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EU ETS, CSRD, and IMO 2023: A Freight Compliance Checklist for 2026

By Mayur Rawte · · 12 min read · Updated

Three regulations now define freight carbon compliance in Europe, and most shippers I talk to still mix them up. The EU ETS puts a price on emissions, CSRD forces you to report them, and IMO's CII rates the ships themselves. They interact in ways that matter, and the 2026 deadlines are the ones you cannot afford to miss.

I'll take each one in turn, explain what it actually requires in plain language, and then — because this is the part people really need — lay out what a freight operator should have in place by the end of 2026 to avoid surprises. If you only read one section, read the one on CSRD Scope 3. That's where most of the unexpected pain is hiding.

EU ETS Maritime: the carbon market grows a sea leg

Since 1 January 2024, the EU Emissions Trading System has covered shipping. The mechanics were set in the 2023 revision of the ETS Directive (Article 3gd, if you want to be pedantic about it), and the phase-in runs on a three-year ramp: 40% of verified emissions had to be surrendered as allowances in 2024, 70% in 2025, and as of January 2026, the full 100%. Container ships, tankers, bulk carriers, and general cargo vessels above 5,000 gross tonnes calling at any EU port are in scope.

The coverage rule is a bit odd and worth memorising: 100% of emissions from intra-EU voyages, 50% from voyages with one endpoint outside the EU. A Rotterdam-to-Antwerp call is fully priced; a Rotterdam-to-New York call is priced on half its emissions. CO2 was the only gas in scope during 2024 and 2025. From 1 January 2026, methane and nitrous oxide join it, which matters disproportionately for LNG carriers because of methane slip.

The price tag is real. At recent EUA settlement prices around EUR 65-80 per tonne of CO2, a single 14,000-TEU container vessel running a weekly Asia-Europe service can face EUR 1-2 million in annual allowance costs, depending on the exact lanes it covers. Operators have mostly passed this through via fuel surcharges and CP clauses, but the accounting sits with the shipping company registered against the IMO number, not the charterer. If you're a cargo owner, check who holds the ETS liability in your contract of carriage — it is not always who you think. For chokepoint-rerouting cases that further change the ETS exposure profile, see how a Hormuz reroute reshapes the per-voyage allowance bill.

CSRD: Scope 3 is the trap

The Corporate Sustainability Reporting Directive (Directive 2022/2464) replaced the old Non-Financial Reporting Directive and dramatically widened the net. The phase-in runs from FY2024 reports (due 2025) for companies already under NFRD, to FY2025 reports (due 2026) for "large" undertakings meeting two of three thresholds — 250 employees, EUR 50M in revenue, or EUR 25M in total assets — and then to listed SMEs in FY2026. The European Commission's own estimate pegs the total affected population at around 50,000 companies once the rollout is complete, up from about 11,700 under NFRD.

For freight, the interesting clause is ESRS E1 disclosure requirement 6: mandatory Scope 3 reporting, including Category 4 (upstream transportation and distribution). If you're a manufacturer or retailer, the CO2e of every truck, ship, plane, and train that moves your goods is now on your balance sheet in reporting terms, even though you don't operate any of them. If you're a carrier, your customers will ask you for auditable per-shipment numbers aligned to ISO 14083. Some already are. Most will be, within 18 months.

The trap is that a lot of shippers are still reporting Scope 3 freight emissions with crude spend-based factors — "EUR 10,000 in ocean freight times X kg CO2e per euro" — which the EFRAG draft guidance explicitly flags as insufficient where more granular data is available. If your carriers are reporting per-shipment WTW emissions to you (and increasingly they are), your auditor will expect you to use those numbers, not a spend-based estimate. This is where I see the most expensive last-minute scrambles.

IMO CII: a letter grade for every ship

Since 2023, every cargo and passenger ship above 5,000 GT has received an annual Carbon Intensity Indicator rating from A to E, calculated as the ratio of grams of CO2 emitted per deadweight-tonne per nautical mile sailed. The reference lines come from MEPC 78 and tighten by 2% each year through 2026 — meaning a vessel that barely cleared C in 2023 will drift toward D or E by 2026 if it doesn't do anything differently.

The teeth are in the enforcement: a ship rated D for three consecutive years, or E for a single year, must file a corrective action plan through its Ship Energy Efficiency Management Plan. The corrective plan can include anything from route optimisation to engine retrofits, but flag states must approve it before the ship keeps trading. In practice, most major charterers now screen for CII rating when selecting vessels, and a D-rating has started to show up as a discount in time-charter fixtures. Whether IMO will harden the consequences at MEPC 84 is an open question; the current review cycle was supposed to conclude by end-2025 and slipped. The fuller view of what MEPC has and has not decided sits in our MEPC 82 outcomes write-up.

FuelEU Maritime: the one that bites the fuel chain

Running in parallel to the ETS, FuelEU Maritime (Regulation 2023/1805) caps the greenhouse gas intensity of the energy used by ships calling at EU ports, measured well-to-wake and expressed in grams of CO2-equivalent per megajoule. The 2020 baseline is 91.16 gCO2e/MJ, and the reduction targets are modest at the start and steep later: 2% in 2025, 6% in 2030, 14.5% in 2035, 31% in 2040, and 80% by 2050.

The main difference from the ETS is that FuelEU doesn't let you buy your way out with allowances — you either reduce the intensity of the fuel mix on your ships, pool compliance across a fleet (which is allowed), or pay a penalty per MJ of shortfall, currently EUR 2,400 per tonne of VLSFO-equivalent missed. In the next few years, that penalty is almost always cheaper than upgrading to bio-methanol or ammonia, so I'd expect most non-EU-domiciled operators to pay it rather than comply. Whether that remains true after 2030 depends entirely on biofuel availability and ammonia bunkering infrastructure, both of which are uncertain.

ISO 14083: the calculation standard that ties it all together

ISO 14083, published in March 2023, replaced EN 16258 as the international standard for quantifying emissions from transport chain operations. It aligns with GLEC Framework v3.2, covers all modes, and — critically for the regulations above — defines the data quality tiers that auditors use to distinguish "we looked it up in a table" from "we measured it on the vessel." CSRD-aligned auditors already expect ISO 14083-compliant methodology; IMO MRV reporting is being progressively harmonised with it; and the GLEC Declaration that large shippers ask for from their carriers is effectively an ISO 14083 attestation with a different brand on it.

If your emission reporting doesn't reference ISO 14083 or GLEC v3.2 anywhere in its methodology statement, that's the single easiest thing to fix before the next reporting cycle. It's a paper change, not an accounting change, and it forecloses an entire category of auditor questions.

Your actual 2026 checklist

Here's what I'd want in place by the end of Q3 2026, based on what I see slip most often:

  1. ETS scope audit. List every vessel above 5,000 GT that touches an EU port in your network, confirm which entity holds the ETS liability in the contract of carriage, and budget for 100% surrender as of January 2026 with CH4 and N2O included.
  2. CSRD threshold test. Run your entity through the two-of-three size test. If you're in, identify your Scope 3 Category 4 data gaps now, not when the auditor asks. Carrier-supplied per-shipment CO2e data beats spend-based factors every time, but only if you can reconcile it to your procurement records.
  3. CII rating review. Request the last 24 months of CII ratings from every operator in your preferred carrier list. Flag any D-rated ships and ask for the corrective action plan. If you can't get either, re-tender.
  4. FuelEU compliance position. If you control multiple vessels, model your fleet pool against the 2025 and 2030 targets. Most operators won't actively comply until 2028 — the penalty is cheaper than the alternative — but you need the number on paper to budget for it.
  5. ISO 14083 methodology statement. Ensure every emission calculation you publish references ISO 14083:2023 and GLEC Framework v3.2 explicitly. Your auditor will look for this first.
  6. Internal reconciliation. The single most useful thing you can do is reconcile three separate numbers for the same quarter: (a) the CO2e you report to your CSRD disclosure, (b) what your carriers tell you their ETS-surrendered tonnage was, and (c) what your procurement spend suggests under a crude spend-based method. If those three don't match to within ~15%, you have a data problem, not a reporting problem.

What this doesn't cover

Everything above is Europe-centric, for the obvious reason that Europe is where the regulation is. There are parallel developments — the UK is building its own ETS-equivalent, California's SB 253 requires Scope 3 disclosure for large companies doing business in the state from 2027, and the IMO's mid-term measures (a global levy or fuel standard) are scheduled for adoption in 2025 and entry into force in 2027. I've deliberately left those out because the rules are still being drafted and I don't want to write something that will be wrong in six months. When there's enough detail to say something useful, I'll update this post.

One regime that is binding in 2026 and that this checklist does not work through in depth is CBAM. CBAM is its own beast — carbon at the border, not in the operator P&L — and the freight-data implications for EU importers and their carriers deserve their own write-up rather than a paragraph here. If you're an EU importer of steel, aluminium, cement, fertiliser, hydrogen, or electricity, treat the CBAM checklist as a parallel obligation that runs on a different clock (annual declarations due 31 May the following year, first one due May 2027 for calendar 2026).

Sources

EU ETS maritime provisions: Directive 2003/87/EC as amended by Directive (EU) 2023/959, Article 3gd. CSRD: Directive (EU) 2022/2464, with the ESRS E1 standard published as Delegated Regulation (EU) 2023/2772. FuelEU Maritime: Regulation (EU) 2023/1805. IMO CII: MEPC 78 outcomes, including Resolution MEPC.352(78) and the associated CII Guidelines. ISO 14083:2023 — Quantification and reporting of greenhouse gas emissions arising from transport chain operations. GLEC Framework v3.2, Smart Freight Centre, 2023. EUA allowance prices referenced from EEX auction data. The commentary on auditor expectations reflects how I've actually seen Big Four assurance teams handle Scope 3 freight in the last two reporting cycles — there is no single published guide for this, which is part of the problem.

Related: a worked example of GLEC v3.2 in practice, which is the underlying methodology CSRD auditors expect. If you want to see what the numbers look like end-to-end on a real shipment, the EcoFreight calculator will export a per-leg breakdown ready for Scope 3 Category 4 disclosure.