As the FuelEU Maritime regulation enters into force, the shipping industry may be looking at a surprising upside. Instead of acting solely as a cost driver, the regulation could create a net financial gain, potentially around €250 million, according to a recent analysis by maritime data and compliance firm OceanScore.
“FuelEU isn’t just another penalty,” said Albrecht Grell, Managing Director at OceanScore. “It’s structured in a way that can push money back into parts of the industry — but only if you understand where and how that happens.”
Understanding the compliance landscape
OceanScore’s analysis focuses on the balance of GHG intensity compliance under FuelEU. The initial compliance deficit across vessels exceeding the regulation’s threshold is estimated at around 2.1 million metric tons (MT) of CO₂e, while more efficient vessels — mainly LNG and LPG carriers — generate a surplus of about 1.3 million MT of CO₂e.
That leaves a net compliance gap of roughly 0.8 million MT, which is likely to be closed using biofuels. These fuels, such as UCOME, have a lower calorific value and higher price point, but offer the advantage of emissions reduction credits and corresponding savings under the EU ETS.
At today’s prices, factoring in the ETS phase-in rate of 70% and current exchange rates, covering this compliance gap via biofuels is expected to cost the industry around €200 million, or €230 per MT of CO₂e. While that’s not insignificant, it’s a relatively modest figure for an industry of this scale.
What happens on the revenue side?
The other half of the story is about how emissions-related costs are passed on, especially in container, ferry, and cruise segments, which together make up nearly 50% of total emissions. In many cases, emissions surcharges are now included in COAs, and some are linked to FuelEU’s penalty levels.
“It’s not a universal practice, but we’ve seen a significant number of surcharges that shadow the penalty rates,” Grell said. “And when you run the numbers, even conservatively, the revenue side starts to look pretty interesting.”
OceanScore’s model assumes that just half of operators apply surcharges at two-thirds of the penalty rate, which equates to about €640 per MT of CO₂e. Under these conditions, total additional revenue could reach €450 million.
Subtracting compliance costs leaves a potential net gain of €250 million — although how sustainable that is remains uncertain.
“Windfalls like this don’t last forever,” said Grell. “But in the short term, there’s clearly value on the table. The trick is knowing how to capture it — and who actually does.”
Who benefits — and why managers matter
Who benefits from this value shift depends on where you sit in the value chain. Owners, charterers, and ship managers all have different exposure to compliance costs and different leverage in passing them along.
Charterers may aim to pass on more cost than they reimburse, owners will negotiate how these costs are handled, and managers - especially third-party ones - often sit at the center of compliance obligations.
“Ship managers are in a uniquely exposed position,” says Grell. “They carry the responsibility for compliance but typically operate on tight margins. The additional cost, for tools, processes, and reporting systems could quickly reach €3,000–4,000 per vessel annually.”
“Managers shouldn’t be shy about asking for their share of this upside.” Grell said. “They’re doing the heavy lifting, and it’s in everyone’s interest that they’re properly resourced to do it well.”
Preparing for a new compliance market
FuelEU doesn’t just introduce a new rule, it’s setting the stage for a compliance credit market. As operators buy and sell surpluses and deficits, pricing, liquidity, and strategy will become real levers for competitiveness.
OceanScore is working with shipping companies to help them navigate this evolving space, offering data-driven compliance tools, emissions strategy support, and access to pooling mechanisms.
“Whether you’re a charterer, an owner, or a manager, this is a moment to get ahead of the curve,” Grell said. “The costs are manageable, and the opportunity is real — but only if you’re prepared.”
