FuelEU Maritime Compliance
Achieve FuelEU Maritime compliance through pooling strategies and expert guidance to avoid penalties.
FuelEU Maritime is here: are you ready to comply?
On January 1, 2025, the first compliance year of the FuelEU Maritime regulation began. The regulation aims to cut greenhouse gas (GHG) emissions from shipping by promoting cleaner fuels and energy sources, in line with the EU's 2050 climate neutrality target. Unlike the EU ETS, which focuses on carbon pricing, FuelEU introduces stricter rules with GHG intensity standards, updated calculation methods, and penalties for non-compliance. The regulation applies to all ships above 5,000 GT calling at EU ports, regardless of flag.
How can you comply with FuelEU Maritime?
Compliance can be achieved through two main strategies:
Switch to lower-carbon fuels
Using alternative fuels reduces your ship's GHG intensity and ensures compliance.Using alternative fuels reduces your ship's GHG intensity and ensures compliance. While effective, challenges include vessel readiness, limited fuel availability at certain ports, and higher costs.
Pool compliance across vessels
Pooling lets you balance performance across your fleet or with external partners, sharing the benefits of cleaner fuels where they are most accessible and affordable. This approach helps avoid penalties while rewarding early movers in decarbonization.
This flexibility helps avoid unnecessary penalties while rewarding early movers in decarbonization.
We're here to help you make the right choice
At CarbonLeap, we support you every step of the way by:
Our goal is simple: we make FuelEU compliance the cheapest, easiest, and most strategic part of your decarbonization journey, so you can focus on preparing your fleet for the future.
Why Work With Us
Fuel EU Maritime Essentials
Market insights
Early poolers win
Early action gives you access to better terms. By closing a deal early in the year, you'll have access to a broader range of counterparties, gain more flexibility in structuring your deal, and secure a stronger negotiation position before the market tightens.
Through our network of decarbonization leaders, we help shipping companies in deficit meet the regulation cost-effectively. We facilitated one of the first FuelEU pooling deals in 2024 and have since been helping clients stay ahead on cost of compliance.
"FuelEU compliance doesn't have to be a burden. Our pooling strategy creates a cost-effective path to meeting requirements while gaining competitive advantage."
— Guido Levie, Fuel EU Specialist
Turning climate regulation into your competitive edge
As climate regulations in shipping grow increasingly complex, it's easy to feel overwhelmed, and even easier to lose sight of the best path forward. The real opportunity lies in turning these regulations into a competitive advantage.
Being at the forefront of transport decarbonization for years, we combine regulatory expertise with practical experience. Whether it's assessing your compliance strategy, structuring first-of-its-kind deals, or simply connecting you with the right pooling partner, we make sure your approach is not just to comply, but to use the new regulation as your competitive edge.
"With stricter regulations on the horizon, such as the IMO GHG Fuel Standard and the FuelEU Maritime 2030 benchmark, pooling provides a strategic way to phase sustainability investments over time."
— Meesz Niehe, Commercial Manager Marine
Yearly Key Deadlines
Report yearly energy use and GHG intensity
Have your data independently verified
Register compliance flexibility measures
Receive your Document of Compliance or settle penalties
Download Our FuelEU Maritime One-Pager
Get a comprehensive overview of FuelEU Maritime compliance strategies and pooling solutions.
After downloading, our FuelEU Maritime specialists will follow up to discuss how we can support your compliance strategy.
In the News
S&P Global • 2025
INTERVIEW: FuelEU compliance pooling market grows, but pricing agreements remain opaque -- CarbonLeap
Seanews • 2025
Innovative pooling agreements by CarbonLeap help shipowners meet FuelEU maritime standards
Hellenic Shipping News Worldwide • 2024
CarbonLeap urges shipowners to act swiftly in order to reap FuelEU Maritime pooling benefits
Frequently Asked Questions
Use renewable or lower carbon fuels, join a pooling arrangement, borrow from next year's compliance balance at 10% interest, or pay the penalty.
Pooling allows ships with a positive compliance balance to share this with ships with a negative balance in the same reporting period. A ship can only join one pool each year, the overall pool must have a positive balance, and one verifier is appointed to check the pool. We'll help you find the right pooling arrangement.
A ship with a negative balance can borrow their deficit, repaid at 10% interest the next year. It's not allowed to borrow consecutive years and borrowing cannot be combined with pooling.
Surplus created by exceeding the fuel requirements, or from pooling more than needed, can be banked and carried forward indefinitely.
The penalty is set to €2,400 per tonne of VLSFO energy equivalent, which translates to €640 per tonne of CO₂-equivalent. The penalty must be paid before a FuelEU Document of Compliance (DoC) is issued.
Penalty payment is required before a DoC will be issued. Persistent non-payment may lead to port bans or detentions in EU/EEA ports.
Any ship with a surplus or deficit balance in the same reporting year. Make sure the one you're pooling with owns the right for FuelEU.
After providing your ship's FuelEU report to your verifier, they will record your final compliance balance. After that you can announce your intentions to either pool, bank or borrow depending on your balance. When pooling, the verifiers also need allocation of compliance surplus among deficit vessels. Subsequently the verifiers record the composition of the pool and approve the final balances. After each ship's FuelEU report is verified, a selected single verifier records the definitive pool composition and allocations in the FuelEU database. A Document of Compliance follows.
It allows cost-efficient compliance without the risk of lower carbon fuel availability, the price fluctuations of these fuels or the technical risks of using biofuels. Contact us to find your pooling partners.
Monitoring Plan – by 31 Aug 2024 (or within 2 months of first EU/EEA call), Annual Reporting – by 31 Jan each year, Verification Complete – by 31 Mar, Pooling/Borrowing Registration – by 30 Apr, DoC Issued / Penalty Paid – by 30 Jun.
Ships submit annual fuel and voyage data to their verifier. The verifier confirms compliance and records it in the FuelEU database. Flexibility mechanisms (pooling, borrowing) must be registered and verified.
The ISM company (Document of Compliance holder).
The rights to determine what to do under FuelEU are only passed on to the charterer once there is an underlying contract between the ISM company and the charterer. For reference, see BIMCO's FuelEU Maritime Clause for Time Charter Parties 2024.
Ready to ensure FuelEU compliance?
Contact us today to learn how our pooling solutions can help your fleet meet FuelEU requirements cost-effectively.
