EU MRV monitoring plan: contents, methods and assessment

The EU MRV article describes the yearly cycle in one line — monitoring plan, per-voyage monitoring, aggregation, verification, submission, document of compliance. This page opens the first step. The monitoring plan is the document a company writes before a ship's first in-scope voyage, describing how that ship will measure everything the Regulation asks for; a verifier assesses it for conformity, and every later step of the cycle is checked against it. It is a process document, not a calculation, so there is nothing here to compute: its authority is what Regulation (EU) 2015/757 says it must contain, how it is assessed, and when it must change.

What the plan is, and when it is due

Article 6 of the Regulation requires a company to submit to a verifier a monitoring plan for each of its ships, indicating the method chosen to monitor and report emissions and the other relevant information Reg (EU) 2015/757 · Arts 6–10 ↗. For a ship that comes into scope, the plan is submitted without undue delay and no later than two months after the ship's first call at a port under the jurisdiction of a Member State. Plans are drafted and submitted in the electronic template held in THETIS-MRV, whose current form is laid down in Commission Implementing Regulation (EU) 2023/2449 Impl. Reg (EU) 2023/2449 ↗. Since the 2023 revision the plan covers methane and nitrous oxide as well as carbon dioxide Reg (EU) 2023/957 ↗.

What goes in it

Article 6(3) lists the minimum content Reg (EU) 2015/757 · Arts 6–10 ↗. In the order the Regulation gives it:

• Ship identification — name, IMO number, port of registry or home port, and the owner — and the company's name with the address, telephone and e-mail of a contact person.
• Emission sources on board — main engines, auxiliary engines, gas turbines, boilers and inert gas generators — and the fuel types they use, with the procedures for keeping that list up to date through the reporting period.
• Completeness of voyages — the procedures used to make sure every voyage is monitored and none is missed.
• Fuel-consumption monitoring — the chosen Annex I method for each emission source, the procedures for measuring fuel uplifts and fuel in tanks, a description of the measurement instruments, and the procedures for recording, retrieving, transmitting and storing the fuel data — together with the uncertainty associated with the method.
• Emission factors — the factors applied per fuel type, or the method for determining them for fuels that have no default.
• Activity data — the procedures for determining distance travelled, time at sea and cargo carried per voyage.
• Data gaps — the method for determining surrogate data where data are missing.
• A revision record sheet recording every change to the plan.

The list is short; the difficulty is that each item describes a procedure the ship must then follow for a full year. The method item is where most of the practical choices sit, and Annex I gives four options.

Method	Basis	What the plan must specify
A	Bunker delivery notes (BDN) combined with periodic stocktakes of the fuel tanks by tank readings	The uncertainty of the BDN quantities and the tank-sounding method and its uncertainty
B	Bunker fuel tank monitoring on board — daily tank readings giving the cumulative fuel used	The reading method and instruments and their uncertainty
C	Flow meters measuring fuel flow to the applicable combustion processes	The meters covering each source, their calibration and uncertainty
D	Direct measurement of emissions in the exhaust gas stacks	The measurement equipment and its uncertainty; used alone or combined where it improves accuracy

Reference facts, cited — not engine coefficients. Reg (EU) 2015/757 · Annex I ↗

Once a method is chosen for a source it is applied consistently for the whole period; a combination of methods may be used where the verifier has assessed it and it improves the overall accuracy of the measurement Reg (EU) 2015/757 · Annex I ↗.

What the verifier checks

The plan is assessed before the reporting period begins, and this is a separate step from the verification of the yearly emissions report that the MRV article describes. Under Article 13 the verifier assesses whether the monitoring plan conforms to Articles 6 and 7 Reg (EU) 2015/757 · Arts 13–16 ↗: that every required element is present, that the chosen method and instruments are ones the ship can actually operate for each emission source, and that the procedures described would produce complete, consistent data. Where the assessment identifies non-conformities, the company revises the plan and submits it for a final assessment, within a timeframe agreed with the verifier but before the reporting period starts. The wording matters: the verifier assesses the plan's conformity with the Regulation; it does not approve the ship or certify its compliance. That comes a year later, when the same plan is the yardstick for the emissions report.

When the plan must change

Article 7 makes the plan a living document Reg (EU) 2015/757 · Art. 7 ↗. It has to be modified when the ship changes company; when a new emission source or a new fuel type appears on board that the plan does not yet cover; when new measurement instruments, sampling or analysis methods change the accuracy of the data available; when the data produced by the chosen method are found to be incorrect; or when the verifier has found part of the plan not in conformity and asks for a revision. The company notifies the verifier of the proposed modification without undue delay, and the material modifications are assessed by the verifier before the modified plan is relied on — the same assessment loop as the original plan, recorded on the revision sheet.

Last reviewed 28 August 2026 · Carbonlogy Compliance Team

How Carbonlogy applies it

Once a plan is in force, the platform's job is fidelity to it. Each voyage carries its ports of call and MRV scope, its fuel by type and the distance and time the plan says will be recorded; validation flags a voyage missing any of them before it reaches the year-end report. At year end the per-ship emissions report and the THETIS-MRV submission are generated from that ledger, so the figures the verifier compares with the plan are the figures the ship actually reported, with no re-keying in between.