With the first FuelEU Maritime compliance data emerging after the inaugural year of greenhouse gas (GHG) intensity reporting for ships trading in the EU, marine insurer Skuld spoke with Joe Bettles, Climate Policy Manager and author of the Countdown newsletter at the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping, to examine what the early results reveal: 

The first data on FuelEU Maritime compliance is now emerging, following the first year of reporting against greenhouse gas (GHG) intensity targets for shipping companies trading in the EU.

To better understand what the early results show, we spoke with Joe Bettles, Climate Policy Manager and author of the Countdown newsletter at the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping (Center). The Center recently published its analysis of the first reporting year in the article “What did we learn from the first year of FuelEU?”

Under the regulation, shipowners have several options for compliance, including:

• The pooling mechanism, which allows vessels with a compliance surplus to trade it with other vessels.
• The borrowing mechanism, which allows companies to defer a compliance deficit to the following year for a 10% surcharge.
• Meet the target by using low GHG intensity fuels.
• Pay the FuelEU penalty (penalty).

Pooling becomes the preferred option

The first year of reporting indicates that pooling has quickly become the preferred choice. According to data from the European Commission, 92% of vessels used the pooling mechanism, while only 2% used borrowing. The remaining vessels either paid the penalty or met the target by using LNG or other low-GHG energy sources.

Commenting on the findings, Joe Bettles says: “Our insights from the first year of reporting indicate that shipping companies were able to comply with the targets, with most using the pooling mechanism. This shows that FuelEU is working as intended. As we approach the IMO’s upcoming discussion on the Net-Zero Framework (NZF), FuelEU demonstrates that it is possible for the global fleet to comply with a GHG intensity regulation using existing fuels and providing incentives for the uptake of cleaner energy sources.”

A developing market for compliance surplus

The Center’s article also reviews the different pooling platforms available to shipping companies seeking to meet their obligations under the regulation. The price of compliance surplus, averaging around EUR 208/tCO₂eq, remained relatively stable, suggesting that the market matured early, with buyers generally able to find sellers.

On the development of the pooling market, Joe notes: “The prices for trading compliance surpluses remained well below the EUR 640/tCO₂eq penalty for VLSFO, making the pooling mechanism significantly more attractive than paying the penalty.”

Fuel choices remain central to compliance

The role of fuel choice is also important. Looking at fuels supplied to the FuelEU market, the Center estimates that 3.22 million tCO₂eq of reductions, relative to an all-VLSFO fleet, will be required to meet the 2% reduction target between 2025 and 2029. Based on analysis of previous years’ fuel consumption, the Center indicates that LNG may have contributed around one-third of the required reduction. Biofuel blends account for the remainder, with biodiesel and bio-LNG dominating the low-GHG fuel mix.

Joe highlights how the pooling mechanism can help extend the impact of lower-GHG fuels across the fleet: “Although LNG is not a drop-in replacement for VLSFO, the pooling mechanism under FuelEU allows an LNG-fuelled vessel to share its over-compliance with other vessels that cannot physically use LNG. Depending on the engine type in the ship, LNG can remain compliant with the 14.5% reduction target through 2039 and can further extend its compliance through banked surplus or by using liquified biomethane.”

Three early lessons from FuelEU Maritime

Drawing on the first year of reporting, Joe Bettles and the Center identify three lessons that may also be relevant for the IMO in the future.

First, the results indicate that a fuel standard for shipping can work. FuelEU’s first year has created incentives for the use of alternative fuels and a market for those who prefer to pay for emissions compliance.

Second, regulations should include mechanisms that support a broader mix of energy sources. Lower-maturity alternatives, such as wind-assisted propulsion, e-fuels and onshore power, still represented a limited share of the mix.

Third, policy stability and clear reduction pathways can help reduce uncertainty for shipping companies and support the business case for investment in cleaner alternatives.

Supporting knowledge sharing across the maritime value chain

Skuld is a Mission Ambassador to the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping, supporting its work as a platform for collaboration, knowledge sharing and practical insight across the maritime value chain.

“The Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping is a highly valuable forum for us at Skuld. It provides access to a broad network of industry stakeholders and helps us stay close to the challenges shipowners face in meeting regulatory requirements and reducing emissions. Just as importantly, it serves as a platform for dialogue and knowledge sharing across the maritime value chain” – Matias Bøe Olsen, Decarbonisation and transition risk lead, Skuld.

Note: Read the full article on FuelEU’s first-year experiences here.

Photo credit: Chris Pagan on Unsplash
Published: 7 August, 2026

Marine Fuels Alliance (MFA) on Friday (3 July) said it has connected with TidalIQ, which has provided an emissions calculator for its website.

MFA said the FuelEU Maritime has turned vessel emissions performance into a commercial issue. Operators now need to understand whether their fleet is in surplus or deficit, what that means financially, and whether pooling can reduce cost or create value.

“The emissions calculator helps users estimate vessel or fleet compliance positions, potential penalty exposure, pooling requirements and the indicative value of surplus compliance,” the alliance said in a social media post.

From there, the TidalIQ platform helps users move from calculation to action: managing fleet compliance, identifying pooling opportunities, generating standardised documentation and maintaining a clear audit trail for verifiers and internal records.

“For operators facing deficits, TidalIQ helps identify a more cost-effective route to compliance. For operators with surplus, it creates a clearer path to monetising better-performing vessels,” it added.

“FuelEU compliance is no longer just a regulatory task. It is a commercial decision – and TidalIQ helps the market make that decision confidently.” 

Note: The emissions calculator can be found here. 

Photo credit: Marine Fuels Alliance
Published: 6 July, 2026

The following is a commentary by Philippos Ioulianou, Managing Director of EmissionLink, on how the maritime sector needs clear guidance on how how EU and IMO regulations will be reconciled to avoid duplicate carbon costs for shipowners:

The European Commission’s commitment to prevent shipping companies from being charged twice for the same emissions is a welcome step, but the maritime sector now needs clear guidance on how this will work in practice, according to integrated emissions management service EmissionLink.

The principle of avoiding double charging is clear, but the practical reality is far more complex. Shipping is already navigating a crowded regulatory landscape. EU ETS and FuelEU Maritime are now in force, while the IMO is moving towards its own global Net-Zero Framework. Each system has a different scope, timeline, calculation method and commercial logic. Without detailed guidance, avoiding duplicate carbon costs will not be straightforward.

A vessel trading into Europe may be exposed to EU ETS, FuelEU Maritime and future IMO carbon rules. However, the obligations will not always sit with the same party, emissions data may not always be calculated in the same way, and costs may not be recoverable under existing charterparty terms. 

According to EmissionLink, the risk for shipowners is not only paying twice for the same emissions. It also includes reporting twice, calculating twice and building parallel compliance processes that increase cost, complexity and confusion.

“The industry needs to know how EU and IMO obligations will be reconciled, how equivalent payments will be recognised, and what evidence shipowners will need to prove that the same tonne of emissions has not been penalised more than once,” said Philippos Ioulianou, Managing Director of EmissionLink. “This will determine whether carbon regulation is seen as a fair transition tool or simply another cost burden.”

Accurate and auditable emissions data will be more important than ever, but data alone is not enough. Owners and operators also need the expertise to interpret that data across different regulatory schemes and make informed commercial decisions. EmissionLink has already supported the delivery of accurate FuelEU emissions data for more than 600 vessels, giving it first-hand insight into the complexity of compliance across different vessel types and operating profiles.

“Every vessel has a different operating profile, every voyage has a regulatory consequence, and every compliance decision can affect cost exposure, penalties, pooling options, charterparty recovery and future planning,” said Mr Ioulianou. “The challenge is no longer simply submitting the right figure into the right system. It is understanding how current and future emissions schemes interact, how they affect the business, and how to avoid double penalties, duplicated processes and unnecessary costs.”

The company also highlights that carbon pricing will only retain credibility if revenues are clearly directed back into maritime decarbonisation. Speaking at a ShipEnergy forum during Posidonia, Mr Ioulianou argued that EU member states must set out a clear pathway for the use of revenues generated through EU ETS and FuelEU-related mechanisms.

“These funds should be directed back into the maritime sector,” he said. “They should not become a general revenue stream for governments. Demanding that shipping pays more while failing to invest in the infrastructure needed to make decarbonisation possible is not a transition strategy. It is taxation with a green label.”

Whilst the European Commission is right to recognise the risk of duplicate carbon costs, the industry now needs practical, transparent and enforceable rules that support compliance while helping shipping transition to lower-carbon operations.

“Shipping cannot decarbonise on promises alone,” said Mr Ioulianou. “The sector needs clarity, consistency and confidence that regulation will support the transition rather than simply adding cost and complexity.”

Photo credit: EmissionLink
Published: 30 June, 2026