Infrastructure Briefing — January 10, 2026
FuelEU Maritime’s 2% greenhouse-gas intensity cut took effect in 2025; 2026 brings the first compliance reconciliations, OPS readiness checks, and pooling decisions for shipowners calling at EU ports.
Executive briefing: Regulation (EU) 2023/1805 (FuelEU Maritime) has applied since January 1, 2025, requiring ships above 5,000 gross tonnage arriving at or departing from EU ports to cut the greenhouse-gas intensity of energy used on board by 2% relative to the 2020 baseline. The first monitoring, reporting, and verification cycle spans the 2025 calendar year, with compliance documents due in 2026 and civil penalties for any excess emissions intensity. Shipowners and charterers must choose whether to pool vessels, claim onshore power supply use at berth, and hedge alternative fuel availability to avoid shortfall costs.
Compliance checkpoints
- Data pipelines. Integrate noon reports, fuel sampling, and voyage activity data with EU MRV templates so that verifiers can confirm total energy used, well-to-wake factors, and any exemptions for safety or force majeure events.
- Pooling elections. Decide which vessels will be pooled for 2025 reporting and document the governance for allocating penalties or rewards between owners and charterers.
- Onshore power supply evidence. Capture metering data and grid connection certificates for ships using shore power at container, cruise, and passenger terminals to claim corresponding GHG intensity reductions.
Operational readiness
- Fuel contract terms. Ensure bunker agreements include sustainability attributes, upstream emission factors, and dispute clauses for failed deliveries that could jeopardize 2025 compliance positions.
- Port interface testing. Validate compatibility of shipboard electrical systems with EU onshore power standards and test safety procedures with terminal operators before peak-season calls.
- Change management. Train deck and engineering teams on recordkeeping, alternative fuel handling hazards, and fallback procedures if biofuel or e-fuel blends fail quality checks.
Evidence for verifiers
- Maintain reconciled bunker delivery notes, laboratory test certificates, and voyage emissions calculations ready for accredited verifier review early in 2026.
- Track any non-availability claims for compliant fuels and retain correspondence with port authorities to justify exemptions.
- Update CII and EU ETS reporting teams so FuelEU Maritime data aligns with other decarbonization disclosures and prevents double counting of reductions.
Sources
Zeph Tech maps FuelEU Maritime monitoring requirements to voyage, bunker, and shore power data flows so operators can defend 2026 verifier reviews and penalty calculations.