The environmental footprint of the ferry fleet is significant: In 2023, passenger and Ro-Pax ships accounted for 16.5% of all EU shipping CO₂ emissions reported in the EU MRV system. This figure excludes vessels under 5000 GT, which make up a large part of the fleet but are missing from official statistics. In addition, ferries are a major source of air pollution, emitting sulphur dioxide (SOx), nitrogen oxides (NOx), particulate matter (PM) and black carbon (BC). Given their frequent operation in urban port areas, these emissions have direct negative health impacts on local populations.
Short- and mid-range passenger and Ro-Pax vessels are subject to overlapping regulatory frameworks. When sailing across borders, specific regulation by the EU as well as the global regulations of the International Maritime Organisation (IMO) apply.
Internationally, the MARPOL convention – regulating pollution from fuel use, sewage, garbage and air emissions – requires ships above 400 GT to comply with regulations to promote efficient ships (EEXI & EEDI), while those above 5000 GT must report their fuel use under the IMO Data Collection System (DCS) and comply with the Carbon Intensity Indicator (CII). Additionally, ferries operating in Emission Control Areas such as the Baltic Sea, the Channel, the North Sea and from 2025 the Mediterranean Sea must meet tighter SOx and NOx limits.
Importantly, IMO regulations apply to ships engaged in international voyages, in parallel to national rules applying at the various ports of call, and to the regulation of the national flag they are registered with. This hierarchy of regulation is established in the UN UNCLOS treaty, and recognised in IMO SOLAS and MARPOL conventions.
While many European ferries operate on purely domestic routes and are therefore outside the scope of several IMO measures, falling instead under EU and national regulation, the EU has transposed (parts of) the global framework into binding law (e.g. Sulphur Directive, Port State Control Directive, or Flag State Control Directive), ensuring consistent enforcement across Member States.
At the EU level, ferries are subject to the same overarching climate and environmental legislation as other passenger ships. This comprehensive regulatory framework incentivises investments in zero-emission technology and electrification, as compliance would bring both FuelEU compliance benefits and Emissions Trading System (ETS) cost savings.
The Fuel EU Maritime Regulation (FEUM) aims to stimulate the uptake of low- and zero-emission propulsion (including electrification) by requiring ships equal or above 5000 GT to progressively reduce the GHG intensity of the energy used onboard. However, some passenger vessels currently benefit from a set of exemptions until 31 December 2029, for domestic voyages to islands of under 200,000 inhabitants, voyages between outermost regions, transnational public service routes for Member States (MS) without a land border, or for pre-2023 public service island connections (including the Spanish exclaves of Ceuta and Melilla). Beyond carbon-intensity targets, FEUM also mandates large ferries to connect to on-shore power when at berth from 2030.
In parallel, the ETS requires shipping companies to surrender emission allowances based on the ETS scope (i.e. 100% of emissions from intra-EEA voyages, 100% of emissions happening in EEA ports and 50% from voyages between EEA and non-EEA ports) for passenger ships, including ferries above 5000 GT since 2024. As with FEUM, exemptions apply until 31 December 2030 for passenger (excluding cruise ships) and Ro-Pax ferries operating on specific island routes (in the same jurisdiction, without a road/rail link, and under 200,000 inhabitants), operating on transnational public service routes (currently only between Cyprus and Greece), and for voyages to and between outermost region ports of the same MS. Additionally, vessels with ice class IA, IA Super or equivalent are allowed to surrender 5% fewer allowances than their verified emissions.
In addition, the UK is exploring extending international coverage of its own ETS to the maritime sector, which will follow the same parameters as the EU ETS. Companies will have to surrender allowances for emissions from ferries above 5000 GT starting from July 2026. As the text states for now, the UK ETS will only cover emissions at-port and between UK ports, and will exempt only non-commercial government vessels from its coverage.
Recognising the substantial emissions that ships cause in port, the Alternative Fuel Infrastructure Regulation (AFIR) mirrors FEUM and introduces a mandate for maritime ports to provide onshore power supply (OPS) to passenger ships (and container vessels) equal or above 5000 GT by 2030. The mandate applies only for ports that have a sufficient number of annual port calls per ship type (e.g. for ferries, 40) and MS should ensure that enough charging points are available to cover the electrical energy needs of at least 90% of these port calls. Exemptions similar to those detailed for FEUM also apply.
Beyond their GHG emissions, ferries are covered by rules limiting air pollution, embedded in EU legislation (e.g. Sulphur Directive). Additionally, services are subject to EU rules on passenger rights, while access to domestic markets was liberalised in EU “Cabotage” regulation (3577/92/EC). Where essential transport to remote regions requires support, public service obligations and state aid control laws apply.
National level
In addition to this harmonised EU framework, the regulation of ferries also takes place at the national and regional level, and reflects the public service role of many routes. The ferry sector is deeply intertwined with public transport systems and regional connectivity.
The EU’s cabotage regulation substantially liberalised the ferry sector, allowing member state-registered vessels to service routes independent of national borders. Where ferries provide crucial public transport functions, but operations are not economically viable, they are often operated with public support or under public ownership. While general state aid restrictions and public procurement directives (2004/17/EC and 2004/18/EC) apply, national or regional cabotage laws also define how public support is provided. This support ranges from publicly funded Public Service Contracts, to Public Service Obligations to direct state ownership of individual ferries. National and regional governments thus have significant leeway in assigning requirements through public tenders and procurement.
As a result, the level of public involvement varies significantly between regions: in the Baltic and North Sea, many ferry routes are commercially viable and operate under market conditions, with specific routes being operated with strong state involvement. Additional requirements are often applied, including environmental standards under existing state aid rules. These requirements have accelerated the uptake of efficient vessels, more competitive pricing, and most recently led to the introduction of some hybrid and fully electric ferries on shorter routes.
By contrast, in the Mediterranean and Atlantic, many ferry connections are still operated with direct state subsidies, under concession contracts, or regulated tariffs, with less stringent or no environmental requirements. Compared to commercially operated and competitive routes, older vessels remain in service, as is the case for island services in Greece, Italy, Spain, France, and Portugal.
This patchwork of national approaches means that ferries face uneven regulatory pressure across Europe. This has implications for both investment decisions and the speed of fleet renewal. A salient example is Norway’s regulation on cabotage that, combined with sustainable provisions in public support and additional environmental obligations, has led to a significantly more modern ferry fleet with a large share of vessels that utilise electrification or alternative fuels. EU law permits similar environmental requirements under the MEAT principles (most economically advantageous tender) of public procurement rules, though environmental requirements are optional.
An example of successful national regulation beyond EU standards is the transposition into national law of the OSPAR convention. Under it, eleven EU member states, Norway, the UK, Switzerland, and Luxembourg as well as the EU agreed to ban discharge of waste water from Exhaust Gas Cleaning Systems (EGCSs), or “scrubbers” near coasts and ports of the north-east Atlantic.
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