FuelEU compliance through internal pools and green digital ship twins
A new report by Dr Aslı Arda from the University of Copenhagen, Faculty of Law, developed within ShippingLab’s SLGreen project, looks at how FuelEU Maritime compliance can be operationalised in practice.
FuelEU sets clear targets for reducing greenhouse gas intensity in shipping, but it does not specify how technologies and operational measures should be implemented.
The report identifies a “deployment gap” between the regulatory framework and its operational legal translation. It highlights that the challenge lies not in FuelEU’s level of ambition, but rather in how its translated into practice. At the centre of this gap are questions of governance: how technologies are used, how data is accessed and shared, and how responsibility, cost, and risk are allocated between actors.
From framework to practice
The report highlights internal FuelEU compliance pools and green digital ship twins as mechanisms that can support this transition. Pooling allows compliance to be managed across multiple vessels, while responsibility remains with the individual Document of Compliance (DoC) holder.
Green digital ship twins enable continuous monitoring of fuel consumption, emissions, and operational performance. Such a continuous function can evidently support FuelEU’s monitoring and verification requirements.
The role of contracts
A key point in the report is the role of contractual structures. Charterparties and internal agreements can define how digital twins are used, how data is shared, and how risks and responsibilities are allocated. In this way, contracts can link technical capabilities with compliance requirements.
A structured approach to compliance
According to the report, internal pools supported by digital twins can function as compliance-facilitating structures, particularly in the early stages of FuelEU implementation. They provide a structured way to operationalise regulatory requirements, including governance, data management, and contractual alignment.
The report was developed by Dr Aslı Arda, University of Copenhagen, Faculty of Law, as part of the SLGREEN project under ShippingLab. ShippingLab is supported by Innovation Fund Denmark, the Danish Maritime Fund, Lauritzen Fonden, Orient’s Fond and DS Norden.
