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Sep 8, 2023
Lockton Edge

Lockton expands Nordic presence with launch of Norwegian energy and employee benefits divisions

The European Union’s Emissions Trading System (EU ETS) was extended to cover emissions from shipping as of 1st January 2024.

The EU ETS is limited by a 'cap' on the number of emission allowances. Within the cap, companies receive or buy emission allowances, which they can trade as needed. The cap decreases every year, ensuring that total emissions fall.

Each allowance gives the holder the right to emit:

  • One tonne of carbon dioxide (CO2), or;
  • The equivalent amount of other powerful greenhouse gases, nitrous oxide (N2O) and perfluorocarbons (PFCs).
  • The price of one ton of CO2 allowance under the EU ETS has fluctuated between EUR 60 and almost EUR 100 in the past two years. The total cost of emissions will vary based on the cost of the allowance at the time of purchase, the vessel’s emissions profile and the total volume of voyages performed within the EU ETS area. The below is for illustration purposes:
  • ~A 30.000 GT passenger ship has total emissions of 20.000 tonnes in a reporting year, of which 9.000 are within the EU, 7.000 at berth within the EU and 4.000 are between the EU and an outside port. The average price of the allowance is EUR 75 per tonne. The total cost would be as follows:
  • ~~9.000 * EUR 75 = EUR 675.000
  • ~~7.000 * EUR 75 = EUR 525.000
  • ~~4.000 * EUR 75 * 50% = EUR 150.000
  • ~~Total = EUR 1.350.000 (of which 40% is payable in 2024)
  • For 2024, a 60% rebate is admitted to the vessels involved. However, this is reduced to 30% in 2025, before payment is due for 100% with effect from 2026.
  • Emissions reporting is done for each individual ship, where the ship submits their data to a verifier (such as a class society) which in turns allows the shipowner to issue a verified company emissions report. This report is then submitted to the administering authority, and it is this data that informs what emission allowances need to be surrendered to the authority.
  • The sanctions for non- compliance are severe, and in the case of a ship that has failed to comply with the monitoring and reporting obligations for two or more consecutive reporting periods, and where other enforcement measures have failed to ensure compliance, the competent authority of an EEA port of entry may issue an expulsion order. Where such a ship flies the flag of an EEA country and enters or is found in one of its ports, the country concerned will, after giving the opportunity to the company concerned to submit its observations, detain the ship until the company fulfils its monitoring and reporting obligations.
  • Per the EU’s Implementing Regulation, it is the Shipowner who remains ultimately responsible for complying with the EU ETS system.

There are a number of great resources on the regulatory and practical aspects of the system – none better than the EU’s own:

Lockton, the world’s largest privately-owned insurance broker, today announces the expansion of its risk advisory and insurance broking services in Norway.

Responding to demand in the region, Lockton Norway will now offer solutions for natural resources, renewable energy and large industrials clients with complex risk management requirements. The office located in Oslo has also established a People Solutions function, helping clients to drive employee understanding, engagement, and satisfaction through comprehensive benefits packages. Both divisions are open to accept new business.

The business will be looking to make a series of senior hires in the coming months, to support existing clients and a strong pipeline of future prospects. The Energy and People Solutions teams will sit alongside current Professional Services, Financial Institutions, M&A and Marine and Transportation teams.

This expansion marks the latest step in Lockton’s growth strategy in the Nordics region, with the independent insurance broker having opened its Stockholm office earlier this year.

EJ Hentenaar, CEO of Lockton Europe, said:

We significantly added to Lockton’s presence in the region three years ago and since then, our Nordic business has grown exponentially as a result of high demand and our deep industry knowledge. In that time, we have opened multiple offices and welcomed some of the best talent in the market, due, in no small part, to our supportive culture and the opportunities for growth that being part of the world’s largest privately-owned insurance broker can bring.

It is clear from our rapidly growing areas of specialism, Lockton Norway is a career destination for brokers who wish to be surrounded by colleagues that are experienced, share an ambitious mindset and are well matched in talent and enthusiasm for their respective fields. I am certain our new Energy and People Solutions divisions will further enhance our standing in the market and help us to continue to attract some of the most talented individuals in the industry.


As the world’s largest independent insurance brokerage firm, Lockton is committed to service and empowered with a single-minded focus on delivering results for clients. More than 9,500 Associates provide 65,000 clients globally with creative solutions in risk management, insurance and employee benefits consulting. We’re purposely unconventional, insatiably curious and uncommonly independent.

For further information contact William L’orange, Chief Operation Officer – Nordic Region, Lockton Norway AS at


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