FuelEU Maritime Pooling Market in 2026: Price Trends, Opportunities and Risks for Shipping Companies
A comprehensive guide to FuelEU Maritime compliance balances, banking, borrowing and pooling mechanisms. We also examine the significant decline in market reference prices following the first compliance period.
What Does FuelEU Maritime Regulate?
FuelEU Maritime has applied since 1 January 2025 and requires covered vessels to reduce the annual average greenhouse gas intensity of the energy used on board.
The system is not simply a fuel tax. It is a fuel- and technology-neutral performance standard.
The regulation generally applies to commercial vessels above 5,000 gross tonnage calling at European ports, regardless of their flag.
The calculation includes:
- 100% of energy used on voyages between EU ports,
- 100% of energy used during stays at EU ports,
- 50% of energy used on voyages between an EU port and a non-EU port.
The calculation is based on a well-to-wake approach. Therefore, it considers not only CO2 emissions from fuel combustion but also carbon dioxide, methane and nitrous oxide emissions generated throughout the fuel’s life cycle.
The reference value is 91.16 gCO2e/MJ, based on the 2020 EU MRV fleet.
The 2025 target requires a 2% reduction from this value, corresponding to a maximum annual average greenhouse gas intensity of approximately 89.34 gCO2e/MJ.
The targets become stricter over time:
2025: 2% reduction – approximately 89.34 gCO2e/MJ
2030: 6% reduction – approximately 85.69 gCO2e/MJ
2035: 14.5% reduction – approximately 77.94 gCO2e/MJ
2040: 31% reduction – approximately 62.90 gCO2e/MJ
2045: 62% reduction – approximately 34.64 gCO2e/MJ
2050: 80% reduction – approximately 18.23 gCO2e/MJ
Compliance Balance: How Are Surplus and Deficit Created?
Following the reporting period, a verifier calculates each vessel’s annual compliance balance.
A vessel performing better than the applicable greenhouse gas intensity target generates a positive balance, commonly referred to as a “surplus.”
A vessel performing worse than the target generates a deficit.
This balance is not an independent token circulating in a general registry. It is a regulatory calculation linked to a specific vessel and reporting period.
The value can only be transferred through mechanisms permitted under FuelEU and recorded in the FuelEU Database.
What Does Buying a FuelEU Credit Actually Mean?
Commercial parties frequently use the term “buying a FuelEU credit.”
From a legal perspective, the transaction should be understood as the contractual purchase of the right to receive an agreed portion of verified compliance surplus within a valid FuelEU pool for a specific reporting period.
Banking, Borrowing and Pooling
Banking
A positive compliance balance can be carried forward to future years through the FuelEU Database. According to the European Commission’s Q&A documents, banked surplus does not have an expiry date.
However, before relying on this balance, the company should ensure that it has been properly verified and recorded in the system.
Borrowing
A vessel may borrow the required amount from the following reporting period.
The borrowed amount is deducted from the following period’s balance with an additional 10% surcharge.
Therefore, borrowing does not eliminate the obligation; it postpones and increases it.
Pooling
Positive and negative balances from different vessels can be combined within a registered pool and allocated among participants.
However, the total pool balance cannot be negative. A vessel with a deficit cannot be placed in a worse position, and a vessel with a positive balance cannot be moved into a deficit position.
Vessels within the same pool do not need to belong to the same company. This allows bilateral or platform-based commercial transactions between companies with surplus balances and companies with deficits.
Each vessel may participate in only one pool for the relevant reporting period.
Critical Deadline for FuelEU Pooling
The selected verifier records the final pool structure and allocation in the FuelEU Database by 30 April of the verification period.
This database transaction is the point at which the commercial agreement becomes an actual compliance outcome.
A signed contract alone is not sufficient without a valid and timely database allocation.
How Did the First FuelEU Compliance Period Change the Market?
The 2025 reporting year was FuelEU Maritime’s first full compliance period.
Between January and March 2026, more than 13,000 FuelEU reports were verified.
By 30 April, more than 12,000 compliance balance reports had been successfully verified, covering over 90% of vessels.
EMSA also reported that the pooling mechanism was used by 90% of vessels.
The emergence of the first verified balances was important for price formation.
Before verification, the market largely relied on estimates related to fuel mix, voyage coverage, methane slip, biofuel sustainability and data quality.
Once the first balances were finalised, surplus providers began offering confirmed and verified quantities instead of estimated volumes. This reduced uncertainty and increased visible supply in the market.
How Much Have FuelEU Pooling Prices Fallen?
FuelEU does not publish an official market price for surplus.
Prices are commercially agreed between parties and vary according to the compliance year, verified quantity, transaction size, timing, counterparty risk and contractual terms.
According to OceanScore Pool-Price Index (OPX) data:
August 2025: EUR 193.63/tCO2e
January 2026 – 2025 surplus: EUR 213.00/tCO2e
July 2026: EUR 131.75/tCO2e
24 August 2026: EUR 118.90/tCO2e
The decline between August 2025 and August 2026 was approximately 38.6%.
Compared with the January 2026 level of EUR 213/tCO2e, the August 2026 price was approximately 44.2% lower.
BetterSea reported a volume-weighted average transaction price of EUR 106.52/tCO2e for July 2026 and a weighted level of EUR 114.00/tCO2e at the end of the month.
During the same period, OceanScore’s offer-based OPX stood at EUR 131.75/tCO2e.
This difference demonstrates why contracts should clearly specify the index used, observation date, transaction volume, and whether the price represents offers or completed transactions.
Why Have Prices Fallen Since the First Year?
The decline cannot be explained by a single factor.
The main reasons include:
- Verified surplus volumes becoming visible
- Rapid adoption of pooling
- The initial 2% reduction target remaining unchanged until 2029
- Biofuel and fuel-mix optimisation generating additional surplus
- Increased market price transparency
- Lower demand pressure following the April deadline
- The ability to bank surplus for future years
Does a Lower Price Mean FuelEU Is Now Cheap?
No.
A lower EUR/tCO2e price alone does not mean that a transaction is economically attractive.
Buyers should compare pooling costs with the marginal cost of direct compliance.
This calculation should consider factors such as:
- Sustainable fuel premium,
- Energy content,
- Life-cycle emission factor,
- Operational constraints,
- EU ETS impact,
- Allocation of charter-party obligations.
The FuelEU penalty should also not be treated simply as a maximum market price.
The penalty system is designed to make non-compliance economically unattractive and may increase in cases of repeated deficits.
What Should a Strong FuelEU Pooling Agreement Include?
A FuelEU pooling agreement is not simply a commodity purchase agreement. Commercial payment should be linked to a verified regulatory allocation within a defined timeframe.
The agreement should clearly address:
- Compliance year and vintage
- Quantity and unit used
- Verification status of the surplus
- Vessels participating in the pool
- Assigned verifier
- FuelEU Database transactions
- Fixed price or applicable price index
- Index publication date and volume range
- Currency, taxes and rounding method
- Prevention of the same surplus being sold elsewhere or banked
- Remedies for insufficient surplus
- Responsibilities for late registration or database errors
- Counterparty credit risk
- Allocation of costs and economic benefits under the charter party
- Regulatory changes and force majeure
Action Plan for Shipping Companies in 2026–2027
- Estimate each vessel’s compliance balance monthly using verified fuel pathways, voyage coverage and methane slip assumptions.
- Separate outstanding 2025 matters, current 2026 exposure and forward planning for 2027.
- Establish internal rules for when surplus should be banked or sold.
- Conduct a make-or-buy comparison between direct fuel use and pooling.
- Select counterparties and verifiers before the final weeks of April.
- Use contracts that link payment milestones to objective verification and database transactions.
- Monitor multiple market references and document why the selected benchmark is appropriate in terms of transaction size and timing.
Frequently Asked Questions
Is FuelEU Surplus an EU-Traded Carbon Allowance Like an EUA?
No. An EUA is an allowance that can be transferred within the Union Registry. FuelEU surplus is a compliance balance linked to a specific vessel and can be banked, borrowed or allocated through pooling under FuelEU rules.
Who Determines the Pooling Price?
The regulation does not set a price. The price is commercially negotiated between the buyer and seller.
Can Any Two Vessels Join the Same Pool?
Covered vessels may participate in the same pool, even if they belong to different companies, provided they comply with the regulatory requirements.
Why Can an Offer Index Be Higher Than a Transaction Index?
Offer indices reflect sellers’ asking prices, while transaction indices reflect prices actually agreed between buyers and sellers. Volume, timing and transaction size can create differences.
Will FuelEU Prices Remain Low?
There is no guarantee. Lower surplus generation, stricter targets, changing fuel prices, banking decisions or increased demand near the deadline could tighten the market again.
What Is the Most Important Contractual Protection?
The seller’s right to payment should be conditional on the agreed surplus amount being verified, allocated on time and legally valid in the FuelEU Database.
Important Disclaimer
This article is for general informational purposes only. It does not constitute legal, tax, investment or trading advice. Organisations should verify current legislation, guidance from competent authorities, contractual obligations and their own risk limits before entering into any transaction.