Pooling provides greater flexibility for FuelEU Maritime compliance

FuelEU Maritime remains one of the shipping industry’s biggest decarbonisation drivers, with 2026 marking a critical year for compliance.

FuelEU Maritime came into force on 1 January 2025 with the aim of increasing the uptake of zero and low carbon fuels. It does so by setting incremental targets for the reduction of greenhouse gas (GHG) intensity of onboard energy, covering both fuels and electricity, on voyages involving EU ports. The reduction target started at 2% in 2025 and will go up to 6% by 2030, ultimately reaching 80% by 2050.

This year alone, there are three key milestones to mark in calendars.

• By 31 March, verified results are confirmed and indicate each vessel’s compliance surplus or deficit. The period between this checkpoint and the next is crucial as companies have a short window to improve their position before any remaining deficit leads to penalties in the summer.
• By 30 April, companies must decide on their compliance strategy if they are in a deficit. The main options are borrowing or pooling. Borrowing offers some flexibility but is limited to cases where the GHG intensity gap does not exceed2%.
• By May – June, penalties for non-compliance will be applied.

Each compliance strategy has its strengths and choosing between the two is far from a matter of preference. Operators will need to choose the strategy that aligns best with their operational priorities.

Between borrowing and pooling, there are key differences:

• Borrowing can only be applied where the GHG intensity shortfall is no greater than 2%.
• There is a 10% penalty applied to borrowed surplus next year.
• Cannot be used in two consecutive years.
• Pooling can offset your deficit using the surplus from other vessels
• No penalty multiplier offering an easier path to compliance
• Can be applied across an entire fleet

Ultimately, the optimal approach depends on each fleet’s exposure and trading profile. What is clear, however, is that penalties are avoidable with the right preparation.

A robust compliance strategy starts with understanding your exposure. Not just in general terms, but on a voyage by voyage and trade by trade basis. That foundation is what allows operators to assess the financial, carbon and compliance consequences in real terms, and to act before options become limited. With continued market volatility, flexibility, speed of execution and proactivity matter. Pooling and other mechanisms work best when deployed early – not at the deadline.

At KPI OceanConnect, we help simplify this complexity. Our dedicated Alternative Fuels & Carbon Markets team of experts can guide our partners every step of the way in understanding the best options available and what makes sense operationally and commercially. We support our customers with access to pooling solutions through partnerships with two highly reputable pooling providers, combining compliance expertise with practical execution capabilities. We connect you to the right pool, optimise your fuel position with tailored recommendations that work alongside your compliance balance, and handle your EUA procurement, all managed through one partner.

This is no longer an environment where owners should need one relationship for conventional bunkers, another for alternative fuels, another for carbon, and another for compliance tools. What operators need is one, integrated, experienced counterparty.