Making emissions data verification manageable at scale

The FuelEU Maritime regulation has been in force since 1 January 2025, and the due date for verification of the first year’s emissions data at the end of April is imminent.

FuelEU Maritime adds reporting complexity

FuelEU Maritime (FEUM) has brought the number of emissions reporting obligations for ships operating in European waters to four, along with IMO DCS as well as EU MRV and ETS. The UK’s own MRV and ETS reports and any pooling arrangements under FEUM add further complexity. “Customers are finding it challenging to meet the verification due date,” says Conrad Golebski, Global Sales Manager, MRV, DCS, and FuelEU Maritime at DNV. “But non-compliance results in costs, which can be quite high for vessels that do not meet the emission targets.”

Data quality issues are widely underestimated

Preparing the document of compliance for the regulatory authorities has been an annual exercise – and a very stressful one, emphasizes Golebski. “The verification process has been anything but smooth because there are typically many quality issues in the data submitted after the end of the year. Shipping companies often underestimate the data quality issue and are surprised when the verification cycle starts and they are inundated with correction requests.

“Rectifying these issues can be a complex and time‑consuming process, involving an intense communication exchange before verification can proceed.”

There are two types of error that compromise data quality, says Golebski. “Human data entry errors must be corrected one by one. Systematic errors will affect the data of the entire fleet, and detecting and correcting them as early as possible will make a big difference towards minimizing the rectification effort.”

Fleet of 900 vessels verified well ahead of the due date

The long‑standing partnership between DNV and Mediterranean Shipping Company (MSC) is a good example of how regulatory complexity can become manageable by building trust and taking a methodical approach to the compliance challenge. “DNV has been MSC’s verifier since 2018, when the fleet under verification comprised approximately 480 vessels,” describes Golebski. “What began with EU MRV and IMO DCS has evolved into one of the most comprehensive verification scopes in the maritime industry.” For the 2025–2026 verification cycle, DNV successfully completed the verification of all MSC reporting obligations across EU MRV, EU ETS, IMO DCS, FuelEU Maritime as well as FuelEU pooling, covering more than 900 vessels and over 2,000 individual reports, within a three-month verification window.

Continuous emissions data submission enables early, high quality verification

This was only possible because MSC consistently tracked all emissions data from its entire fleet throughout the year and corrected all data quality issues in the process. “Clients who choose to upload their ships’ emissions data to the OVD Admin continuously throughout the year instead of waiting until January can benefit from our quality checking algorithms and make the necessary corrections as they go,” Golebski points out. “This will make the actual verification step the following spring much more comfortable and avoid missing the submission deadline.”

From the DNV warehouse, the data can be distributed to the client-requested services, such as Fleet Status, Emissions Insight, the DCS-, MRV-, and FEUM-specific applications, or Emissions Connect. “It is this centralized digital concept that makes our system so convenient,” says Golebski. “We maintain and update our infrastructure constantly to account for client needs and improve user-friendliness.

“At the end, MSC was able to submit to us data of very good quality. Of course, with a fleet of 900 ships, it’s impossible to have everything perfect at first. But compared to the previous process, we were able to process all the vessels well ahead of the deadline. This was a great accomplishment, especially with the addition of FuelEU Maritime, a completely new regulation nobody knew how to implement.”

More personnel and new checks ensure prompt attention to client needs

MSC confirms: “Managing compliance for a fleet of this size, across multiple new and evolving regulations, is a significant challenge. The close cooperation with DNV and the structured approach on both sides allowed us to complete this verification cycle successfully and on time.”

In view of the new regulation, DNV had significantly increased its core verification and governance teams and provided a liaison to each key customer as a point of contact for questions and issues. “We now have about 120 people dedicated to our core greenhouse gas compliance work, with individual groups assigned to each DNV region,” says Golebski. “We were able to develop new checks this year to better respond to customer needs. This was key to completing the verification cycle early.”

Contships Management ensures timely reporting amid fleet renewal programme

For Contships Management Inc., the world’s largest independent owner of feeder container ships between 900 and 1,500 TEU, the verification timeline was especially stringent as the company was selling assets as part of its fleet renewal effort, says Margarita Kourounioti, Sustainability and Compliance Manager at Contships. “This year’s collaboration with DNV has been one of continuous engagement and real, measurable progress. Contships’ fleet renewal programme, which saw the sale of multiple vessels, brought immediate FuelEU Maritime obligations and fostered an ongoing dialogue with the verification team that ultimately strengthened the process. With enhanced data quality checks, a structured pre-verification phase, and dedicated support, this verification period was the most efficient to date, ensuring emissions data was verified and available well ahead of regulatory deadlines, in line with the early access that charterers and investors now consider standard practice.”

Comprehensive IT infrastructure enables a fully digital process

DNV has also invested substantially in its IT infrastructure and built integration APIs for all leading performance management systems for Data Workbench. “Our service was the first fully digital verification service available at DNV, thanks to API integrations, monitoring plan generators, and online forms,” says Golebski. “All this makes it very easy for clients to work with us and benefit from the automated processes on Veracity that other companies still do manually. What is more, digital data collection and processing ensure consistency, quality, and continuous feedback. All that saves time.”

A statement echoed by DNV client Neptune Lines, which specializes in pure car/truck carriers: “DNV delivers smooth verification through strong tools, true partnership, and continuously leading‑edge services,” says Sonia Lavranou, Energy Efficiency Engineer at Neptune.

Monitoring plan generator speeds up mandatory process

Under the EU MRV and ETS regulations, shipowners and managers are required to submit ship-specific emissions monitoring plans to the administering authority annually. Monitoring plans specify how the company intends to monitor and collect the data, the fuel types used, and other data. They can be created conveniently using DNV’s Plan Generator, also called EU MRV Monitoring Plan Online Form, which is available on the My Services portal under “Actions”. It allows users to edit their digital data conveniently online.

Proactive strategy is key to timely submission of document of compliance

Bernhard Schulte Shipmanagement (BSM) likewise benefited from DNV’s proactive and fully digital process, the company says. “The DNV team’s support throughout our FuelEU verification was outstanding. From the early documentation pre‑checks to resolving queries and completing the verification with accurate numbers, their diligence and proactive communication were evident at every step. The collaboration between our teams worked extremely well, and it was a pleasure to work with them.”

BSM has been among the few companies with well‑defined procedures and compliance achieved ahead of deadlines, Golebski points out. Both are important for ESG and sustainability reporting. “Carbon emissions carry a growing financial liability,” he stresses. “We advise all our customers to make sure their data is as accurate as possible to avoid overpaying for emissions. As maritime decarbonization regulations continue to expand in scope and ambition, our successful cooperations show what is possible for any kind of fleet size when shipowners and verifiers work as long‑term partners rather than transactional counterparts.”