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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. This is provided the pool satisfies the regulatory conditions on surplus/deficit allocation and total positive balance. For more details, see our 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 th

As regulatory obligations under FuelEU Maritime begin to settle into market practice, maritime lawyers and shipowners face new challenges. They must craft robust Sale and Purchase (S&P) contracts for ships that safeguard against unexpected regulatory and commercial liability. While our previous newsletter addressed the general compliance responsibilities of buyers and sellers (“Selling and Buying Ships Under FuelEU Maritime”), this edition moves beyond theory. It provides act

Each week, more stakeholders enter the FuelEU Maritime pooling market. With this influx comes growing uncertainty about what can and should be traded. One recurring misconception is the idea of trading only “already generated surplus.” While this cautious approach may seem prudent, it overlooks the annual nature of FuelEU Maritime compliance. Understanding FuelEU Calculations & Annual Energy Consumption FuelEU Maritime does not measure compliance at any single point in time.

BetterSea and Evigo by OSM Thome Form Partnership to Deliver Standardized & Streamlined FuelEU Pooling to Maritime Customers. Under the terms of the agreement, Evigo will white-label BetterSea’s FuelEU Platform, offering it under the Evigo brand. The FuelEU pooling option complements Evigo’s existing services, the collaboration enables Evigo to provide its customers with direct access to BetterSea’s standardized FuelEU pooling framework.

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. This evolution has attracted far more participants than the regulation or its creators anticipated. FuelEU Pooling Rights and Their Holders The regulation assigns compliance responsibility to the ISM company, granting them the right to pool. However, contractual arrangements allow for the reassig

Last week, the maritime sector was waiting for a turning point. At the extraordinary MEPC83 session, the International Maritime Organization (IMO) was expected to adopt the long-discussed Net Zero Framework (NZF). Instead, following a geopolitical standoff led by the United States and Saudi Arabia, the decision was deferred. The IMO will now revisit the NZF no earlier than October 2026, effectively pushing back the global decarbonisation timeline by at least one to two years.

The regulatory landscape for shipping has never been more dynamic. Three major frameworks will likely dominate the conversation going forward. Let's explore the side effects of these regulations and how they have changed the industry. EU Emissions Trading System (ETS) Since its extension to maritime in 2024, the EU Emissions Trading System has changed the way owners and charterers collaborate. What was once siloed consumption data is now the basis for voyage statements, EUA r