About
Overview
The proposed regulation would require a gradual reduction in GHG emissions from offshore vessels used in petroleum activities in Norway. The regulation is set to commence in 2029 and be phased in until 2040.
Whilst the main purpose is to reduce GHG emissions as part of the long-term goal of transforming Norway into a low-emission society by 2050, the regulation also seeks to promote the development and adoption of zero-emission technologies for vessels; including the development of bunkering infrastructure for permitted fuels.
The proposed regulation stipulates a requirement for operators on the Norwegian continental shelf to reduce the GHG intensity of offshore vessels used in petroleum activities. The GHG intensity is to be reduced by a set percentage over three-year periods:
- From 2029 to 2031: 10% reduction in GHG intensity
- From 2032 to 2034: 15% reduction in GHG intensity
- From 2035 to 2037: 20% reduction in GHG intensity
- From 2038 to 2040: 40% reduction in GHG intensity
GHG intensity refers to the emissions of GHG per unit of energy consumed, measured in grams of CO₂ equivalents per megajoule (MJ). The proposed limit for maximum allowable GHG intensity is set as a reduction from the reference value of 91.16 grams of CO₂ equivalents per MJ. The reference value aligns with the FuelEU Maritime regulation.
Verification period and responsible party
It is the "operators" who are responsible for fulfilling the requirement. The operator is defined as the person who, on behalf of the license-holder, is in charge of the day‑to‑day management of the operations. Petroleum activities are defined as all activities related to subsea petroleum deposits, including survey/exploration, exploratory drilling, extraction/production, transport, utilisation and decommissioning, as well as planning of such activities; however, not the transport of petroleum in bulk by ship.
The operator must fulfil the prescribed requirement for the specific three year period for all vessels that are used for petroleum activities. The requirement applies for the combined energy use of all vessels performing the following activities on behalf of the operator in connection with petroleum activities:
- Transport of supplies, materials, personnel and equipment.
- Installation, operation and decommissioning activities, including anchor handling, towing and pipeline- and cable-laying.
- Tasks related to emergency preparedness and hazardous/accident situations around installations.
This means that the requirement to reduce the GHG intensity is not linked to the specific vessel but rather to the operators who must ensure that the combined emissions from all the vessels in their service are in compliance. This entails that there is no requirement that the vessels are owned or chartered by the operator.
In order to allow for flexibility the operators may buy or sell compliance surpluses between each other in order to fulfil the requirement.
Permitted fuels
In order to meet the requirements, offshore vessels will need to gradually increase the use of fuel with lower GHG emissions than fossil fuels. Types of fuel (referred to as "energy carriers") which may be used to achieve compliance include:
- Renewable fuels of non-biological origin (RFNBO), for example renewable hydrogen-based fuel
- Low-carbon hydrogen based fuel
- Biogas made from raw materials listed in Annex IX of the Renewable Energy Directive ((EU) 2018/2001)
- Land power
The proposed regulation excludes the use of liquid biofuel. This contrasts with the FuelEU Maritime and the Net-Zero Framework where the use of biofuel is not excluded. According to the consultation letter issued with the draft proposal, despite meeting the sustainability requirements, NEA considers that liquid biofuel does not contribute to technological advancements in maritime transport. Therefore, liquid biofuel is assigned the same emission factor as the least favourable production process for equivalent fossil fuel (MGO).
Reporting, verification and supervision
Operators must submit an annual report to the NEA by 31 March each year with an overview of total consumption of each energy carrier for ships covered by the GHG‑intensity requirement. After each three‑year compliance period, operators must also submit a period report to the NEA by 31 March the following year documenting that the GHG‑intensity requirement has been met. The three-year period report must be verified by an external, accredited verifier.
Non-compliance and sanctions
If an operator fails to meet the GHG‑intensity requirement at the end of a three‑year compliance period, the NEA may require the operator to make up the shortfall during the next three‑year period in addition to meeting that period’s obligations. Non‑compliance for a given period therefore does not relieve the operator of responsibility for that period, and the requirement to address underachievement can be combined with an administrative penalty for breaches.
Thommessen is monitoring the development of this legislative proposal.
Who does it impact?
The proposal will impact operators on the Norwegian continental shelf as well as shipping companies operating offshore vessels that are providing services to such operators.
Status: Launched
The proposal was launched on 4 July 2025 with a request for consultation from key stakeholders in the industry. The deadline for submission of responses to the consultation was 3 October 2025. The next steps is for the NEA to redraft the proposal and submit it for debate in the Norwegian Parliament.
Relation to other initiatives and regulations
The proposal has significant similarities to FuelEU Maritime and the IMO Net-Zero proposal. However, the proposal is national Norwegian and might in its current form apply in parallel to any EU or UN legislation.
Participants
Norway
Thommessen's comments
The proposed regulation bear similarities with the FuelEU Maritime Regulation (the "FuelEU Maritime"), although the FuelEU Maritime does not as of now include offshore vessels.
In addition, if the IMO's Net-Zero Framework (the "Net-Zero Framework") is adopted, it will cover offshore vessels with a gross tonnage of above 5,000 from 2028, with a possibility of later being extended to vessels with a gross tonnage of above 400.
This entails that the new Norwegian regulation might entail a double or triple burden depending on how the relevant EU and international regulations evolve.
There are some notable differences between the proposed regulation and the FuelEU Maritime and Net-Zero Framework. One key feature of the proposed regulation is that it applies to the total emissions from all vessels performing services for the operator, rather than to the ISM Company or registered owner on a per vessel basis. It is not yet clear how vessels which fall within the scope of the regulation will be defined, as there is no requirement of ownership or a charterparty.
Some stakeholders in the industry have criticised the proposal for adding an additional regulatory burden on operators on the Norwegian continental shelf, for conflicting with EU legislation, for being unclear in scope and legal basis and for being a competitive disadvantage for the Norwegian offshore operators.