FuelEU pooling in 2027: prices, deadlines and how to choose a partner
Pools for the 2026 reporting period must be recorded by 30 April 2027. This guide compares what a pool costs with the penalty, sets out the rules a pool must meet and lists what to agree with a counterparty before you commit.
By Margus Roosipuu, Founder · Published 15 October 2026
The short version
- Deadline: pools for the 2026 reporting period are recorded in the FuelEU database by 30 April 2027. Counterparty talks take time, so they are best started well before the verified balance is available.
- Price against penalty: the penalty works out at roughly €640 to €655 per tonne of CO₂e in deficit, depending on the ship's actual GHG intensity. OceanScore's index of published surplus offers for 2026 stood at €108.60 per tonne in September 2026.
- Rules: a pool is valid only if its total balance is positive, no ship in deficit ends with a larger deficit and no ship with a surplus ends in deficit (Article 21).
- Borrowing: a ship that borrows for 2026 cannot join a pool for 2026, and it cannot borrow again for 2027.
How a FuelEU pool works
Pooling is the only way to use one ship's surplus to cover another ship's deficit. Ships of the same company or of different companies can pool their compliance balances for a reporting period. The conditions come from Article 21 of Regulation (EU) 2023/1805 and the European Commission's questions and answers:
- A pool has two or more ships. Each ship's balance can be in only one pool per reporting period. Separate pools are possible for the GHG intensity limit and for the RFNBO sub-target.
- The total balance of the pool must be positive. A ship in deficit cannot end with a larger deficit, and a ship with a surplus cannot end in deficit.
- A ship in a pool cannot borrow for the same reporting period.
- Each pool has one verifier, agreed by all participating companies. Every company confirms the pool in the FuelEU database, and the verifier records the final composition and allocation by 30 April.
The regulation sets no price for pooling. Payments between the companies are a private commercial agreement.
What pooling costs compared with the penalty
The penalty is €2,400 per tonne of VLSFO-equivalent energy in deficit, where one tonne equals 41,000 MJ (Annex IV). Because the deficit in grams of CO₂e is converted to energy using the ship's actual GHG intensity, one tonne of CO₂e in deficit costs about €643 at 91 g CO₂e/MJ. The penalty rises by 10% for each further consecutive year in deficit (Article 23).
Market offers for surplus have been well below that level and have fallen through the second half of 2026:
| Month | Offer index, 2026 compliance year |
|---|---|
| July 2026 | €132 per tonne CO₂e |
| August 2026 | €118.90 per tonne CO₂e |
| September 2026 | €108.60 per tonne CO₂e |
Source: OceanScore FuelEU Pool-Price Index (OPX). The index is based on published surplus offers, not completed transactions.
A real deal price depends on the volume, the timing, whether the surplus is already verified and the payment terms. Platform, verifier and advisory fees come on top, so compare total cost, not only the price per tonne.
Worked example: pool, borrow or pay
A ship uses 205,000 GJ of energy in scope in 2026, about 5,000 tonnes of VLSFO-equivalent, at an actual GHG intensity of 91.0 g CO₂e/MJ. The limit for 2026 is 89.34 g CO₂e/MJ, so the ship ends the year with a deficit of about 341 tonnes of CO₂e.
| Route | What happens | Cost or effect |
|---|---|---|
| Pay the penalty | The deficit of about 341 t CO₂e remains | About €219,000, or 10% more if the ship was also in deficit for 2025 |
| Join a pool | 341 t of surplus allocated to the ship at €108.60 per tonne | About €37,000 plus fees |
| Borrow | Borrowing is capped at 2% of the limit times the energy, here about 366 t, so the whole deficit can be covered | No payment now, but about 375 t (1.1 times) is added to the 2027 deficit, and the ship cannot borrow again for 2027 |
Estimate for illustration, calculated with the formulas in Article 20, Article 23 and Annex IV. Your verified compliance balance is calculated under Annex I and confirmed by your verifier. Try your own figures in the FuelEU calculator, or look up your ship by IMO number for a first estimate from public EU data.
Timeline to 30 April 2027
- Now to December 2026: estimate each ship's 2026 balance from fuel and voyage data. Check your charter parties for who bears the FuelEU cost and who decides on pooling. BIMCO published a FuelEU Maritime Clause for Time Charter Parties in 2024, so check whether your contracts use it or similar wording.
- January 2027: the FuelEU report for 2026 goes to the verifier by 31 January. Shortlist counterparties and agree terms in principle.
- February to March 2027: the verifier checks the report and, by 31 March, records each ship's compliance balance in the FuelEU database (Article 16(5)). Agree the pool's verifier and the final volumes.
- April 2027: every company confirms the pool in the FuelEU database, and the pool's verifier records the composition and allocation by 30 April.
- By 30 June 2027: any remaining penalty is paid and the FuelEU document of compliance is issued (Articles 22 and 23).
How to choose a pooling partner
- Verified or estimated surplus: if the seller's balance is not yet verified, agree how volume and price adjust to the verified figure, and what happens if the surplus turns out smaller.
- Pool verifier: one verifier oversees the whole pool. Agree who it is, who pays its fee and whether it can meet the April timetable.
- Payment security: tie payment to the recorded allocation, or use escrow. Avoid paying the full price before the pool is recorded.
- Deadline risk: agree what happens if a party does not confirm the pool in the FuelEU database before 30 April, including termination and refunds.
- Counterparty checks: confirm the company, its ownership and the ships, and screen against sanctions lists, as for any commercial contract.
- Data sharing: agree which fleet data each participant receives and how it may be used.
If your ship has a surplus
A surplus can be banked to the same ship for the next reporting period (Article 20) or shared in a pool. Banking keeps it for later years, when the limit tightens to 85.69 g CO₂e/MJ from 2030. Selling turns it into cash now, at offer prices that have fallen in recent months. Banking must be recorded before the document of compliance is issued, so the choice cannot wait until the summer.
Where Legatia can help
We review your fleet's 2026 position, compare banking, borrowing, pooling and the penalty, and coordinate an agreed pool with suitable counterparties before 30 April. Your company and its verifier remain responsible for compliance decisions and statutory verification. Scope and fee are set out in a written proposal before work starts.
Sources
- Regulation (EU) 2023/1805, Articles 20 to 23 and Annex IV.
- European Commission: FuelEU Maritime questions and answers, pooling questions 21.1 to 21.3.
- OceanScore FuelEU Pool-Price Index, monthly values for the 2026 compliance year.
- BIMCO FuelEU Maritime Clause for Time Charter Parties 2024.