From 1 July 2026, the UK Emissions Trading Scheme (UK ETS) extends to domestic maritime transport, following the Greenhouse Gas Emissions Trading Scheme (Amendment) (Extension to Maritime Activities) Order 2026 (UK SI 2026/392). For UK-trading owners and managers already juggling CII, EU ETS and FuelEU Maritime compliance, this is a fourth carbon reporting regime to layer in — and one with its own scope, deadlines and reporting system. Below we work through the ten questions that come up most often when shipping companies start preparing.

1. To which ships does it apply?

The UK ETS applies to cargo and passenger ships of 5,000 gross tonnage (GT) and above. Offshore ships are also in scope, but their inclusion is delayed until 1 January 2027. Exemptions apply to ships engaged in government non-commercial maritime activities, fish-catching and fish-processing vessels, and ships operating Scottish ferry services — with further detail set out in the Order itself.

2. Which voyages are covered?

Scope is narrower than the EU ETS. The UK ETS covers:

• Intra UK voyages — port-to-port movements between two UK ports, and voyages that start and end at the same UK port.
• Port calls at UK ports and offshore installations — including time at berth or at anchor — even where the wider voyage is international. A leg of an international voyage that calls at a UK port still generates an in-scope reporting obligation for that port stay.
• International voyages- From UK port to EEA or Non EEA ports- the voyage itself has zero ETS surrender obligation, but 100% emission during the port stay fall under 100% scope.

Voyages between the UK and ports outside the EEA, including UK Overseas Territories and Crown Dependencies, are not in scope, since they are not "domestic" voyages. A special rule applies to Northern Ireland–Great Britain voyages: a 50% surrender obligation applies to the voyage itself, while port stays at both ends remain subject to a full 100% obligation. For an international voyage between, say, Netherlands and Great Britain,

3. Who is responsible for compliance?

Responsibility sits with the ship operator, which by default is the registered owner. This can be delegated to the ISM company, but only where a legally binding agreement assigns the UK ETS obligations to them — and that agreement must be recorded in METS (Manage your Emissions Trading Scheme), the digital platform that runs the entire scheme. Owners and managers should settle this allocation of responsibility now, not after the first reporting cycle begins.

4. From which date should monitoring start?

1 July 2026. Operators must collect emissions data in line with their approved Emissions Monitoring Plan (EMP) from that date for all in-scope voyages and port calls. A voluntary on boarding phase is running until 30 June 2026, during which operators can register, set up METS access, and prepare their EMP ahead of the mandatory start.

5. When must the Emissions Monitoring Plan (EMP) be ready?

The EMP is submitted at company level in METS — one plan per operator, covering every ship under its responsibility, rather than a plan per vessel. It sets out the monitoring methodology, vessel list, emission sources and calculation methods. Unlike the EU MRV scheme, the UK ETS EMP is not verified before submission — it goes straight to the regulator for approval.

The statutory deadline is 42 days from the date the operator performs its first maritime activity in scope. For most operators trading from day one, that means an EMP should be submitted to the regulator by roughly mid-August 2026. Given the regulator must then review and approve it, we'd recommend treating the voluntary onboarding window (now to 30 June 2026) as the real deadline for getting the EMP drafted.

There is no charge for early onboarding, including the assessment of an EMP application.

6. What are the reporting and surrender deadlines — and which are the first reporting and surrendering years?

The standard annual cycle is:

• Annual Emissions Report (AER) submitted, and independently verified by a UKAS-accredited verifier, by 31 March each year, covering the previous scheme year.
• Allowance surrender completed by 30 April each year.

The first scheme year is a truncated six-month period: 1 July to 31 December 2026. From 2027 onward, the scheme year reverts to the standard calendar year (1 January–31 December).

One point worth flagging clearly: published guidance indicates the regulator has set the allowance surrender deadline for this first, truncated scheme year at 30 April 2028 — a notably longer compliance window than the standard one-year cycle, reflecting transitional arrangements for the scheme's launch. Because this is an unusual provision and still bedding in, operators should confirm the exact AER and surrender dates applicable to their first reporting period directly via METS or their assigned regulator rather than relying solely on secondary guidance.

7. Where is reporting done, and to whom?

Everything is handled digitally through METS (Manage your Emissions Trading Scheme) — the UK's equivalent of THETIS-MRV and the EU ETS registry combined. There is no onboard Document of Compliance requirement, unlike the EU ETS.

The regulator that reviews your monitroing plans ( EMP). and the Annual Emission reports ( AER) and surrender obligations is determined by the operator's registered address:

For international opertaors located outsdie of the UK  by default this will be the UK Environment Agency (default).

8. What gases must be monitored and reported?

The UK ETS aligns with the EU ETS on gas scope: carbon dioxide (CO₂), methane (CH₄) and nitrous oxide (N₂O), covering both combustion emissions and methane/VOC slip, calculated on a tank-to-wake basis. CH₄ and N₂O are converted to CO₂-equivalent using IPCC AR5 global warming potentials (CH₄ = 28, N₂O = 265).

9. What are the fines and penalties for non-compliance?

Civil penalties under the maritime extension follow the same framework applied across all UK ETS sectors, and include:

• Failure to register or give required notice — a penalty of 10% of the relevant amount or £2,500 (whichever is higher) where there is a "penalty year"; £2,500 where there is not.
• Under-reporting of emissions — £10 per tonne of CO₂-equivalent (adjusted by an inflation factor), with a discretionary additional penalty of up to £5,000 at the regulator's discretion.
• Failure to surrender sufficient allowances by the deadline — a "deficit notice" is issued, triggering a mandatory penalty calculated against the UK ETS carbon price for that scheme year (set at £49.41 per tonne CO₂e for the 2026 reporting year), plus a discretionary daily penalty for continuing non-compliance. The operator remains liable to surrender the outstanding allowances regardless of the penalty.

Regulators also have the power to publish the names of operators found non-compliant — a reputational, not just financial, exposure.

10. How does a company register and start the process?

1. Submit a METS account request via the official Forms link issued by the UK ETS Authority: Register for a METS account.
2. The UK Registry Administrator will open a holding account on the operator's behalf and issue instructions on appointing Authorised Representatives for the Registry account.
3. Use the onboarding period to draft the company-level EMP directly in METS — your class society ,verifier or service provider can help consolidate vessel-level data into the operator-level plan.
4. Confirm internally who holds UK ETS responsibility — owner or ISM manager — and put the supporting agreement in place before the 1 July 2026 start.

Asses your fleets operational profile and identify any prospective voyages that might fall under the scope. Alternately, go all in and register with METS during the voluntary phase and ensure your compliance.

Our Perspective

At TECS, we're seeing the same pattern with UK ETS that we saw with EU MRV and EU ETS: operators who treat the monitoring plan as a paperwork exercise end up scrambling at the regulator-approval stage, while those who use the voluntary onboarding window properly walk into 1 July with a clean data trail. The truncated first scheme year and the unusual two-year surrender timeline for that period make this an easy one to under-prioritise — don't. Clearly define the UK ETS responsibilities now between owners and ISM Manager, get your METS account live, and start the EMP draft well before the 42-day clock starts running.

How we can help

TECS provides end-to-end UK ETS support — from METS on boarding and Emissions Monitoring Plan preparation, to voyage data collection, evidence pack review and preparation and final verification of the annaul emssion report , followed by submssion in METS , our team can cover the full scope for you in our standard done for you service model