UK Emissions Trading Scheme (UK ETS) Charging Scheme Consultation - Maritime Operators

With the addition of a new sector to the UK ETS, we need to establish suitable charges for regulating these activities.

Introduction of charges for maritime operators

The UK ETS is expanding to include emissions from the maritime sector. The UK ETS Authority consulted on this policy in detail in 2024 and published the interim response in July 2025 (UK ETS scope expansion: maritime sector - GOV.UK) confirming the scope and that SEPA will regulate Scottish-based maritime operators.

We plan to introduce charges for maritime operators to coincide with the launch of the UK ETS maritime regime on 1 July 2026. As we are consulting based on draft legislation, there may be some changes before the UK ETS maritime regime becomes law.

How we have calculated the charges

To set fair fees, we looked carefully at the work involved in regulating maritime operators under the UK ETS in Scotland. Our aim is to make sure charges are clear, reasonable, and based on the actual cost of regulation.

We followed three key principles when developing this approach:

• Fairness: Operators pay for the services they use, so one group does not subsidise another.

• Consistency: We have used our experience with aircraft operators as a guide, because the compliance requirements for maritime operators are very similar.

• Transparency: The charges reflect the real work needed, such as assessing applications, assessing submissions and reports and checking compliance.

Based on this review, we propose that charges for maritime operators will be broadly in line with those for aircraft operators, with small adjustments where needed for sector differences. We think this approach is simple, fair, and easy to understand.

As this is a new sector for the UK ETS, we will review the resources and charges once the system is up and running. This will make sure fees remain fair and continue to cover the cost of regulation without overcharging operators.

These principles guided the development of the proposed charges outlined in Section 5. In particular, the use of aviation sector benchmarks has helped ensure consistency and fairness. While the charges are broadly aligned with those for aircraft operators, small adjustments have been made to reflect the specific regulatory needs of the maritime sector. This approach ensures that maritime charges are proportionate and in line with similar UK ETS regimes.

We understand that charges may vary slightly across UK administrations depending on local regulatory arrangements. However, our approach is consistent with the principles applied elsewhere, providing reassurance that the proposals are not out of step with broader UK ETS practices.

What are the charges / components for the new scheme?

The following summarises the proposed amendments to the ETS Charging Scheme.

Maritime operator charges 

The proposed charges include:

• Application fee – for submitting an Emissions Monitoring Plan (EMP) for approval - £2,833.
• Variation fee – where EMP varied to include new vessel - £1,356
• Variation fee – for making changes to an existing EMP - £1,356.
• EMP Resubmission fee – where SEPA  serves a notice requiring a maritime operator to submit a revised EMP - £1,356
• Annual subsistence charge – to cover ongoing regulatory work - £2,932.
• Pro-rata adjustments – if an EMP starts or ends part-way through the year.
• Hourly rate – for additional regulatory work, such as complex determinations or specialist queries - £146.

This structure is designed to be clear, predictable, and based on the actual work required to regulate the sector. It also ensures that costs are fairly allocated to those who create them, in line with the polluter pays principle.

Amendment to the Hourly Rate 

The ETS Charging Scheme currently includes an ‘hourly rate’ under paragraph 12, for certain activities that fall outside standard charges. We propose updating the wording of paragraph 12 so that it also covers maritime-related activities where this is appropriate.

Specifically, we will revise the text under paragraph 12.1 of the ETS Charging Scheme to make it clear that the hourly rate can be applied to maritime operators for time spent by us making a determination of maritime emissions or emissions figure for surrender under the UK ETS maritime regime. This ensures consistency across all sectors and provides flexibility to recover costs for work that cannot be covered by fixed fees.

Pro-rata charges for subsistence fees

If an emissions monitoring plan is approved (e.g. a successful application) part way through the year, the charges will be calculated on a proportional basis for the remaining period until the end of the year.

Other changes

We plan to make amendments to paragraph 2 (Interpretation), paragraph 14 (Liability to pay charges) and 15 (Time to make payment of charges) for additional clarity

Increases in charges

The ETS Charging Scheme states that we may increase charges annually by up to any increase in the Office for National Statistics measures of inflation as of 30 September in the immediately preceding year. The figures quoted in this consultation are subject to any increase applied on 1 April 2026.