Borrowing under FuelEU Maritime is often described in market discussions as a convenient fallback option. The narrative is simple: if a pool does not work out or surplus cannot be sourced at an acceptable price, the vessel can simply borrow compliance from the following year. This narrative is misleading. Borrowing is not designed as a universal safety net, and in many practical situations it cannot even cover the deficit of a single conventional vessel. In addition, the regu
