Distinct Systems: FuelEU and EU ETS
The FuelEU Maritime and EU ETS regulations operate under separate frameworks. The EU ETS requires the surrender of EUAs based on CO2 emissions, while FuelEU monitors whether a vessel's onboard energy usage meets greenhouse gas intensity standards. A ship that has already fulfilled its EU ETS obligations may still face a FuelEU penalty if a compliance deficit remains after verification, provided it has not been offset through a pool, banking, or borrowing mechanism. Such penalties do not require shipowners to calculate amounts manually. In practice, the process relies on two key pages within THETIS-MRV: first, check the FuelEU Report for any deficit; second, review the Penalties section within Compliance Balances to find the penalty amount, payment account details, and the submission portal for proof of payment.
Step One: Identifying a Deficit in the FuelEU Report
If a vessel's FuelEU Report has been completed, the deficit can be found by navigating through THETIS-MRV as follows: Log in, go to MY FLEET, select the specific vessel, click Actions, then FEU report, followed by Energy GHG Intensity, and finally Initial compliance balance. The key figure here is the Initial Compliance Balance. A negative number indicates the vessel has a FuelEU compliance deficit. The interpretation is straightforward: a positive balance means a surplus, zero indicates perfect compliance, and a negative balance signifies a deficit. If this negative figure is not resolved through pooling, banking, or borrowing, it will proceed to the penalty process.
Step Two: Determining the Penalty Amount on the Penalties Page
The penalty amount and payment instructions are located on a separate page: Compliance Balances. Select the relevant vessel and then click on Penalties. On this Penalties page, pay close attention to four key items. The Verified Compliance Balance shows the deficit after verification, for example, -1.15 tCO2e. The Compliance balance Penalty displays the amount due, such as 742 EUR for this vessel. The Comments / instructions payment section contains the administering authority's payment instructions, receiving account details, and payment deadline. If this section is blank, you must contact the AA or Administering State to request payment guidance. Finally, the Proof of payment and Submit payment to AS section is where you upload the payment confirmation after the transaction is completed and submit it to the authority.
Step Three: Verifying Information Before Payment
Before making the payment, cross-reference the THETIS-MRV page with the payment instructions from the administering authority. Key details to verify include the vessel name, IMO number, company name, reporting period, penalty amount, payee, IBAN, SWIFT/BIC code, and payment deadline. Also, check if any specific remarks are required, such as an invoice number, reference number, CIF, or VAT number. Payment remarks should strictly follow the official requirements. If no specific format is required, a suggested structure is: FuelEU penalty / vessel name / IMO / reporting period / company name / reference or invoice number. Be mindful of bank transaction fees. Administering authorities typically require the full penalty amount to be received. Therefore, you should select the option for the payer to cover all transaction fees to ensure the recipient receives the exact penalty amount.
Step Four: Uploading Proof of Payment in THETIS-MRV
After the payment is made, return to the Penalties page. In the Proof of payment area, upload the bank transfer receipt or payment confirmation document. Then, click Submit payment to AS to send it to the Administering State. It is recommended to keep a comprehensive record of the payment, including the bank transfer receipt, a screenshot of the successful payment, a screenshot of the THETIS-MRV Penalties page, the payment instructions or invoice from the authority, and the FuelEU Report or Compliance Balance Report.
Step Five: Confirming the Availability of the FuelEU DOC
Paying the penalty is not the final step. After the administering authority confirms the payment, the shipowner must return to the Document of Compliance page in THETIS-MRV to check if the FuelEU Document of Compliance (DOC) can be downloaded. The DOC is a document that may be required for port state control inspections, charter party compliance, and when charterers request compliance documentation. Once obtained, it is advisable to save the PDF and a system screenshot.
Key Timeline and Deadlines
The process has several critical dates. By January 31st of the following year, the shipowner must submit the previous year's FuelEU Report. The verification body must complete its verification by March 31st, after which the compliance balance appears in the system. By April 30th, actions like pooling, banking, or borrowing to offset deficits should typically be completed. From May onwards, vessels with unresolved deficits begin penalty preparations. As of June 1st, a FuelEU penalty applies to any remaining deficit according to the regulations. The penalty payment must be completed by June 30th, and the process for obtaining the FuelEU DOC should be advanced. Note that the actual pace of these processes can vary by EU Member State administration. Some may provide the receiving account details directly in the Comments / instructions payment section of THETIS-MRV, while others may send payment instructions or an invoice separately via email. In all cases, the final authority rests with the THETIS-MRV page and the official guidance from the administering state.
Financial Implications of Penalties vs. Pooling
Paying a penalty is an option, but it may not be the most cost-effective. For a conventional fuel vessel with a 50-tonne FuelEU deficit, a rough estimate of the direct penalty is around 32,000 EUR. If the same deficit were addressed by purchasing compliance surplus through a pool, based on some pool resource quotes in the current market, the cost per tonne could be approximately 400 EUR cheaper than the penalty. This means a 50-tonne deficit could potentially save about 20,000 EUR. There are also timing differences. If a pool is formed and verified by the end of April, the DOC can often be obtained earlier. The penalty route, which involves waiting for the penalty amount, making the payment, uploading proof, and awaiting confirmation from the authority, often extends into June, July, or even later.
Earlier this year, we assisted several shipping companies in joining an international FuelEU pool, guiding them through the entire process from deficit confirmation and pool matching to compliance balance adjustment. We do not charge an additional service fee for participating in a pool through us. In principle, the shipowner pays only for the tonnes of compliance surplus purchased, with no extra consulting, service, or handling fees. If your company had vessels calling at the EU in 2026 or expects to have EU voyages in the second half of the year, we recommend registering your interest now. Registration does not constitute a commitment to join the pool and creates no payment obligation. We will first assess the potential FuelEU deficit based on the vessel's EU voyages and fuel consumption. This will be followed by a discussion on next steps, considering the pool resources and price window for the coming year.
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