For vessels within FuelEU scope, we review the compliance information your team provides, compare available options and coordinate agreed pooling transactions. Your company remains responsible for its compliance decisions, and statutory verification remains with its accredited verifier.
Smaller operators can get a structured starting point for assessing their position. In-house teams can engage Legatia for partner search and transaction coordination. Suitable options depend on vessel scope, the verified compliance balance and available counterparties.
Checked against Regulation (EU) 2023/1805. Each point names the article so your team can check it too.
Ships above 5,000 gross tonnage carrying passengers or cargo commercially, under any flag. FuelEU counts all energy used at berth in EU ports and on voyages between EU ports, and half of the energy on voyages between an EU port and a port outside the EU.
The yearly average GHG intensity of energy used on board must not exceed a limit set from a reference of 91.16 g CO₂e/MJ: 2% lower from 2025, 6% from 2030, then 14.5%, 31%, 62% and 80% by 2050.
€2,400 per tonne of VLSFO-equivalent energy in deficit, where one tonne equals 41,000 MJ. The amount rises by 10% for each further consecutive year in deficit. Estimate yours.
A surplus can be banked to the same ship. A deficit can be covered by borrowing up to 2% of the limit, repaid at 1.1 times the next year and not two years running, or by pooling with ships that have a surplus.
Container and passenger ships moored in TEN-T ports covered by Regulation (EU) 2023/1804 must use onshore power from 2030, and in other ports where it is available from 2035. Stays under two hours are exempt. Non-compliance costs €1.50 per kW of power demand per hour.
FuelEU gives each ship a compliance balance, a surplus or a deficit, against an intensity limit. Emission allowances belong to the EU Emissions Trading System, a separate obligation for many of the same ships. How they differ.
| From | Reduction | Limit (g CO₂e/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 |
Reduction from the 91.16 g CO₂e/MJ reference value (Article 4). Limits rounded to two decimals. RFNBO fuels count double until 2033, and a 2% RFNBO sub-target may apply from 2034 (Article 5).
| Date | What happens |
|---|---|
| 31 January | The company submits the FuelEU report for the previous year to its verifier |
| 31 March | The verifier notifies the company of each ship's compliance balance and records it, with the verified FuelEU report, in the FuelEU database (Article 16(5)) |
| 30 April | Borrowing and pools are recorded in the FuelEU database (Articles 20 and 21) |
| Before 1 May | The verifier records the verified compliance balance after banking, borrowing and pooling (Article 23(1)) |
| 30 June | Penalties are paid and the FuelEU document of compliance is issued (Articles 22 and 23) |
A pool needs agreed partners before the 30 April recording date, so counterparty talks are best started early in the year. Read our guide to FuelEU pooling in 2027: prices, deadlines and how to choose a partner.
Practical guides with article references, written for operators and compliance teams.
What a pool costs compared with the penalty, the Article 21 rules and what to agree with a counterparty before 30 April 2027.
Read the guide →The first verification cycle, the 2025 target and the compliance decisions facing ship operators.
Read the article →What each rule measures, how it is settled and why a pooling deal does not reduce your ETS bill.
Compare the rules →FuelEU Maritime sets limits on the yearly average greenhouse gas intensity of energy used on board ships within its scope. A ship's verified compliance balance can be managed through banking, borrowing or pooling under the regulation, subject to the relevant conditions.
Where there is a compliance deficit after banking, borrowing or pooling, a FuelEU penalty applies: €2,400 per tonne of VLSFO-equivalent energy in deficit, rising for consecutive years. It depends on the size of the deficit, not on a flat amount per tonne of fuel. Early assessment helps establish whether pooling or another permitted route is suitable.
We help compare feasible counterparties and coordinate an agreed transaction. Final compliance calculations and statutory verification are the responsibility of the company and its accredited verifier.
Review the fleet information and compliance position supplied by your team and identify relevant constraints.
Search for suitable pooling partners and compare available commercial terms and timing.
Coordinate agreed documentation, milestones and payment protections, including escrow where available and agreed.
We review the fleet's compliance position and timing requirements.
We identify suitable partners and present available terms for comparison.
We coordinate the agreed transaction, documentation and payment milestones.
We track agreed actions and coordinate documentation with your team and accredited verifier. The verifier remains responsible for statutory verification.
We review your fleet, timing and transaction requirements, then provide a written proposal with the service scope, fee and any applicable third-party costs before work begins.
No. Depending on the verified balance and the available arrangements, banking, borrowing, pooling or paying a penalty may be relevant. We compare options using the information available; your company and verifier confirm compliance decisions.
Under Article 21, compliance balances from multiple ships can be combined subject to the regulation's conditions. The pool must have an overall surplus, and a ship in deficit cannot end the pool with a larger deficit than it started with. The verifier records the results in the FuelEU database.
Where commercially available and agreed by the parties, we can coordinate an escrow arrangement and its milestones. The escrow provider's terms govern the funds; Legatia does not hold client funds.
Pricing depends on fleet size, timing, transaction structure and agreed service scope. We provide the fee in writing before work starts.
Timing depends on counterparty availability, data readiness, verifier schedules and the reporting deadline. We confirm a working timeline after reviewing your fleet position.
We can review information supplied for advisory and matching purposes. Statutory calculations and verification are performed through the applicable FuelEU process by the company and its accredited verifier.
Ships above 5,000 gross tonnage that carry passengers or cargo for commercial purposes, regardless of flag. FuelEU counts all energy used at berth in EU ports and on voyages between EU ports, and half of the energy on voyages between an EU port and a port outside the EU (Article 2). We check your vessels and voyage pattern during the initial assessment.
No. FuelEU sets a limit on the greenhouse gas intensity of the energy a ship uses, and each ship ends the year with a compliance balance: a surplus or a deficit. A surplus can be banked or shared in a pool; a deficit can be covered by borrowing or pooling, otherwise a penalty applies. Emission allowances belong to the EU Emissions Trading System, which is a separate obligation for many of the same ships.
€2,400 per tonne of VLSFO-equivalent energy in deficit, where one tonne equals 41,000 MJ (Annex IV). The deficit in grams of CO₂e is converted to energy using the ship's actual GHG intensity. The amount is multiplied by 1 + (n − 1)/10 when a ship is in deficit for n consecutive years (Article 23). Our calculator gives an estimate.
No. Partner availability and commercial terms change. We provide a structured search and coordination service but cannot guarantee a match, a transaction or a particular financial outcome.
A short email is enough to start. We reply within one business day with what we can do and a written proposal if it fits.
Include your fleet size, reporting period and deadline, and whether a verified compliance balance is available. Please do not send confidential vessel documents before we agree a secure way to receive them.
Marselling OÜ · Reg. no. 16967810 · Tallinn, Estonia. Scope and fees are confirmed in writing before engagement.
