Who is responsible for ensuring compliance with the Fuel EU requirements?

The shipping company is responsible for ensuring compliance with the requirements of the Fuel EU regulation. As per regulation EU 2015/757 (MRV), the ‘company’ means the shipowner or any other organisation or person, such as the manager or the bareboat charterer, which has assumed the responsibility for the operation of the ship from the shipowner and has agreed to take over all the duties and responsibilities imposed by the International Management Code for the Safe Operation of Ships and for Pollution Prevention.

By 31 August 2024 – Monitoring plans

Shipping companies will need to submit a monitoring plan to verifiers for assessment for each of their ships, indicating their chosen method to monitor and report the amount, type and emission factor of energy used onboard.

For ships falling under the scope of this Regulation for the first time after 31 August 2024, companies shall submit a monitoring plan to the verifier without undue delay and no later than two months after each ship’s first call at a port under the jurisdiction of an EEA Member State.

From 1 January 2025 – Recording information

Based on the monitoring plan, each company will need to record the following information on an annual (1 January to 31 December) basis, for each of its ships arriving at, berthed at or departing from an EEA port:

  • The port of departure and port of arrival including the date and hour of departure and arrival and time spent at berth;
  • the connection to and use of on-shore power supply (OPS) or the existence of any of the exceptions (mandatory for container and passenger ships);
  • the amount of each type of fuel consumed at berth and at sea;
  • the amount of electricity delivered to the ship through OPS;
  • the well-to-wake emission factors for each type of fuel consumed at berth and at sea, broken down by well-to-tank, tank-to-wake and fugitive emissions, covering all relevant greenhouse gases; 
  • the amount of each type of substitute source of energy consumed at berth and at sea;
  • the ship’s ice class, if the company requests to exclude the additional energy used due to ship’s ice class from the calculation of the compliance balance; and 
  • the ship’s ice class, the date, time and position when entering and leaving the ice conditions, the amount of each type of fuel consumed and the distance travelled when sailing in ice conditions as well as the total distance travelled for all voyages during the reporting period, if the company requests to exclude the additional energy used due to sailing in ice conditions from the calculation of the compliance balance.

By 31 January 2026 – Information submission

By 2026, and in each subsequent year, by 31 January the company is to provide the verifier the information listed above (in recording information) for each of its ships falling in scope of Fuel EU. This shall be submitted in the form of a FuelEU report. 

In the event a ship transfers from one company to another part way through a reporting year the transferring company must send the above listed information to their selected verifier. The verifier within one month (and as close as possible to the completion date of transfer) should verify the data and record it in the Fuel EU database . The company that has responsibility for the ship on 31 December of any reporting period will be responsible for compliance of the ship with Fuel EU during the entire reporting period during which the transfer(s) took place. i.e. any surplus of deficits in GHG intensity remain with the ship when company ownership changes. 

By 31 March 2026 – Notification of verification activities

From 2026, and in each subsequent year, by 31 March, the verifier will have completed their verification assessment of the submitted Fuel EU report, notified the company and recorded in the Fuel EU database the:

  • Verification report, stating as applicable that the vessel complies with the Fuel EU regulation, in addition to the corresponding vessel Fuel EU report.
  • Yearly average GHG intensity of the energy used on board.
  • Ship’s compliance balance.
  • Number of non-compliant port calls in the previous reporting period including the time spent moored at the quayside and, where applicable at anchorage, for each port call requiring OPS.
  • Amount of the yearly energy used on board by a ship, excluding energy from OPS.
  • Amount of the yearly energy used on board by a ship from the RFNBO.

By 30 April 2026 – Use of flexibility compliance mechanisms

From 2026, and in each subsequent year, by 30 April companies are to notify verifiers of their intention to utilise a flexibility compliance mechanism. Flexibility compliance mechanisms include banking, borrowing, or pooling to share compliance and minimise financial exposures and shall be recorded in the Fuel EU database. 

By 30 April 2026 – Reporting

From 2026, and in each subsequent year, by 30 April the verifier will have reported the following information back to the company:

  • The ship’s yearly compliance balance, accounting for any flexibility compliance mechanisms applied.
  • The sub target for RFNBO (if applicable).
  • Fuel EU penalty (if applicable).

On 1 May 2026 – Penalties

From 2026, and in each subsequent year, on 1 May, a company will be liable to pay a penalty if the ship:

  • Has an outstanding GHG intensity compliance deficit.
  • Does not meet the RFNBO sub target (as/when applicable).
  • Has had any non-compliant port calls with regards to onshore power requirements (from 2030).

The funds raised from the penalties will be allocated to support common projects aimed at decarbonising the maritime sector.

By 30 June 2026 – Fuel EU document of compliance (DoC)

From 2026, and in each subsequent year, by 30 June:

  • The verifier will issue a Fuel EU document of compliance for the ship provided the ship has no compliance deficit or non-compliant port calls.
  • The administering authority will issue a Fuel EU document of compliance for any ship that has a compliance deficit, provided that any outstanding penalties have been paid. 

The Fuel EU DoC will be valid until 30 June in the subsequent year. Vessels in scope of Fuel EU and entering an EEA port will have to carry a valid Fuel EU DoC.

Failure to present a Fuel EU DoC for two or more consecutive reporting periods could result in a ship being banned from the EU.

From 1 January 2030 – Zero-emission berthing

Container and passenger vessels entering EEA ports will need to connect to onshore power supplies  to meet new zero-emission at berth requirements at major TEN-T ports. There are several exceptions to the requirements, which include staying at port for less than two hours, using zero-emission technology onboard whilst at berth or making a port call due to unforeseen circumstances or emergencies.

Failure to connect will result in a penalty.

From 1 January 2035 – Zero-emission berthing

Container and passenger vessels entering EEA ports will need to connect to onshore power supplies  (where they are available) to meet new zero-emission at berth requirements at all EU ports.

Back to LR FuelEU Maritime Regulation