Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Action Date: Immediate

 

Dear All,

                  

This Newsletter aims to inform all concerned parties that the FuelEU Maritime verification period for the 2025 reporting year has commenced, and to outline the required actions, key deadlines, and compliance procedures for the 2026 compliance cycle.

This NL aims to ensure timely compliance with Regulation (EU) 2023/1805, including the application of flexibility mechanisms, verification of compliance balances, and issuance of the FuelEU Document of Compliance (DoC).

 

Responsibility for Compliance

The Company holding the Document of Compliance (DoC) under the ISM Code shall be responsible for FuelEU Maritime compliance. The DoC holder retains full liability for any penalties arising from non-compliance.

 

Verification Period – Key Milestones

By 31 March 2026 – Annual FuelEU Report Verification

The annual FuelEU report shall be verified by the appointed verifier within THETIS-MRV.

The report shall include the vessel’s Initial Compliance Balance, prior to the application of any flexibility mechanism.

 

By 30 April 2026 – Compliance Confirmation Deadline

Companies shall:

Create and submit a Compliance Balance Report in THETIS

Select and apply an appropriate flexibility mechanism, including

• Banking
• Borrowing
• Pooling
• Payment of penalty

Ensure all selected mechanisms are:

• Submitted
• Reviewed
• Approved by the verifier

 

Additionally:

-         - The verifier shall confirm the final compliance balance in THETIS

-         - Each vessel shall have a verified compliance balance by 30 April 2026

 

FuelEU Document of Compliance (DoC)

A FuelEU DoC shall be issued on a per-vessel basis, subject to compliance status:

 

Positive or Zero Compliance Balance

The vessel is eligible to receive the FuelEU DoC upon verifier confirmation

 

Negative Compliance Balance

-        - The Administering State shall calculate applicable penalties

-      - The DoC shall be issued only after settlement of penalties

-       - Payment instructions shall be provided directly by the Administering State

 

Required Actions by Stakeholders

Ship Owners, Managers, Operators, and Verifiers shall take the following actions:

 

1. Review Verified FuelEU Reports

Confirm each vessel’s compliance balance as verified by 31 March 2026

 

 

2. Assess Flexibility Mechanisms

Evaluate the applicability of:

• Banking
• Borrowing
• Pooling

 

Engage early with:

• Pooling partners
• Verifiers

 

3. Apply Compliance Strategy

Submit selected mechanisms via THETIS

 

4. Ensure approval by verifier

Alternatively, proceed with penalty settlement

 

5. Finalize Compliance Position

Ensure each vessel achieves a verified compliance balance by 30 April 2026

 

6. Complete Additional Verification Activities

Coordinate promptly with verifiers for any additional checks related to flexibility mechanisms

 

Failure to complete the above actions by 30 April 2026 may result in:

• Non-compliance status
• Financial penalties
• Delay or non-issuance of the FuelEU DoC

 

Additional Guidance

Stakeholders are encouraged to consult:

•          European Commission FuelEU Maritime Guidance
•        EMSA THETIS-MRV platform guidance and tutorials

 

Applicability

This Circular applies to:

• -        All vessels subject to FuelEU Maritime Regulation
• -     All PHRS-certified companies and vessels, where applicable

 

Conclusion

The FuelEU Maritime framework introduces a structured compliance cycle requiring:

• Accurate reporting
• Timely verification
• Strategic use of flexibility mechanisms

 

Early preparation and coordination with verifiers are essential to ensure full compliance and avoidance of penalties.

 

PHRS Head Office – March 27, 2026