Field visits under UK ETS (United Kingdom Emissions Trading System) are a crucial part of the annual verification process of Annual Emissions Reports (AER). Without these visits, the verifier will not be able to validate the AER. The location and scope of these visits are determined based on the verifier's risk analysis and will focus on monitoring and managing related emissions data. A field visit does not necessarily require attendance on every vessel or at every location, and DNV's default approach is to visit the ISM company.
Details of Field Visits and Their Requirements
An in-person field visit is typically expected. A virtual visit will only be conducted if the verifier concludes that they can provide reasonable assurance and the marine operator receives approval from the regulatory body. The operator's request for a virtual visit must include information provided by the verifier, such as the results of the risk analysis, and must be submitted by February 28 of the following year. For example, if emissions are reported for the year 2027, the request for a virtual visit must be submitted by February 28, 2028, at the latest.
Read more: DT Midstream has launched gas development plans in the Midwest
Timelines and Deadlines
A field visit is a prerequisite for finalizing the AER verification. Since the AER must be verified by March 31, 2027, for the first reporting period of UK ETS (from July 1 to December 31, 2026), DNV recommends that the field visit be conducted by the end of February 2027. DNV also recommends that UK ETS field visits be coordinated with other planned verification activities, such as EU MRV, FuelEU Maritime, and related ISM audits, where possible, to reduce duplication and complexities.
Operators must prepare the necessary documentation for verification, which includes: • Approved Emissions Monitoring Plan (EMP) • Verifier's risk analysis • Data transfer activities and control procedures • Approval from the relevant regulatory body for a virtual visit • A complete list of vessels covered by the marine operator's AER • Verification report from the previous year (if verified by another verifier).
The EMP is maintained at the company level and describes the monitoring methodology, the vessels under the operator's responsibility, and the related emissions sources. Vessel emissions are generally aggregated into a company-level AER that must be verified before submission to the regulatory body.
Our current verification method requires the verification of vessel-level emissions reports from the operator's fleet by DNV. Supporting documentation, including usable cargo samples, bunker delivery notes (BDN), and proof of sustainability (POS), must be submitted through OVD Admin DNV in My Services. The AER at the company level will be created based on the marine operator's fleet in the My Services portal. Verification will only occur after the necessary field visit, EMP verification, and submission of the vessel list and underlying vessel-level information.
We are further developing a combined verification approach at both the company and vessel levels for UK ETS. Additional practical information regarding the process and necessary actions from the client will be communicated as soon as the approach is finalized.
Some recommendations include: early planning for UK ETS field visits and, where possible, combining them with EU MRV visits or FuelEU Maritime. Ensuring the approval of the Emissions Monitoring Plan (EMP). Preparing necessary documentation, including risk assessment, data transfer activities, and related procedures. Early engagement with DNV to support the planning of field visits and annual verification activities.
Read more: Ukraine has halted attacks on Russian oil refineries
