Compliance mechanism
Use fuels or energy with lower well-to-wake GHG intensity
- Comes with higher fuel costs
- Emission factors remain uncertain until a Proof of Sustainability (PoS) is issued
- Some biofuels present operational risks. For example, Cashew Nutshell Liquid (CNSL) based fuels have been linked to clogged filters, injector malfunctions, sludge formation, and corrosion
- Market supply may be constrained, creating availability challenges.
Pay the penalty cost
- Any ship still in deficit after banking, borrowing, or pooling must pay a penalty
- Penalty level: €2,400 per tonne VLSFO-eq (≈ €640 per tonne CO₂e at typical fossil intensity)
- The penalty increases by 10% for each consecutive year a ship remains noncompliant
- The penalty per tonne increases as a ship’s actual GHG intensity decreases, so it is usually more cost-effective to fully comply one vessel and pay the penalty on the other, rather than spreading low-carbon fuel across both and leaving both partially non-compliant.
Flexibility mechanism
PROS
CONS
NEUTRAL
Banking
Surplus from a compliant ship can be banked indefinitely
Can be used in any future year
(e.g., 2025 → 2040)
Must repay the borrowed amount +10%
Borrowing
Ships with a deficit may borrow from next year
Must repay the borrowed amount +10%
Limits: max 2% of required intensity × annual energy use
Not allowed in two consecutive years
If the ship has no FuelEU activity next year or is scrapped → penalty applies
Pooling
Two or more ships can combine balances to meet the requirement
Rules:
- Total pool balance must be positive,
- No ship’s deficit may increase,
- No ship with surplus may fall into deficit
Surplus after pooling can be banked
Pooled ships cannot borrow
Only one pool per year; remaining deficits must be settled with penalties
Pooling mechanism
Two or more ships, including ships from different companies, can join a compliance pool and re-allocate compliance balance between the individual ships. This means that even if each individual ship does not meet the required GHG intensity, the ships with a negative compliance balance can rely on other ships with positive compliance balance to achieve a combined GHG intensity level meeting the GHG intensity requirement.
A compliance pool must meet the following criteria:
- the total compliance balance of all ships is positive
- ships which had a compliance deficit do not have a higher compliance deficit after the reallocation of the compliance balance
- ships which had a compliance surplus do not have a compliance deficit after the reallocation of the compliance balance
A ship that achieves a positive compliance balance after reallocation in a pool may bank its surplus for use in subsequent reporting periods. However, vessels joining a pool are prohibited from borrowing compliance balances from future periods. If a ship maintains a negative compliance balance following pool participation, it becomes liable for penalty payments. Importantly, each vessel may only participate in a single pool per annual reporting cycle under FuelEU Maritime regulations.
What is KICKSTER FUELEU MARKETPLACE?
When does pooling happen?
- 31th December: FuelEU consumption for the year closes; balances are fixed.
- March: verified balances appear on THETIS.
- 1st–30th April: official pooling window. If pooling isn’t completed by 30th April, the penalty applies. April is also when surplus can be banked or deficits borrowed.
Who pays?
FuelEU Maritime still does not define a clear “polluter pays” rule. That leaves cost allocation open between owners, charterers, and managers.
The start/end gap
When pooling spans only part of a charter, the opening and closing months often fall outside the pool.
These uncovered periods require separate agreements and are becoming more commercially significant as pooling prices rise.
How does FuelEU pooling reduce costs
Without pooling, ships over the annual GHG limit must either:
- pay €640 per tonne of CO₂ in penalties, or
- switch to low-/zero-carbon fuels that can cost 23× more than conventional fuels.
- Pooling creates a market alternative:
- Vessels with surplus (e.g., using biofuels or operating efficiently) can sell credits.
- Vessels with deficits can buy that surplus instead of paying full penalties or changing fuels.
This typically costs less than one-third of the penalty, avoids technical and operational risks, and allows banking or selling surplus during the April pooling window. In short: pooling turns compliance into a shared, market-driven system that lowers total costs across the industry.
What will set KICKSTER FUELEU MARKETPLACE apart?
Kickster’s marketplace is built on transparency, fairness, and industry trust:
- Multiple offers from multiple providers a true market view, not a single non-transparent price
- No hidden commissions or margins, only a small onboarding fee
- Direct counterparties for all deals
Pooling applies only to full calendar years
Pooling works on full-year compliance balances. Partial years are difficult to pool. Example: a 3-year charter often includes:
- 2 partial years
- 2 full years
Only those two full years can easily be pooled.
Not every vessel will enter a pool
Pooling under FuelEU won’t be universal. It will depend on charter duration, segment, and timing. In practice, “my charterer will handle pooling” won’t always hold. Managing 2025 compliance will require transparency, flexibility, and continuous tracking.
Case study
Best compliance option
#OPTION 1
PAY THE PENALTY
- Easiest operationally, but by far the most expensive
- Penalties escalate if non-compliance continues year after year
- Offers no flexibility or strategic benefit
#OPTION 2
SWITCH TO BIO30 (30% BIOFUEL + 70% FOSSIL DIESEL)
- Meets FuelEU compliance through emission reductions higher fuel costs (+€209/t)
- Uncertain emission factors until Proof of Sustainability (PoS) arrives
- Technical risks reported with certain biofuels (e.g., Cashew Nutshell Liquid (CNSL))
- Biofuels: clogged filters, injector failures, sludging, corrosion
- Supply availability can be limited
#OPTION 3
POOLING
- Purchase surplus from over-compliant vessels at ~€250/t CO₂e
- Lowest overall compliance cost
- No operational or technical risks Flexible:
- buy only what you need
- bank surplus for future years
- lock in lower prices before demand increases
