The 2025 EUA surrender showed that last-minute compliance is costly.
2024 EUA Surrender: Shipping’s first compliance test
The 2025 EUA surrender showed that last-minute compliance is costly.
The 30 September 2025 deadline has passed. For the first time, owners and operators of vessels over 5,000 GT that called at EU or EEA ports during 2024 were required to report their CO₂ emissions, purchase, and surrender carbon allowances (EUAs) covering 40% of those emissions under the EU Emissions Trading System (EU ETS).
As expected, the run up to the compliance deadline saw a flurry of last-minute activity. Many shipowners and managers scrambled at the last moment to buy allowances, accepting spot prices the market was offering. Having averaged around EUR 71.60 per EUA from January through to end September 2025, prices rose above EUR 76.00 average per EUA in the final 10 days of the month as demand spiked.
The EU ETS has turned emissions into a measurable financial factor for shipping. Compliance costs now require active management alongside operational and regulatory obligations. A planned, proactive approach to EUA procurement can significantly reduce costs.
In 2024, verified shipping emissions totalled around 33 million tonnes, a small fraction of the EU ETS market’s 1.1 billion tonnes. Even with the share of covered emissions rising to 70% in 2025, pushing shipping’s EUA demand to around 62 million tonnes, this remains a relatively minor slice of the total.
EUA pricing is driven primarily by:
• EU climate and energy policies
• Auction volumes and EUA supply
• EU industrial output and energy consumption
• Seasonal weather patterns
Speculative trading, compliance activity and geopolitical developments
Given this, even large shipping companies cannot influence EUA prices. Strategic planning and execution efficiency are therefore essential.
Many shipping companies currently treat EUA costs as pass-through expenses to charterers. While contractually valid, this approach is not necessarily cost-efficient. Most companies already have visibility of their EUA exposure for the coming year, creating opportunities to adopt structured procurement strategies.
Primary EUA supply is released via weekly auctions that feed into secondary markets where most shipping businesses purchase allowances. This provides ample opportunity to spread procurement over time. In one example, a company requiring over 1 million EUAs annually executed purchases in blocks across the year rather than bulk-buying at peak prices in January or September. The approach achieved savings of more than EUR 8m, even after factoring in execution and trading costs.
Operators with less certainty over their EUA requirements can use flexible solutions such as purchasing through third parties who warehouse allowances and allocate them as needed. This ensures timely compliance, avoids penalties and reduces exposure to potential year-end price spikes.
Compliance obligations are set to grow. The FuelEU Maritime Regulation is now in force, and the IMO’s Net Zero Framework - expected to be adopted in October - will introduce further requirements from 2028 onwards.
The direction is clear: the cost of emitting is increasing, regulations are tightening, and financial exposure for shipping is expanding.
The experience of 2025 shows that last-minute compliance is expensive compliance. A reactive approach to EUA surrender may have been manageable this year, but costs are expected to rise as regulations intensify and prices increase.
A planned, data-driven, and strategically executed approach to EUA procurement reduces costs, minimises volatility, and ensures readiness for future regulatory developments.
Maritime Carbon Solutions (MCS) provides shipping clients with emissions estimates, real-time vessel emissions data, and access to carbon markets. Through its partnership with ClearBlue Markets, MCS combines shipping expertise with carbon market intelligence to support cost-efficient compliance strategies under the EU ETS and future regulatory frameworks.