For shipping companies operating under the EU Emissions Trading System (EU ETS), EU Allowances (EUAs) have quickly become more than aregulatory requirement. They are now a significant and increasingly visible cost of operating a vessel in European waters.
With the 30 September surrender deadline approaching, thequestion for many fleet managers is straightforward: When is the right time to buy EUAs?
There is no simple answer. EUA prices are influenced by energy markets, industrial activity, regulatory developments, supply dynamics and broader market sentiment. But one pattern has become increasingly relevant for shipping: the timing of compliance demand throughout the year.
Understanding that pattern can help companies avoid leavinga large EUA purchase until the last minute, when market conditions may be less favourable.
The EUA market has changed significantly
The price of an EUA has evolved considerably over the past decade. After years of relatively low prices, the market entered a new phase from around 2018 onwards as the EU ETS was strengthened and the supply of allowances became progressively tighter.
Prices moved from around €20–25/t in 2019–2020 to approximately €53/t in 2021 and around €80/t in 2022. In 2023, EUA prices reached an all-time high of more than €105/t before correcting as industrial activity weakened and energy markets normalised.
After falling through 2024, prices recovered during 2025 and into 2026. By August 2026, EUA prices were again trading around the €80/tlevel, following significant movements throughout the year.
The longer-term direction is important, but for fleet managers there is another question that matters just as much: How does the price behave during the year?
From April to September: the compliance cycle has shifted
Historically, the EU ETS compliance cycle created a strong demand period in the first part of the year. Companies had to surrender their allowances by 30 April, meaning that the months leading up to the deadline often saw increased demand for EUAs
That changed with the revised EU ETS compliance calendar. Since 2024, the surrender deadline has moved to 30 September. For shipping companies, the annual cycle now means that emissions from the previous year are verified by the end of March, while the corresponding allowances must be surrendered by 30 September.
This has effectively shifted the focus of compliance demandtowards the second and third quarters. As September approaches, companies that still have an EUAdeficit need to enter the market and close their positions. This can create additional demand during a period when market participants are already closely watching the balance between available supply and expected compliance requirements. In other words, the compliance deadline itself can become a market driver.
What does the seasonal pattern tell us?
Looking at the past few years, there is no guaranteed “cheap month” for EUAs. Prices can move sharply in either direction based on factors outside the compliance cycle. However, the market does show a recurring dynamic:
- Early in the year:
Compliance-related buying pressure is generally lower following the previous year's surrender cycle. Prices are therefore more heavily influenced by energy markets, macroeconomic conditions, industrial demand and regulatory developments.
- Spring:
New emissions data becomes available and companies gain a clearer picture oftheir expected compliance position. This is an important period for assessing how many allowances will ultimately be required.
- Summer:
As the September deadline gets closer, companies with outstanding positions increasingly need to consider their EUA exposure. At the same time, market participants are responding to developments such as the annual Total Number of Allowances in Circulation (TNAC) announcement and changes to auction supply.
In 2026, the European Commission confirmed that approximately 190.5 million allowances will be placed into the Market Stability Reserve between September 2026 and August 2027, reducing the volume of allowances entering the market through auctions.
- August–September:
This is where the compliance clock becomes particularly relevant. Companies that have waited to cover their positions are increasingly exposed to whatever the market price happens to be at that point.
And that leads to an important point for fleet managers: The risk is not the deadline. The risk is waiting for the deadline.
Why waiting until 30 September can be costly
There is nothing inherently wrong with buying EUAs close tothe surrender deadline. The problem is that waiting removes flexibility. If a company knows that it will need a significant number ofallowances, delaying the entire purchase until September means accepting themarket price available at that exact moment.
That price could be lower. But it could also be higher.
A combination of higher energy prices, tighter allowance supply, stronger compliance demand or an unexpected regulatory development canmove the market quickly. And once a company is approaching its surrender deadline, there is little room to wait for conditions to improve.
For a fleet with a substantial EUA requirement, even a relatively small price movement can translate into a meaningful difference intotal compliance cost. This is why a more structured approach can make sense: monitor the position throughout the year, understand the expected requirement,and avoid turning EUA purchasing into a last-minute transaction.
Rather than trying to identify the perfect day to buy, companies can consider building their position progressively and making purchasing decisions based on their actual exposure.
Compliance starts with visibility
For fleet managers and owners, however, the challenge is not only the EUA price.
It is also knowing how many EUAs are actually needed, where they need to be allocated, what has already been purchased and what remains outstanding
When this information is spread across spreadsheets, emails, different stakeholders and separate systems, it becomes difficult to maintain a clear picture of the fleet's overall position.
This is where digitalisation can make a practical difference.
Stay ahead of your EUA position
As carbon pricing becomes an increasingly important part of shipping compliance, having a clear view of your EUA position is key. The goal isn't to predict the market perfectly, but to understand your exposure early enough to make informed purchasing decisions, rather than being forced to actas the deadline approaches.
The Njord Digital Platform brings EUA management into one place. Through Njord Compliance, fleet managers can get a real-time overview of their EUA position across the fleet, including allowances required, purchased and allocated, with the ability to drill down into individual vessels or accounts.
When additional EUAs are needed, they can be purchased directly through the platform and assigned to the relevant account or vessel. By connecting visibility and action in one place, Njord helps fleet managers and owners stay on top of their EUA position and make compliance more manageable.
Don't wait for compliance to become urgent. Be ready for it.
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