Monitoring plans

The monitoring plan for each ship must be verified by an accredited verifier before it is submitted to the administering authority in THETIS-MRV.

Deadlines

The shipping company shall submit a positively assessed monitoring plan to the administering authority no later than three months after the ship’s first call in an EEA port.

Preparations

Whilst working on a monitoring plan, the shipping company should do the following:

Shipping companies shall submit monitoring through THETIS-MRV.

Monitoring plans and emission reports shall be verified by a verifier accredited by a National Accreditation Body in the EEA.

Shipping companies may select any duly accredited verifier for each of their ships, irrespective of the ship's flag or the country where the company is based and where the accredited verifier is based.

A MOHA is necessary for the reporting of greenhouse gas emissions and the surrendering of EU ETS allowances. The account may also be used to transfer/receive allowances to/from other accounts in the registry.

Shipping companies must open a MOHA in the country of their administrating authority. On January 31, 2024, the European Commission published a list of administrating authorities and shipping companies.

You can find the list here.

Shipping companies not included in the list who are performing voyages covered by the EU ETS Directive must identify their administrating authority through THETIS-MRV. The THETIS-MRV helpdesk will help the companies assign their responsible administering authority in the system.

The helpdesk may be contacted by email:

How to apply

The Norwegian Environment Agency is the national administrator of the Union Registry in Norway. A guide on how to apply for a MOHA is available here:

According to the Registry Regulation, a shipping company shall submit to the relevant national administrator a complete application for a maritime operator holding account (MOHA):

within 40 working days of the publication of the attribution list (published on 31 January 2024);
for shipping companies not included in that list, within 65 working days of the first port of call falling within the scope of the ETS Directive.

Content

Shipping companies shall use the monitoring plan template in Annex I Template for monitoring plans, in Implementing Regulation (EU) 2023/2449.

All mandatory fields shall be duly filled in.
All fuel tanks which are part of a measuring method, all emission sources and all measuring equipment must be included and listed separately. The identification and technical description shall be sufficient.
The measuring equipment must be sufficiently described, identifiable and related to an emission source/fuel tank. The technical description shall provide required information such as specification, year of installation, maintenance intervals and calibration method and intervals. If calibration is not applicable to the respective measuring equipment, this should be clarified and an alternative method for quality assurance should be provided.
Ships using LNG as fuel shall include methane slippage in the monitoring plan. Where default slippage coefficients are not listed for a specific emission source class, companies should apply a slippage coefficient of zero.
Only fuels that the ship actually consumes shall be listed.
Cargo tank(s) have to be listed in the fuel tank table when cargo is used as fuel.
Information in the fuel tank table, emission source table and measuring equipment table needs to be consistent. For example all measuring equipment listed in the fuel tank table or in the emission source table has to be listed in the measuring equipment table.
The MP Assessment Report shall be attached.
If the shipping company is an ISM company, we ask you to attach the mandate when submitting the monitoring plan.

Please note that this is not a complete list of monitoring plan requirements. For detailed requirements regarding the content of each part of the monitoring plan, see Annex I to Regulation (EU) 2023/2449 (the Templates Regulation), cf. the Greenhouse Gas Emissions Trading Regulation (klimakvoteforskriften) § 2-1a second paragraph. See in particular the footnotes as well as the header rows of the tables.

Methods for handling missing data must be sufficiently clear, comprehensive and unambiguous for the administering authority to understand what sources of data will be used as a backup for all relevant scenarios of missing, or incorrect data. Below, we list particularly the important aspects that must be accounted for. See also the European Commission's guidance document, chapter 7.4.4.

The method for handling missing data;

must be described in such a way that they cover all parts of the data flow thoroughly. For example, they must cover any dysfunctional measuring equipment, loss of AIS signals, missing BDN, missing registrations of measurements, loss of registered measurements, use of incorrect calculation basis, etc.
should be a different method than the method(s) otherwise mentioned in the monitoring plan. If a method for handling missing data is similar to a monitoring method during normal operation, it is important that it is clearly described how the method can be considered an alternative used in the event of lost or incorrect data.
should be conservative. For example, it is not sufficient to calculate emissions using historical data, unless specific conditions (such as wind and sea conditions) are also taken into account. Furthermore, Article 3(l) of the same regulation defines "conservative" as the use of assumptions that ensure no underestimation of annual emissions and no overestimation of distances or amounts of cargo carried.

Procedures should be sufficiently described, including reference to existing procedure, name of person/position responsible, location of records etc.

References to existing procedures should be provided as a general rule. If this is missing, we consider that as a strong indication that no external procedures exist, and that the description given in the "Description of procedures" field constitutes a complete procedure. This means that the content of the description of the procedure should provide clear, complete and unambiguous instructions to the shipping company's employees and the ship's crew on how the tasks are to be performed. If, on the other hand, reference is given to external procedures, the description of the procedures may be briefer and more general, but it should still provide sufficiently detailed information to allow the verifier and the administering authority to make an informed decision on whether or not the procedures enables the company to comply with the relevant requirements.

To assess the descriptions, we generally need information on

the responsibilities and roles of the personnel on the ship offshore and onshore,
the frequency of tasks,
and a brief description of how all relevant tasks are performed, including methodology and criteria, where relevant.

For more information on what is expected in each individual procedure, please also see the European Commission's guidance document The EU ETS and MRV Maritime General guidance for shipping companies, in particular Chapter 6.

Please note that this is not a complete list of monitoring plan requirements. It is the shipping company’s responsibility to ensure that the content of the monitoring plan is accurate, complete and updated.

More detailed information on the content of the monitoring plan is available in the European Commission's Guidance Document No. 1.

Template

All mandatory fields must be filled in.

Submit the monitoring plan

The monitoring plans shall be submitted through THETIS-MRV.

Please contact the THETIS-helpdesk if you have any questions or problems related to this step.

Assessment and approval of monitoring plans

Shipping companies shall submit monitoring plans of ships under their responsibility and falling within the EU ETS scope to their responsible administering authority for approval.

Monitoring plans that meet the regulatory requirements and were submitted within a reasonable timeframe will be approved by the 6th of June 2025, in accordance with Article 6(8) of the MRV Regulation, cf. Section 2-1a of the Greenhouse Gas Emissions Trading Regulation.

The Norwegian Environment Agency will approve monitoring plans through administrative decisions. It is important that shipping companies read these carefully, as they may contain crucial information. Additionally, the monitoring plans will be marked as ‘approved’ in THETIS-MRV.

Shipping companies registered in Norway will receive administrative decisions in Altinn. Shipping companies registered elsewhere may choose to receive administrative decisions either by email or letter.

Note that monitoring plans for ships only falling within the scope of the MRV Regulation can be controlled by the administering authority but shall not be approved.

Fee

Shipping companies will have to pay a fee for the approval of monitoring plans. The fee is based on processing time. The invoice will be issued once the monitoring plan has been approved.

See Section 9-3 of the Greenhouse Gas Emissions Trading Regulation.

Regulations (in norwegian)

Modifications of the monitoring plan

Shipping companies must regularly, and at least once a year, check if the ship’s monitoring plan fits the ship’s operations and if the monitoring methods can be improved.

Shipping companies must change the monitoring plans in the following situations:

When the shipping company changes.
When new greenhouse gas emissions occur due to new emission sources or the use of new fuels not included in the monitoring plan.
When the availability of data changes due to new types of measuring equipment, new sampling methods, or analysis methods, or for other reasons that may affect the accuracy of greenhouse gas emissions calculations.
When data from the applied monitoring method is found to be incorrect.
When any part of the monitoring plan does not meet the requirements of the MRV Regulation and the company must revise it according to Article 13(1) of the regulation.

In case of modifications of the monitoring plans, shipping companies shall notify the verifiers without undue delay.

In circumstances provided by points 2, 3 and 4 above, modifications of the monitoring plan shall be subject to assessment by the verifier. Following the assessment, the verifier shall notify the shipping company whether those modifications are in conformity with the requirements of the MRV Regulation.

Once a shipping company has received a notification of conformity, and for ships falling within the scope of the EU ETS Directive, it shall submit its modified monitoring plan to the responsible administering authority for approval. Shipping companies shall also submit modifications provided under points 1 of the above to the responsible administering authority without undue delay once it has notified the verifier.