FuelEU Maritime: the first year
FuelEU Maritime caps the greenhouse gas intensity of the energy a ship uses on voyages to, from and between EU and EEA ports, counted from well to wake. 2025 was the first reporting period; its reports, verification, pooling and penalties ran in 2026. This guide goes through those steps and what they mean for 2026 data.
Rules as checked on 2026-10-19. Each rule names its article.
Which ships and which energy
- Ships of above 5,000 GT that carry cargo or passengers for commercial purposes, whatever their flag. Regulation (EU) 2023/1805 Art. 2(1)
- 100% of the energy used on voyages between two EU/EEA ports of call and 100% at berth in them; 50% on voyages between an EU/EEA port of call and one outside. Art. 2(1)
- The company responsible is the same as under the EU ETS: the shipowner, or the manager or bareboat charterer that has taken over the ship's ISM duties. Art. 3(13)
The GHG intensity limit
The limit is a reference value of 91.16 gCO₂e/MJ lowered in steps. Each step applies from 1 January of its year until the next one. Art. 4(2)
| From | Reduction | Limit, gCO₂e/MJ |
|---|---|---|
| 2025 | 2% | 89.34 |
| 2030 | 6% | 85.69 |
| 2035 | 14.5% | 77.94 |
| 2040 | 31% | 62.90 |
| 2045 | 62% | 34.64 |
| 2050 | 80% | 18.23 |
The intensity is well to wake: the emissions of producing and delivering the fuel plus those of burning it, with default values per fossil fuel in Annex II. Biofuels, RFNBO and other fuels get their lower values only when certified; otherwise they count as the least favourable fossil pathway. Methane and nitrous oxide count with global warming potentials of 25 and 298, not the 28 and 265 of the EU ETS. Renewable fuels of non-biological origin (RFNBO) count 2 times in the energy until 2033. Art. 4(1), Art. 5(1), Art. 10, Annex I (Equation (1), RWD), Annex II; Directive (EU) 2018/2001 Annex V
Compliance balance and penalty
- Balance = (limit − the ship's yearly intensity) × energy used, in tonnes of CO₂ equivalent. Positive is a surplus, negative a deficit. Art. 16(4), Annex IV Part A
- Penalty for a deficit left after banking, borrowing and pooling: the deficit converted to the energy of very low sulphur fuel oil (VLSFO, 41,000 MJ per tonne) at the ship's intensity, times €2,400 per tonne of VLSFO. Art. 23(2), Annex IV Part B
- A ship with a deficit in consecutive periods pays more: the penalty is multiplied by 1 + (n − 1) × 0.1, where n is the number of periods in a row. Art. 23(2)
- Without a FuelEU document of compliance for 2 or more consecutive periods, and where other enforcement has failed, a Member State can issue an expulsion order. Art. 25(3)
Example: a typical container ship in 2025
The same ship as in the EU ETS guide and the calculators' preset: the median container ship in the EU MRV data (EU MRV public data 2025 (THETIS-MRV, version 62, full-year reports)), 930 t of HFO between EU/EEA ports, 4,160 t to or from them, 170 t of MDO/MGO at berth. Annex II default factors, fossil fuels only.
| Fuel in scope | 3,010 t HFO + 170 t MDO/MGO |
|---|---|
| Energy in scope | 129.2 TJ |
| Ship's GHG intensity | 91.69 gCO₂e/MJ |
| Limit for 2025 | 89.34 gCO₂e/MJ |
| Compliance balance | −303.9 t CO₂e |
| Penalty, first deficit | €193,991 |
| Penalty, second deficit in a row | €213,390 |
With the default factors, HFO (91.74 gCO₂e/MJ) and MDO/MGO (90.77) are both above even the first limit, so a ship running on them alone has a deficit: it needs other fuels, a pool or borrowing, or it pays the penalty. The limit stays at 89.34 gCO₂e/MJ until 2029, so the same fuel gives the same deficit each year until then. Try your own fuel mix in the FuelEU calculator, which can also add the EU ETS cost of the same fuel.
Banking, borrowing and pooling
- Banking: a surplus can be carried to the same ship's next period, until the FuelEU document of compliance is issued. Art. 20(1)
- Borrowing: a deficit can be covered by an advance surplus from the next period, at most 2% of the limit times the ship's energy, and not in consecutive periods. The next period repays it × 1.1. The example ship could borrow up to 230.8 t of its 303.9 t deficit and would then start the next period 253.9 t down. Art. 20(2), (3)
- Pooling: the balances of two or more ships, of one company or several, can be combined. The pool's total must be positive, no ship with a deficit may end up with a larger one, and no ship with a surplus may end up in deficit. A ship is in one pool per period, and a pooled ship cannot borrow. Art. 21(1), (4), (7)
The Regulation sets no price for surplus moved between ships in a pool. The FuelEU calculator lets you enter a price you have been quoted to compare pooling with the penalty.
Deadlines
For 2025 data, the first period, these steps ran from 31 January 2026 to 30 June 2026. For 2026 data the same steps fall in 2027:
- 31 January 2027 · Company: Give the verifier the FuelEU report of each ship for the previous year, with its monitoring data. Regulation (EU) 2023/1805 Art. 15(3)
- 31 March 2027 · Verifier: Record the verified FuelEU report and verification report in the FuelEU database and notify the company. Regulation (EU) 2023/1805 Art. 16(5)
- 30 April 2027 · Company / verifier: Record any borrowed (advance) compliance surplus; the pool verifier records the final pool and its allocation. Regulation (EU) 2023/1805 Art. 20(3), Art. 21(8)
- before 1 May 2027 · Verifier: Record the verified compliance balance (after banking, borrowing and pooling) in the FuelEU database. Regulation (EU) 2023/1805 Art. 23(1)
- 30 June 2027 · Company: Pay the FuelEU penalty for a compliance deficit still open on 1 June (and for non-compliant port calls). Regulation (EU) 2023/1805 Art. 23(2), (5)
- 30 June 2027 · Verifier / ship: FuelEU document of compliance issued (once any penalty is paid); ships calling at EU/EEA ports must hold it. Regulation (EU) 2023/1805 Art. 22, Art. 24(1)
EU MRV, EU ETS and IMO dates are in the shipping compliance calendar.
What comes next
- 2030: the limit drops to 85.69 gCO₂e/MJ (6% below the reference). Art. 4(2)
- 2030: container and passenger ships at berth in the ports concerned must connect to shore power, with some exceptions, or pay €1.5 per kW of power demand at berth per hour for each non-compliant call. Art. 6(1), (4), (5), Art. 23(5)
- 2034: a minimum share of RFNBO applies from this year if their use stays low in the years before. Art. 5(3)
Proposed changes (not law)
On 17 July 2026 the Commission proposed amending the MRV and FuelEU Regulations (COM(2026) 620): one monitoring plan and one report per ship for EU MRV / EU ETS and FuelEU, and EU MRV extended to oil tankers, chemical tankers, gas carriers, LNG carriers, ro-pax ships and passenger ships from 400 GT up to 5,000 GT. It is a proposal: the calculator and this page follow the rules in force. On 2026-10-19 it was awaiting a vote in the European Parliament’s environment committee (ENVI) (2026/0210(COD)). The EU ETS changes proposed at the same time are in the EU ETS guide.
Related
- FuelEU Maritime calculator: balance, penalty and the EU ETS cost of the same fuel
- EU ETS for shipping
- EU ETS Excel models for budgeting several ships
- Shipping compliance calendar