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FuelEU Maritime is now transitioning from a phase of preparation into one of execution. Over the first compliance year, market participants have developed compliance strategies based on assumptions. Surplus positions were modelled, pooling arrangements were structured, and commercial transactions were entered into on the expectation that these structures would translate into regulatory outcomes once the FuelEU Database and its operational framework became operational. With th

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

FuelEU Maritime allows pooling as one of its flexibility mechanisms. Under Article 21 of the Regulation, companies may group vessels in a pool to reallocate compliance balances, provided the pool satisfies the regulatory conditions on surplus/deficit allocation and total positive balance (see previous newsletter ). In April of the year following the reporting period (for the first time April 2026), pools and their allocations must be recorded in the Official FuelEU Database a

As the first FuelEU Maritime compliance cycle progresses, the surplus market has expanded rapidly. What began as a maritime compliance instrument has evolved into a traded commodity, and in doing so, it has attracted far more participants than the regulation or its creators appear to have anticipated. FuelEU pooling rights and who holds them The regulation assigns the compliance responsibility and as such the right to pool to the ISM company. However, contractual arrangements

The regulatory landscape for shipping has never been more dynamic. Three major frameworks outlined below will likely dominate the...

The end of a FuelEU Maritime reporting year doesn't mean the work is done. On the contrary, it marks the beginning of an interesting...