EU ETS for shipping and offshore

When the EU decided to include maritime emissions in its emissions trading system starting in 2024, it was more than a regulatory adjustment. For the shipping and offshore sectors, it marked a clear shift in how the industry is expected to manage risk, investments, and competitiveness going forward. Norwegian players, many of whom operate globally, feel this directly. Where emissions reporting was once seen as a compliance requirement, the numbers must now be understood as economic variables with a direct impact on the bottom line.

What we expect to see is that the EU ETS, reinforced by FuelEU Maritime and possibly the IMO Net Zero Framework, will also act as a catalyst. By adding a direct cost on emissions, it challenges established operating patterns and brings emissions data into the boardroom in a way we haven’t seen before. Several companies now experience that this transition is forcing a new type of strategic thinking, where technology, data, and business models must work more closely together.

The EU ETS is built on a “cap-and-trade” system that sets a ceiling for total emissions and assigns a price to what is emitted. With the system now covering shipping, the rules apply to all vessels over 5,000 gross tonnage calling at EEA ports. Emissions from voyages within the EEA, parts of voyages to and from third countries, and all import activities are included.

The result is that maritime emissions can no longer be regarded solely as a reputational issue; they have become measurable, costly, and comparable across operators. For many, this marks the beginning of a more holistic approach to energy use, operations, and future investments.

The EU has planned a gradual phase-in toward 2027, giving the industry time to establish robust data foundations and internal systems. At the same time, this means businesses must maintain control over the entire reporting chain: from how data is collected and verified, to how costs are modelled and planned for.

In practice, shipping companies must assess whether their current technical systems, internal controls, and allocation of responsibilities are suited for a regime where emissions represent both a real cost and a strategic factor in contract negotiations.

The effects of the EU ETS are felt primarily in three areas:

We see that the companies succeeding are beginning to ask a few fundamental questions:

• What will fluctuations in the carbon price mean for our largest contracts and routes?
• How do we adapt our fleet, technology, and fuel strategy in a more carbon-conscious market?
• How do we ensure reporting is accurate, consistent, and cost effective?
• How can documented emissions reductions be used actively in dialogue with customers and investors?

These questions shape operational and strategic decisions, and they are central in the discussions we have with shipping and offshore companies today.

At KPMG, we work closely with maritime companies navigating this transition. We see a wide range of needs, spanning from supporting the establishment of solid monitoring, reporting and verification (MRV) routines, to analyzing how carbon costs will affect future contracts, or advising strategic choices related to fleet and technology.

We support clients by

• Creating and operationalizing EU ETS planning
• Ensuring reporting processes and data foundations are accurate, audit-ready, and integrated into management processes
• Establishing or improving digital data flows that provide better control and insight
• Assessing investment options, fuel strategies, and technologies that can strengthen competitiveness going forward
• Modelling the actual cost of emissions in the short and long term, and what it means for operations and margins

In practice, we combine industry insight, technical ETS expertise, and hands on experience from maritime transition, turning regulatory requirements into potential competitive advantages.