Shipping companies are facing potentially significant financial consequences from errors in their first FuelEU Maritime (FEUM) submissions, with some mistakes resulting in penalties and missed claims worth tens or even hundreds of thousands of euros.
According to maritime emissions verification specialist Normec Verifavia, which provides independent compliance and verification services to more than 1000 vessels, the inaugural year of FuelEU Maritime reporting has exposed a range of reporting and calculation errors as operators navigate the new regulatory framework.
“Incorrect returns can be extremely costly,” said Shubham Jain, Client Director – Shipping at Normec Verifavia. “Errors can arise both from the underlying data and from the methods used to calculate compliance balances and penalties.”
“We have seen cases where errors in reported data led to the miscalculation of penalties, resulting in financial impacts ranging from approximately €10,000 to €150,000. FuelEU Maritime compliance depends on the accurate submission of voyage and fuel consumption data, robust calculation methodologies, and the correct allocation of fuels under the regulation’s prioritisation rules. Errors at any stage can lead to inaccurate greenhouse gas (GHG) intensity values and Compliance Balances.”
Jain explained that because GHG Intensity, Compliance Balance and FuelEU penalties are intrinsically linked, inaccuracies at any stage of the calculation chain can result in corresponding overstatements or understatements of financial liability. Independent verification therefore plays a critical role in identifying and correcting errors before compliance reporting is finalised.
Another key challenge relates to the prioritisation and redistribution of fuels under FuelEU Maritime. Incorrect fuel allocation can materially distort GHG Intensity and Compliance Balance calculations, leading to an inaccurate distribution of FuelEU-related costs, penalties, and compliance surpluses. This is particularly relevant in charter operations, where contractual arrangements govern the allocation of compliance responsibilities between the shipowner and the charterer. If fuel allocation methodologies are not transparent, consistently applied and fully aligned with regulatory requirements, discrepancies may give rise to commercial disputes over the fair allocation of FuelEU-related costs.
Jain noted that “the treatment of biofuels remains a particular area of concern, with incorrect accounting leading to operators paying more than necessary to meet their compliance obligations. Even small errors in allowance calculations can lead to substantial financial impacts.
One operator, for example, had underreported its emissions and was able to submit a corrective claim to its charterer worth approximately €60,000.”
“The consequences become even more significant when vessels are participating in pooling arrangements,” he said. “Errors affecting one vessel can have wider implications across an entire pool.”
The introduction of FuelEU Maritime has added a new layer of complexity to shipping’s decarbonisation compliance requirements. While the regulation is intended to encourage the uptake of lower-carbon fuels and reduce greenhouse gas emissions from shipping, compliance costs can be substantial, making accurate reporting increasingly important.
Normec Verifavia argues that many of the problems encountered during the first reporting cycle stem from outdated data collection practices.
“There are still too many organisations relying on manually completed spreadsheets that are submitted months after voyages have taken place,” Jain said.
While some operators continue to use spreadsheet-based systems, the majority of the company’s clients now transfer operational data directly from onboard systems through automated interfaces. The most effective operators provide data on a voyage-by-voyage basis, allowing compliance costs to be tracked continuously and anomalies identified promptly.
By contrast, companies that submit several months of voyage data at a time often face significant challenges when discrepancies are identified.
“If we need clarification several months after a voyage, crew changes may have taken place and knowledge of the circumstances of a particular voyage can be lost,” Jain explained. “At that point there is often heavy reliance on written records held on the ship, and resolving issues can become time-consuming and resource-intensive, particularly when reporting deadlines are approaching.”
Jain also believes many operators continue to overlook the derogations and exemptions available under FuelEU Maritime.
“Operators do not always recognise that certain voyages, ports, ship categories or operational circumstances qualify for specific derogations or exemptions under the Regulation,” he said. “That can result in unnecessary compliance obligations, inaccurate GHG intensity calculations and inflated compliance deficits or penalties.”
He added that one of the important aspects of independent verification is reviewing a vessel’s operational profile against the regulatory framework to identify where exemptions or special provisions may legitimately apply. While responsibility for compliance remains with the operator, independent verification provides an important safeguard against regulatory misinterpretation and future compliance disputes.
Looking ahead, Jain believes compliance reporting should become an integral part of voyage planning rather than an administrative exercise conducted after the event.
“Good voyage planning drives emissions reductions,” he said. “If compliance monitoring is integrated into operational decision-making from the outset, reporting becomes much more straightforward and operators gain a clearer understanding of their compliance position throughout the year.”
Achieving FuelEU Maritime compliance is no longer simply a reporting exercise. It requires early voyage planning, robust emissions forecasting, effective coordination between shipowners, charterers and managers, careful evaluation of sustainable fuel options, and continuous verification of operational data. As operators gain experience with the regulation, compliance management is becoming an integral part of commercial and operational decision-making rather than a year-end administrative task.
With FuelEU Maritime now entering its second year, the lessons from the first reporting cycle are becoming increasingly clear. While fuel selection will remain central to reducing compliance costs, accurate data management, timely reporting and independent verification are proving just as critical. For many operators, investing in robust compliance processes today may ultimately prove the most cost-effective way of avoiding unnecessary penalties, commercial disputes and missed financial opportunities.
