Introduction

The countdown to 30 September 2025 has begun.

For the first time under the EU ETS, maritime operators must surrender 40 % of their verified 2024 CO₂ emissions in EU Allowances (EUAs). Missing the date triggers an automatic €100 per-tonne fine plus mandatory back-payment of the missing EUAs—an expensive double hit.

Yet compliance is about more than just buying allowances: your Monitoring Plan, emissions data, and MOHA (Maritime Operator Holding Account) all have to align perfectly, or the Registry will block transactions when you need them most. Liquidity is already thinning and spot prices tend to spike in the final weeks.

The checklist below breaks down what should already be done and what must happen next—so you can surrender on time and at the lowest possible cost.

Tasks Already Completed (By April 2025)

• EU-ETS Monitoring Plan submitted and approved by AA (by 06 June 2025)
• Vessel-level emissions reports prepared and verified (by 31 March 2025)
• Company-level Emissions Report submitted and verified (by 31 March 2025)
• Verified emissions data entered into THETISMRV and the Union Registry (MOHA) (by 1 April 2025)

Pending Tasks

With the surrender deadline approaching, these actions are still required:

• Calculate EUA Surrender Obligation: 40% of verified 2024 emissions (phase-in rule)

• Purchase EUAs: Secure allowances via auction or secondary market to meet your obligation

• Open MOHA Account: Ensure your Maritime Operator Holding Account is active with the climate registry of your attributed EU member state

• Surrender EUAs via MOHA: Complete the transaction for surrendering allowances (by 30 September)

• Maintain MOHA Access: Confirm account is not blocked or restricted

Common reasons for blockages:

• Missing/invalid emissions data or monitoring plan

• Failure to maintain KYC credentials or registry roles

• Legal issues or unpaid fees

What Happens If You Miss the Deadline?

Delay or failure to complete any of the above tasks risk:

• Penalties: €100 per ton of CO₂eq not surrendered, additionally missing EUAs also to be surrendered. Public disclosure of defaulting company and blacklisting risk.
• MOHA restrictions: Blocked registry access may prevent EUA transactions until issues are cleared
• Expulsion order: Failure to surrender EUAs for 2 or more consecutive reporting periods can be denied EU port entry or detailed until compliance is achieved.

Why EUA Prices Might Spike in September

Traders, exchanges, and analysts are warning of a liquidity squeeze as the surrender date approaches. Spot EUAs may become harder to source, and latecomers could face inflated prices.

Procurement teams that delay might find themselves:

• Competing for thin spot volumes

• Facing longer execution times

• Unable to secure trusted account connections in time

What Full Compliance in September Really Demands

Submission of your emissions data was only the first half of the equation. September compliance now depends on:

• Fast and secure EUA sourcing

• Timely registry access and surrender

• Ongoing communications with your Administering Authority

How Azolla Can Support Last-Mile EUA Compliance

Azolla supports operators with last-mile compliance by:

• Procuring spot EUAs at near-exchange prices through our requisition platform

• Ensuring direct delivery into your MOHA, avoiding delays or trust list errors

• Providing same-day confirmations, even when market liquidity tightens

• Helping you meet surrender deadlines without exchange access

Reach out to us for more details ets@azolla.sg