicating both a tightening of supply and thus likely higher auction revenues again this year.

Record revenues in Germany’s national emission trading system

Unlike the EU ETS 1, the German national emissions trading system (nEHS), which covers emissions from heating and transport, witnessed an increase in revenue. In 2024, revenue from the nEHS reached EUR 13 billion, up 21% from the EUR 10.7 billion recorded in 2023 as Figure 2 shows. This increase was primarily due to a rise in the fixed price of nEHS certificates from €30 per tonne in 2023 to €45 per tonne in 2024 (UBA, 2025).

Figure 2: Sales revenues from the nEHS in Germany 2023-2025 (source: DEHSt, 2025b)

A total of 278 million nEHS certificates were sold on the European Energy Exchange (EEX) in Leipzig in 2024 at the new fixed price, generating approximately EUR 12.5 billion. An additional 17 million certificates for 2023 were sold at the previous year’s price of 30 EUR/tCO2, adding another €500 million to the total revenue. Despite a lower number of certificates sold compared to 2023 (which saw 358 million certificates sold), the revenue increase was sustained by the price hike.

Total revenues from emission pricing at record high

Germany’s combined revenue from the EU ETS 1 and nEHS reached EUR 18.5 billion in 2024, surpassing the EUR 18.4 billion in 2023 and significantly exceeding the EUR 13 billion in 2022. These funds are allocated to the Climate and Transformation Fund (KTF), which finances initiatives supporting Germany’s energy transition and decarbonisation goals.

Dirk Messner, President of the German Environment Agency (UBA), emphasized that emissions trading must continue to be a driving force for climate protection, economic competitiveness, and social sustainability. He advocates for a climate bonus to support households affected by rising carbon prices, alongside targeted subsidies to assist vulnerable groups in transitioning to climate-friendly alternatives (UBA, 2025).

Regulatory developments: Aligning national legislation

The German Bundestag passed the TEHG-Europarechtsanpassungsgesetz 2024 in the end of January 2025, aligning national regulations with the reformed emission trading rules of the EU. Key aspects of this reform include (BMWK, 2025):

  • Inclusion of maritime transport: From 2024, 40% of emissions from shipping are covered under EU ETS 1, increasing to 70% in 2025 and 100% in 2026.
  • Stricter emission caps in aviation: Starting 2024, airlines face lower emission limits, and for the first time, they must report non-CO2 climate effects such as contrail formation.
  • Transition to the EU ETS 2 in 2027: The new European emissions trading system for transport and heating will replace the German nEHS and other national carbon pricing schemes of EU Member States.
  • Implementation of the Carbon Border Adjustment Mechanism (CBAM): CBAM introduces carbon pricing for imports of energy-intensive products such as steel, cement, and aluminum, ensuring fair competition within the EU market. A transition phase is underway, with full financial obligations beginning in 2026.

At the start of 2025, the fixed CO2 price in the nEHS rose from 45 to 55 EUR/tCO2 (compare Table 1), a step that has been planned since the introduction of the system in 2021. This gradual increase allows citizens and businesses time to transition to greener alternatives and will also likely lead to higher sales revenues during 2025 again. With the nEHS being absorbed into the EU ETS 2 from 2027, price for emissions in those sectors will be based on free auction prices.

Year Price EUR/tCO2 Mechanism
2021 25     Fixed price  
2022 30
2023 30
2024 45
2025 55
2026 55-65 Auction with price corridor
From 2027 45-100 (estimates) Auction with free market price (EU ETS 2)
Table 1: Development of emission pricing in the sectors covered by the nEHS

The 2025 price hike in the nEHS is expected to have only moderate impact on fuel costs. The price per liter of gasoline and diesel may rise by around 3 cents. However, fuel prices fluctuate due to external factors such as global oil prices, which often cause greater price variability than carbon pricing alone. For an individual driving 15,000 km annually, the expected cost increase will be around EUR 50 per year (Bundesregierung, 2025).

Conclusion and future trajectory

As the EU emission trading framework expands, carbon pricing evolves as central mechanisms for climate policy. While the EU ETS 1 faced revenue declines due to economic fluctuations and market adjustments, the nEHS saw record revenues driven by increased carbon pricing. Germany’s total revenue from emissions trading reached an all-time high, reinforcing the importance of dedicating these funds to climate mitigation and social equity initiatives.

The price increase in the nEHS, the expected higher prices in the EU ETS 1, the introduction of CBAM and the launch of the EU ETS 2 in 2027 mark significant milestones in the transition towards a carbon-neutral economy. As Europe moves towards its 2050 net-zero target, emissions trading will remain a cornerstone of environmental and economic policy.

Sources

BMWK, 2025, Bundestag beschließt umfassende Reform des Emissionshandels, URL: https://www.bmwk.de/Redaktion/DE/Pressemitteilungen/2025/20250131-bundestag-emissionshandel.html

Bundesregierung, 2025, CO2-Preis beträgt jetzt 55 Euro, URL: https://www.bundesregierung.de/breg-de/aktuelles/co2-preis-kohle-abfallbrennstoffe-2061622

DEHSt, 2025a, Auctioning report: Fourth Quarter 2024, URL: https://www.dehst.de/SharedDocs/downloads/EN/auctioning/2024/2024_report_Q4.pdf?__blob=publicationFile&v=3

DEHSt, 2025b, Sales report: Fourth Quarter and entire year 2024, URL: https://www.dehst.de/SharedDocs/downloads/EN/nehs/sales-reports-nehs/2024/2024-Q4_sales-report.pdf?__blob=publicationFile&v=3

UBA, 2025, Revenue from emission trading one again at record level, URL: https://www.umweltbundesamt.de/en/press/pressinformation/revenue-from-emissions-trading-once-again-at-record

 

The EU ETS 2 – pricing emissions in buildings and road transport

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The European Union’s Emissions Trading System (EU ETS) constitutes a cornerstone of the EU’s strategy to combat climate change since its establishment in 2005. The new EU ETS 2, implemented from 2024 covers emissions from buildings, road transport, and additional sectors such as fuel use in small industrial installations. The EU ETS 2 is founded upon the objectives of the EU Climate Law and the Fit-for-55 package and requires the fuel suppliers to monitor and report emissions in their fuels. From 2027 when the EU ETS 2 is fully operational, emission allowances need to be purchased and surrendered based on the emissions in the fuels sold. This new emission trading system adds a further layer of complexity to the regulatory compliance landscape.

Key facts about the EU ETS 2

The EU ETS 2 will be running in parallel to the EU ETS 1 and encompasses areas that were previously excluded, such as the buildings and road transport sectors. The operational principle of the EU ETS 2 is based on a cap-and-trade system, where an annually decreasing cap is set on total emissions and a corresponding number of allowances is auctioned to regulated entities. One allowance needs to be surrendered per ton of CO2 emitted. The EU ETS 2 is designed to reduce emissions by 42% by 2030 in comparison to 2005 levels. In contrast to the EU ETS 1, which regulates emissions at the point of origin, the EU ETS 2 places the compliance burden upstream at the release for consumption of fuels and not at the point where fuels are combusted. Estimates of the EU Commission expect up to 11.400 fuel suppliers, distributers and resellers to be regulated (regulated entities). This new system harmonises national and EU responsibilities, targets and emissions pricing.

To determine emissions under the scope of the EU ETS 2, a comprehensive monitoring, reporting, and verification (MRV) system is implemented at the company-level. To avoid double counting, emissions from fuel combustion under the EU ETS 1 should not be counted in the EU ETS 2. This requires fuel suppliers and their clients to provide proof and documentation in such cases. The EU ETS 2 permits the coexistence of national carbon taxes with the EU ETS 2, allowing EU Member States to exempt companies from EU ETS 2 requirements until 2030 if national measures are more stringent. In Germany the national ETS is only fully integrated into the EU ETS 2 from 2027 onwards, which makes a double reporting of emissions necessary for 2024 – 2026.

First compliance deadlines in 2024

For companies subject to the EU ETS 2, key compliance activities should already be ongoing, and deadlines are approaching soon. Companies must commence monitoring emissions by January 2024 and report those emissions by 30 April 2025. The timeline for compliance is stringent, as Figure 1 indicates.

Figure 1: Timeline of EU ETS 2 compliance obligations. Source: carboneer

To monitor emissions in accordance with the rules of the EU ETS 2, by 31 August 2024 a monitoring plan should be submitted to the competent national authority. Full compliance, especially procuring and surrendering allowances under the EU ETS 2 is required from 2027, and failure to meet these deadlines can result in significant penalties and legal repercussions, making it imperative for companies to commence preparations without delay. The potential consequences of non-compliance include financial penalties and loss of competitiveness.

From 2027 onwards allowances under the EU ETS 2 will be auctioned. An allocation of free allowances such as during the start of the EU ETS 1 and currently still applied to EU industry will not exist. To regulate the supply of allowances and maintain price stability, a market stability reserve will be implemented. The initial allowance cap in 2027 will be determined by applying a 5.1% annual reduction to the 2024 emission level. From 2025 onwards, this linear reduction factor increases to 5.38%. This implies that the total supply of allowances in 2027 will be approximately 1.25 billion, declining to below 800 million by 2030. Figure 2 illustrates the decline in the allowance auction volumes over time, aligned with the EU’s long-term sectoral climate targets.

Figure 2: Approximate EU ETS 2 allowance supply. Source: carboneer

Challenges and complexity

The EU ETS 2 presents a significant challenge for companies as they need to develop comprehensive emission monitoring plans, detailing their activities, fuel types, and emission calculation methodologies to comply with their obligations. Especially the calculation of the emissions can be a complex undertaking. First, a scope factor needs to be established to determine the portion of a company’s fuel sales that lie within the regulated activities, such as buildings and road transport. The scope factor ranges from 0 (no fuel in scope) to 1 (all fuel in scope). This ensures only relevant emissions are counted. Using the correct emission factor for different fuels along with the quantity of fuels, the total CO2-emissions can be calculated.

To ensure data quality, the MRV follows a tier system that categorises data accuracy from Tier 1 (least accurate) to Tier 4 (most accurate). Higher tiers, used for companies with more larger fuel streams and thus higher emissions, require more precise data, ensuring reliable results. Importantly, emissions from fuels based on biomass can be zero-rated if they fulfil the criteria on biomass under the Renewable Energy Directive (RED) II and the upcoming RED III.

Monitoring plans must gain approval from the competent national authority, underscoring the importance of early and thorough preparation. The emission reporting for 2024 is due 30 April 2025, with third-party verification becoming mandatory from the 2025 emission report on. The introduction of the EU ETS 2 pricing can result in significant cost increases, which will have an impact on both operational expenses and consumer prices. Figure 3 displays price forecasts for the allowances in the EU ETS from different sources. As prices are determined through demand and supply, they can be expected to exhibit significant volatility, with forecasts ranging from €48 to €340 per tCO2 by 2030. Companies ought to manage cost risk via tailored procurement strategies for EU ETS 2 allowances.

Figure 3: Forecast of EU ETS 2 allowances prices in 2030. Data Source: UBA, 2024, Source: carboneer


The Social Climate Fund plays a crucial role in mitigating the financial impact on vulnerable consumers in the EU. Its objective is to support vulnerable households and micro-enterprises that are impacted by the transition to a low-carbon economy. The fund, financed by revenues from the auctioning of allowances, provides financial assistance for measures that reduce emissions and energy costs. One example is the provision of subsidies to enhance the energy efficiency of residential properties such as improvements to insulation and the installation of more efficient heating systems. This dual focus on households and businesses ensures a broader impact, promoting social equity and economic resilience, and helps to offset some of the financial burdens and operational challenges posed by the EU ETS 2.

To understand the potential impact of the rising allowance prices, Figure 4 illustrates how different fuel types are being impacted by different allowance prices.

Figure 4: Price impact on different fuels under varying EU ETS 2 allowance prices. Source: carboneer

What should an EU ETS strategy entail?

Due to the complexity of the EU ETS 2 and its stringent timeline, a sound EU ETS 2 strategy is essential. But what does a company need to prepare for?

MRV details and compliance cycle

  • Development of comprehensive monitoring plans that cover all relevant activities, fuel types, and emission calculation methodologies
  • Monitoring plans must be approved by national authorities
  • Verification of emissions

Compliance obligations:

  • Detailed understanding of the EU ETS 2 rules and associated regulation
  • Build capacity, assign responsibilities, internal and external communication
  • Access to registries and EU ETS 2 allowances

Financial impact assessment:

  • Assessment of EU ETS 2 exposure and cost forecasts
  • Implementation of strategies to manage costs and pass on costs to consumers
  • Risk management and allowance procurement strategies to reduce financial exposure

Conclusion

The EU ETS 2 is a crucial tool in the European Union’s strategy to combat climate change by establishing a new cap-and-trade system for fuels in sectors such as buildings and road transport. It aims to reduce emissions by 42% by 2030 compared to 2005 levels. The system introduces complex obligation for companies that require planning and a compliance strategy, including stringent monitoring, reporting, and verification processes starting from 2024. With allowance prices expected to rise significantly, the financial implications are substantial and necessitate robust risk management and hedging strategies. Companies should act now to understand and navigate these new regulations, ensuring compliance and maintaining competitiveness.

Authors: Florian Schlennert and Simon Göß.

Sources: UBA, 2024, Supply and Demand in the ETS 2, URL: https://www.umweltbundesamt.de/publikationen/supply-demand-in-the-ets-2