Nordisk Circular
February 2026
UK ETS Expansion to Include Maritime Emissions
The UK Government has confirmed that domestic maritime emissions will enter the UK ETS scheme from 1 July 2026, advancing the Government’s decarbonisation agenda
The UK Government has confirmed key details of its plan to bring domestic maritime emissions into the UK Emissions Trading Scheme (UK ETS) from 1 July 2026, marking a significant step in the country’s decarbonisation strategy.
Scope and Applicability
- It will apply (for now) to vessels of 5,000 GT and above on domestic voyages and in-port emissions.
- The first surrender deadline is 30 April 2028, which applies to both the 2026 and 2027 reporting periods. Although the surrender deadline for the 2027 reporting period is deferred, annual reports must be submitted within the usual timeframe, by 31 March 2027.
- Threshold review planned for 2028, with potential extension to smaller vessels (from 400 GT).
- Of particular importance to Nordisk Members is the inclusion of off-shore vessels as from 1 January 2027. This aligns with the EU ETS timeline.
- The responsible entity under the UK ETS mirrors that of the EU ETS, being the registered owner unless the ISM Company has agreed to assume responsibility for compliance.
Future Expansion
- Influenced by the delayed IMO decision on its Net Zero Framework, the UK Government confirmed its intention to move forward with its own measures to include international emissions. Thus, international voyages could be included from 2028. A formal link between the UK ETS and EU ETS is under discussion, which if successful, will hopefully allow mutual recognition of allowances and harmonised reporting.
Key Provisions
- Voyages between mainland UK and Northern Ireland will count at 50%, to avoid disparity between the carbon pricing of voyages from Great Britain to Northern Ireland and the Republic of Ireland.
- Exemptions: Ferry services to Scottish islands and peninsular communities, as well as fish catching and processing vessels, remain outside the scheme for now. A review is scheduled for 2028.
- No requirement for a Document of Compliance or port state control checks; instead, compliance will be managed through the UK ETS registry and management system.
Compliance and Monitoring
- Owners (i.e. the responsible entity) must monitor, report, and verify emissions under UK ETS rules, which will include CO₂, methane, and nitrous oxide. Methane and nitrous Oxide will be converted into CO2e based on their global warming potential. This mirrors the EU ETS which expanded to include methane and nitrous oxide from 1 January 2026.
- A simplified approach will apply for ships conducting more than 300 similar domestic voyages annually.
Why It Matters
The expansion of the UK ETS introduces carbon pricing for shipping in UK waters, creating cost incentives for cleaner fuels and operational efficiency.
With the delay to the vote on the IMO’s Net Zero Framework, it is expected that more regional schemes such as the UK ETS will begin to emerge. Given the potential expansion of the UK ETS to international voyages, linkage to the EU ETS is important to reduce the administrative burden on owners and avoid double exposure.
The UK government has also committed to reviewing the interaction of the UK ETS with the IMO Net Zero Framework, once the IMO scheme is adopted.
For full details, see the UK Government’s Authority Response.
In this issue
Written by:
Vicki Tarbet
Solicitor (England & Wales)
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