The maritime sector has been implemented in The Danish Emissions Trading System, effective from January 1st, 2024. The implementation of the maritime sector in the EU Emissions Trading System (EU ETS) is a continuance of the existing EU ETS, and thereby builds on the already existing monitoring, reporting and verification of emissions.
Ships covered by the EU ETS
The maritime expansion from January 1st, 2024, initially covers CO2 emissions from all cargo and passenger ships of 5000 gross tonnage (GT) and above, that call at EU ports, regardless of the flag under which they sail. The included maritime companies, which are registered in one of the EU member states must open a Compliance Account in the country they are registered in. Companies that are registered in countries outside the EU but sail to EU ports are also covered by EU ETS. The companies will be assigned to an EU member state and must open a Compliance Account, which is called Maritime Operator Holding Account. The EU Commission determines, according to adopted guidelines, where the maritime companies need to open a Compliance Account.
The Danish Energy Agency is the competent authority in Denmark and must assess the climate reports. The Danish Business Authority is responsible for approving, providing access to the Danish ETS Registry, as well as helping companies with their use of the register. For further information regarding the Danish Energy Agency's work on The EU Emissions Trading System in Denmark.
Timeline of the Maritime Implementation:
- From 2024: cargo and passenger ships of or above 5000 gross tonnage (GT)
- From 2027: offshore ships of or above 5000 GT
On January 31st, 2024, the EU Commission published an attributions-list assigning the shipping companies with ships weighting over 500 BT and covered by the EU ETS, to the EU Member States by which they must be administrated.
Accounts in the EU ETS registry
Shipping companies have their own type of Compliance Account called Maritime Operator Holding Account. Requirements for documentation are the same as for opening Operator Holding Accounts and Aircraft Operator Holding Accounts. However, additional documentation is required for opening of Maritime Operator Holding Account.
The fee for having an account in the Danish EU ETS Registry will be the same for shipping operators as it is for the other Compliance Accounts in Denmark.
Both those who are covered by the EU ETS and those who are not, can apply to open Trading Accounts in the Danish EU-ETS Registry. The purpose of Trading Accounts is for trading or voluntary climate reduction and therefore Trading Accounts cannot be used to comply with compliance obligations under the EU's Emissions Trading Scheme. Account holders of Trading Accounts can choose to buy allowances in order to delete them and in that way contribute to reducing the quantity of allowances and thus CO2 emissions. In order to have Trading Accounts in the Danish EU ETS Registry, companies must have an active Danish VAT registration.
Both Compliance Accounts and Trading Accounts require at least two Account Representatives at account opening, who can act on behalf of the account holder in the EU ETS.
Surrendering allowances
The companies that are covered by the EU Emissions Trading System must surrender the number of allowances to the EU each year, which corresponds to the total amount of greenhouse gases that the company has emitted into the atmosphere in the previous year. One allowance corresponds to the emission of one tonne of CO2 equivalents.
The first surrender of CO2 allowances for maritime operators took place in September 2025 for their 2024 emissions.
The share of emissions that must be covered by allowances gradually increases each year:
- 2025: 40% of emissions reported for 2024 must be covered by emission allowances
- 2026: 70% of emissions reported for 2025
- 2027 and beyond: 100% of reported emissions
The account representatives who are associated with an account must surrender the allowances through the Danish EU ETS Registry by 30 September each year at the latest.
The maritime sector will not be allocated free allowances.
Trading with allowances
Anyone who has an account in the Danish ETS Registry can trade with allowances regardless of the account type and there is no ceiling on the amount that can be traded. Allowances in the EU's Emissions Trading System are a financial instrument, and the price varies depending on the market economy.
Allowances can be bought on digital auction platforms and trading markets, which are registered or approved by the EU ETS. Allowances can also be traded between companies or individuals who have accounts in the EU ETS, regardless of which country the accounts are registered, and whether they are Trading or Compliance Accounts.
Account holders must enter into their own agreements concerning price, allowance volume, transaction date, etc., with the party with whom they wish to trade. Financial transactions relating to the purchase and sale of emission allowances take place outside the EU ETS Registry and do not have to be notified to the Danish Business Authority. It is only the transfer of the allowances that are performed in the EU ETS Registry and no service fee is charged for performing transactions in the EU ETS Registry.
Shipping Operators can trade with the following types of allowances , in the Danish ETS Registry:
- EUA – General allowances
- EUAA – AOHA allowances
- CHU – General Swiss allowances
- CHUA – AOHA Swiss allowances
Guidance Document
On the EU Commission website, you can find different Guidance Documents regarding the EU ETS maritime inclusion.
Frequently Asked Questions
You can get more detailed information about the Maritime implementation in Denmark in our FAQ (Frequently Asked Questions).