One of the lesser-discussed but tricky elements of the FuelEU Maritime Regulation is the power of administering states to conduct retrospective checks, reviewing and re-verifying compliance data after it has already been submitted and even accepted. This retrospective power can reach back two full compliance periods and can have significant implications. What happens if a ship’s 2025 data is reassessed in 2027? What if that vessel was part of a pool that was declared complian
