Owners must balance profitability and sustainability by carefully choosing when to invest, what type of emission-reducing measures to implement, and how much to spend on them. © BSM

“Emissions reporting in the shipping industry is increasingly fragmented. Each regulatory framework tends to apply its own approach to calculating, collecting and verifying emissions, resulting in often parallel systems,” says Anil Jacob, Head of Fleet Performance and responsible for BSM’s Emission Management Services. “It’s unbelievable how much has come into force in just the last few years.”

Where we stand today: a tangle of frameworks

The current regulatory environment is mainly shaped by two bodies, the International Maritime Organization (IMO) and the European Union (EU).

The IMO mandates several global frameworks, including:

  • Emission Control Areas (ECAs): Designated sea areas with stricter limits on sulphur oxides (SOx) and nitrogen oxides (NOx) emissions (e.g., parts of Europe and North America).
  • Energy Efficiency Design Index (EEDI): Applies to newbuildings, requiring improved energy efficiency in ship design.
  • Data Collection System (DCS): Requires vessels to monitor and report data on fuel consumption, voyage details and emissions.
  • Energy Efficiency Existing Ship Index (EEXI): Establishes the actual energy efficiency of a vessel and determines compliance.
  • Carbon Intensity Indicator (CII) framework: Measures a ship’s annual operational carbon intensity and sets reduction targets to improve its rating over time.

The EU adds further regulatory layers for vessels calling at its ports:

  • Monitoring, Reporting and Verification (EU MRV): Requires vessels to monitor and report fuel consumption, emissions and other voyage data on EU-related voyages.
  • Emission Trading Scheme (EU ETS): Obliges vessels to buy and surrender Emission Allowance Certificates based on their emissions.
  • FuelEU Maritime Regulation (FEUM): Mandates a gradual reduction in the greenhouse gas intensity of energy used. Compliance can involve alternative fuels, banking and borrowing, or pooling.

The United Kingdom (UK) also requires participation in its UK MRV system.

Looking at 2026: revision and expansion

The IMO will review and likely tighten both the EEXI and CII frameworks, with possible enforcement measures introduced.

For the EU ETS, shipping companies will need to surrender allowances for 70% of their reported emissions in 2025 (up from 40% in 2024). From 2027 onwards, 100% of emissions will be covered.

Similarly, the UK will implement its own UK ETS, requiring vessels calling at UK ports to buy and surrender emission allowances.

From 2027: all eyes on the IMO Net-Zero Framework

Coming into effect in 2027, the IMO Net-Zero Framework introduces two key global measures. The core elements were agreed at the 83rd session of the IMO's Marine Environment Protection Committee (MEPC 83) in April 2025, with formal adoption expected in October 2025.

Under this framework, ships will need to comply with:

  • Global fuel standard: Ships must progressively reduce their annual greenhouse gas fuel intensity (GFI)—the GHG emitted per unit of energy used.
  • Global economic measure: Ships exceeding GFI limits must purchase remedial units to offset emissions. Conversely, ships using zero or near-zero GHG technologies may receive financial incentives.

“Given the highly divergent positions of over 100 participating nations, the current agreement can be considered a solid foundation,” says Anil Jacob.

Notably, the amended position on the issue of the responsible party was not reversed: by default, compliance responsibility lies with the ship itself, not the Document of Compliance holder. There is also a provision allowing upstream cost recovery from Commercial Managers, who typically order the fuel. “This turns the system into a ‘polluter pays’ framework—an important outcome for ship owners. This is positive news for both ship owners and managers,” he adds.

Owner challenges

Anil Jacob and his team of BSM’s Fleet Performance Centre have identified three key challenges for ship owners:

  1. Rising resource needs: It takes significant resources and careful planning to interpret and navigate the sheer volume of regulations, particularly as the forthcoming MEPC framework will not replace any of the existing regional systems. It will come as a new global layer of mandatory emissions limits and GHG pricing.
  2. The digital divide: Much of the global fleet still lacks digitalisation. Yet, digital tools are essential not only for accurate data collection, transparency and regulatory compliance but also for effective charter party negotiations.
  3. Balancing profitability and compliance: Owners must strike a careful balance between commercial performance and sustainability. Key questions are: What investments and measures will ensure compliance? When should owners act quickly—and when should they wait?
Our solutions

“We understand compliance and we are here to guide our clients through it. Think of it as a ‘thought partnership’,” says Jacob.

Transparency through a holistic outlook
“We assess all international and regional regulations as a connected whole – wherever possible – and give our clients full transparency on what lies ahead. Every client receives a five-year compliance outlook and cost projection, supported by 24/7 access to our LiveFleet performance monitoring platform. In short, we co-create solutions with our clients,” he explains.

Efficiency through digitalisation and collaboration
“Our data management approach is built on digitalisation and strategic partnerships.” For example, BSM collaborates with DNV’s Veracity platform and Berenberg to streamline EUA trading. “This integration enables verified emissions data from across the managed fleet to be directly translated into EUA purchase offers—greatly reducing manual effort,” underlines Jacob.
BSM also supports clients with a dedicated FuelEU Dashboard which forecasts each vessel’s compliance balance and simulates strategies for reducing exposure—such as biofuels or flexibility mechanisms. Based on these simulations, BSM recommends the most suitable compliance strategy, including pooling options.

“The experience of recent years has shown that digitalising data collection and sharing is key to making all our lives easier. We’re committed to continuing on this path at full speed. The more we automate, the better we can simplify compliance and help our clients stay profitable,” Jacob concludes.

bsm_fpc_infographic.jpg

Visualisation of BSM’s data flow, synchronisation and compliance map. © BSM

Anil Jacob

BSM’s Head of Fleet Performance

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