Key Deadline Fast Approaching

The deadline for confirming pooling arrangements for Reporting Period 1 under the FuelEU Maritime Regulation is 30 April 2026.

Ship owners, operators, charterers and other industry players who intend to participate in a FuelEU compliance pool must ensure their pooling arrangements are finalised and recorded by the selected pool verifier in the FuelEU database by the end of this month.

Benefits of FuelEU pooling to achieve compliance:

• Avoids having to pay the penalty.
• Avoids the multiplier effect incurred in the event of cumulative penalty payments.
• Presently, the pooling market is cheaper than paying the penalty.
• There is no need for vessels to be in the same ownership or management to form a pool.
• There are independent third-party providers of such pooling arrangements — you don't need to figure out the pooling arrangements yourself. But make sure the terms you sign up to achieve the intended result!

FuelEU Pooling is not just an operation tool – it requires careful contractual and regulatory consideration. With the deadline imminent, we are seeing an increase in requests relating to pooling arrangements.

Practical considerations and top tips for FuelEU pooling arrangements:

• Ensure the requirements to enter the pool are robust.  Members of the pool should hold the pooling rights.
• Who are you pooling with? Counterparty due diligence.
• Consider the structure of the pool / methodology for sharing compliance balances.
• Timings under the arrangement – who does what, when and where?
• Data sharing / confidentiality.
• Risk allocation in the event of non-compliance / pool collapse.
• Termination rights.

The above lists are not exhaustive but highlight key points for consideration. With the deadline approaching, participants from across the shipping industry are proactively engaging in ensuring compliance with FuelEU Maritime, with pooling arrangements being a prominent feature.