What happens if your FuelEU pool fails? The execution risk under FuelEU Maritime in International Shipping News 27/04/2026 Today, pooling is widely recognised as a reliable compliance mechanism under FuelEU Maritime. In most commercial discussions, the underlying assumption is that once a pool is agreed, it will be executed. This assumption deserves closer investigation. In practice, pooling is not a single step but a multi-stage process with dependencies and hard deadlines. The successful execution of a pool requires that each of these steps is completed correctly and in sequence by all pool participants. Failure at any point, even by only a single participant, can prevent the pool from successful execution. The consequence is straightforward: if the FuelEU pool fails, the compliance position reverts to the individual vessel level, with all associated penalties and constraints. FuelEU reporting depends on everyone The actual regulatory execution of a pool requires alignment across all participating companies, their verifiers, and the responsible entities (if different) accessing the FuelEU Database. Each vessel must first have its data verified on time (March 31). While this may appear to be a straightforward and easily achieveable requirement, delays at the verification stage are already emerging. Where a single pool participant does not have verified data available, the pool cannot progress as initially intended. Even when verification is completed, the process’ next step depends on timely agreement of surplus allocation. If one party delays in confirming its position, the entire pool cannot be initiated, which directly impacts the ability to meet reporting deadlines. Not only the pool participants but also the pool starter company introduces an additional dependency. If the pool is not initiated and submitted for approval in time, the window for coordination across all parties narrows. Given the number of entities typically involved, even small delays at this stage can become critical. Once submitted, each participating company must approve the pool. Here again, the process is only as strong as its weakest link. A single delayed or withheld approval prevents the pool from moving forward. Finally, the pool must be verified. Even where all prior steps have been completed, delays at the verifier level can still prevent timely completion. Verification capacity constraints or requests for clarification may extend timelines beyond what was initially assumed. Intermediaries amplify execution risk These dependencies become materially more complex in the presence of intermediaries. In some pooling structures, surplus is not directly exchanged between the parties that ultimately participate in the pool. Instead, it is traded through chains involving traders, or other intermediaries. These structures introduce additional layers between the surplus-generating vessel and the party responsible for reporting. Each additional layer increases the distance between commercial agreement and operational execution. Information must be passed along the chain, reporting instructions must be translated into actionable steps, and responsibilities must be aligned across parties that may not have direct contractual relationships with each other. This creates multiple potential points of failure. Critically, the party that trades the surplus often has no direct control over whether the necessary actions are ultimately taken. As a result, intermediaries do not m