UK ETS Shipping Compliance: What the UK Emissions Trading Scheme Requires of Ship Operators

Shipping has been inside the UK Emissions Trading Scheme since 1 July 2026, and the first verified emissions report is due on 31 March 2027. Most coverage written before launch focused on whether the scheme would apply. With the first monitoring period already running, the questions facing fleet managers and DPAs are practical ones: which company holds the obligation, when the monitoring plan was due, and what the audit trail must show by March.

What Is the UK Emissions Trading Scheme for Shipping?

The UK ETS is the United Kingdom's cap-and-trade carbon market, running since 2021 for power and industry. The Greenhouse Gas Emissions Trading Scheme (Amendment) (Extension to Maritime Activities) Order 2026 brought domestic shipping into it. Operators must monitor emissions, have them verified, and surrender one allowance per tonne of CO2 equivalent.

Which Vessels and Routes Are in Scope?

Scope turns on three tests: ship size, voyage type, and whether the activity takes place in a UK port.

In scope from 1 July 2026:

• Cargo and passenger ships of 5,000 GT and above, regardless of flag
• Voyages between two UK ports, including voyages that start and end at the same UK port
• All emissions at berth, at anchor, and while moving within UK ports, including port calls on international voyages

Outside the scheme:

• International voyage legs to or from the UK, for now
• Offshore ships, until 1 January 2027
• Fishing and fish-processing vessels, government non-commercial ships, and Scottish ferry services
• Wooden ships and ships without mechanical propulsion

Two details catch operators out. Voyages between Northern Ireland and Great Britain carry a 50% deduction on the surrender obligation, but in-port emissions on those routes are charged in full. International voyages are not settled either. The government consulted until 20 January 2026 on adding 50% of emissions from international voyages from 2028, and no final decision had been confirmed at the time of writing.

Who Holds the UK ETS Obligation: Owner, ISM Company, or DPA?

The UK ETS places the obligation on the "maritime operator." By default, that is the registered owner. The obligation moves to the ISM company only when three conditions are all met:

1. The ISM company has assumed responsibility for operating the ship from the owner
2. The ISM company carries the duties and responsibilities of the ISM Code
3. The ISM company has agreed, under a legally binding written agreement, to take on UK ETS compliance

For DPAs and technical managers, the third condition is the one to check. A standard ship management agreement written before 2026 is unlikely to mention UK ETS. Without that clause, the obligation stays with the registered owner, even if the manager collects every litre of fuel data. Owners and managers should settle this in writing before the first report is filed, because the METS account, the monitoring plan, and any penalty all attach to whoever holds the obligation.

UK ETS Compliance Deadlines for Ship Operators

The monitoring plan is the first gate, and its deadline is triggered by activity rather than by date. Operators must apply for an Emissions Monitoring Plan within 42 days of first carrying out a covered maritime activity. A ship that made a UK domestic voyage in July 2026 was already past that point by mid-August.

Approved monitoring methods

The monitoring plan must name one of four approved methods for each emission source:

• Method A: bunker delivery notes plus periodic fuel tank stocktakes
• Method B: daily tank soundings at sea and at bunkering
• Method C: flow meters on combustion processes
• Method D: direct CO2 measurement at the exhaust stack

Ships scheduled to complete 300 or more voyages a year, such as short-sea ferries, may apply for simplified monitoring without per-voyage tracking.

Verification and penalties

Reports must be verified by a UKAS-accredited verifier before submission. Missing the surrender deadline triggers an excess emissions penalty of £100 per missing allowance, adjusted for inflation, and the missing allowances must still be surrendered.

How SPICA LogBook Supports Emissions Record-Keeping

A verifier tests the data trail behind every figure: bunker delivery notes, tank soundings, port arrival and departure times, and the voyage log that separates domestic legs from international ones. Gaps in any of those records become non-conformities in the verification report.

SPICA LogBook replaces paper MARPOL logbooks with a digital system, keeping a permanent edit history, role-based sign-off, and onboard storage that works offline. Its integrated CarbonOne emissions reporting module turns logged fuel use and distance into CII, EEXI, EEOI, and AER reports. Neither tool files UK ETS reports or replaces an accredited verifier. The value lies in a clean, consistent source record that the operator and verifier can rely on.

For bridge teams, SPICA e-Navigator adds environmental zone management to passage planning, while a laminated map of emissions regulations keeps MARPOL special areas and ECAs visible on the bridge. The ICS guide Shipping and the Environment gives superintendents broader regulatory context, and current Annex VI texts sit in the MARPOL publications collection.

Is UK ETS the Same as the EU ETS?

No. The two schemes share a monitoring philosophy but differ in scope, and an operator trading between UK and EU ports may face both on the same voyage.

The UK and EU committed in May 2025 to negotiate a link between their carbon markets, with maritime named as a sector to include. Until a linking agreement takes effect, UK and EU allowances are not interchangeable.

Request a SPICA Demo

The 31 March 2027 deadline arrives at the end of a busy winter. Operators who confirm the responsible entity, the monitoring method, and the source records now will reach verification with fewer surprises.

Request a SPICA demo through the SPICA LogBook and CarbonOne page, or contact ANS at +1 (954) 522-3321 or sales@amnautical.com for SPICA licensing and MARPOL publications.

Frequently Asked Questions

Does UK ETS apply to vessels under a certain size?

UK ETS applies only to ships of 5,000 GT and above. Smaller ships are outside the scheme, as are offshore ships until 1 January 2027.

Do ships need to report emissions under UK ETS?

Yes. Every in-scope operator needs an approved Emissions Monitoring Plan and must submit a verified annual emissions report through METS by 31 March of the following year.

Is UK ETS the same as the EU ETS?

No. The EU ETS has covered shipping since 2024 and includes 50% of voyages into or out of the EEA. UK ETS currently covers only UK domestic voyages and UK in-port emissions.

Does UK ETS apply to foreign-flagged ships?

Yes. Scope depends on the ship's activity in UK waters and ports, not its flag. Operators based outside the UK are regulated by the Environment Agency.

Who is responsible for UK ETS compliance on a managed ship?

The registered owner, unless the ISM company has taken on UK ETS compliance under a legally binding written agreement and also holds ISM Code responsibility.

What is the penalty for not surrendering UK ETS allowances?

An excess emissions penalty of £100 per missing allowance, adjusted for inflation, and the missing allowances must still be surrendered.