What does Halyard save your fleet this year?

Type a ship's IMO number, or your company's. We read your ship's public EU MRV report for 2025 and price this year at 2026 rules.

Your fleet, foundIn the public EU MRV reports for 2025, under the company that holds its Document of Compliance.
A work email unlocks the figuresYour carbon bill, what Halyard saves you this year, the risk removed, the price and the payback, ship by ship.
Yours to adjustUntick ships, add or edit them, set your team's figures. The totals follow.

How we got these numbers

The deadlines, what a miss costs and who has paid it, each line of your saving with its dated constants, and every source. Penalty rates are official; the ranges for Halyard's own saving are estimates.

The five deadlines

Each deadline, who acts, and what a miss does.

Deadline	Obligation	Who acts	If missed	Source
31 January	FuelEU report per ship to the verifier	FuelEU company (ISM DoC holder)	National sanctions; verification and Document of Compliance delayed	DNV, FuelEU compliance timeline (opens in a new tab)
31 March	Verified MRV ship and company reports to the administering authority; verified emissions in the Union Registry; FuelEU balance recorded	ETS shipping company, verifier	National fines; registry account can be blocked, which blocks surrender	European Commission, ETS maritime FAQ (opens in a new tab)DEHSt, German fines (TEHG § 49) (opens in a new tab)
30 April	FuelEU pooling, banking and borrowing recorded	FuelEU company, verifier	The deficit goes to penalty	DNV, FuelEU compliance timeline (opens in a new tab)Watson Farley & Williams, FuelEU first deadline (opens in a new tab)
30 June	FuelEU penalty paid; FuelEU Document of Compliance issued	FuelEU company, verifier	No Document of Compliance; two or more consecutive periods can lead to an expulsion order	DNV, FuelEU compliance timeline (opens in a new tab)Clyde & Co, FuelEU penalties (opens in a new tab)
30 September	Surrender allowances for the prior year (70% of 2025, 100% of 2026 onward)	ETS shipping company (registered owner, or ISM company by mandate)	€135.31 per missing tonne, allowances still owed, company named publicly	DEHSt, sanctioning, penalty €135.31 (opens in a new tab)NEa, enforcement of the surrender obligation (opens in a new tab)

Phase-in: 40% of 2024 emissions, 70% of 2025, 100% from 2026. Coverage: 100% of intra-EU voyages and port stays, 50% of voyages between the EU and a non-EU port. Source: European Commission, ETS maritime FAQ (opens in a new tab).

What a miss costs

The EU ETS surrender, the FuelEU penalty, and the national fines for late reports. Risk removed is never a yearly saving.

EU ETS: a missed surrender

A flat €135.31 for every tonne of CO₂e not surrendered by 30 September. It is €100 indexed to European CPI; this is the value for reporting year 2025.Source: DEHSt, sanctioning, penalty €135.31 (opens in a new tab)
Flat, not graduated: one day late equals six months late. The Dutch NEa has no legal room to reduce or waive it, and Norway imposes it regardless of fault.Source: NEa, enforcement of the surrender obligation (opens in a new tab); Norwegian Environment Agency, surrender of allowances (opens in a new tab)
The allowances are still owed after the penalty is paid.Source: DEHSt, sanctioning, penalty €135.31 (opens in a new tab)
Companies that do not comply are named publicly. After two or more consecutive failures a port state can issue an expulsion order valid across the EU; no public maritime case is known as of October 2026.Source: European Commission, ETS maritime FAQ (opens in a new tab)
It is enforced: Norwegian Air paid about NOK 400 million for 372,818 missing allowances.Source: Miljødirektoratet, Norwegian Air penalty (opens in a new tab)

FuelEU Maritime: the deficit penalty

penalty = |compliance balance in gCO₂e| ÷ (actual GHG intensity × 41,000 MJ/t) × €2,400

About €640 for each tCO₂e of deficit on VLSFO (€2,400 per tonne of VLSFO-equivalent ÷ 3.7474 tCO₂e).Source: Clyde & Co, FuelEU penalties (opens in a new tab); DNV, FuelEU compliance timeline (opens in a new tab)
Repeat deficits cost more: ×(1 + (n−1)/10) for n consecutive deficit years, so ×1.1 in year two and ×1.2 in year three.Source: Clyde & Co, FuelEU penalties (opens in a new tab)
Borrowing is allowed up to 2% of the target, repaid ×1.1, and not in two consecutive years.Source: DNV, FuelEU compliance timeline (opens in a new tab); Watson Farley & Williams, FuelEU first deadline (opens in a new tab)
A pooled surplus traded at €87 to €225 per tCO₂e in 2026: 15 to 35% of the penalty.Source: Manifold Times, OceanScore pooling marketplace (opens in a new tab); IndexBox, FuelEU pooling values (opens in a new tab)
Worked example, on the engine's VLSFO figure of 91.4 gCO₂e/MJ against 89.34: 5,000 t of VLSFO in scope is 205 million MJ. A gap of 2.06 g/MJ is about 422.5 tCO₂e of deficit, a penalty of about €270,600; year two ×1.1 is about €297,600.Halyard prices FuelEU on the engine's 91.4 g/MJ for VLSFO, as the app does.

National fines for late or missing reports

Set by each administering state, mostly per company, and they do not scale with emissions. No published fine against a named shipping company found for 2024 or 2025.

State	Amount	Status	Source
Germany	Up to €500,000 (intentional) or €100,000 (negligent) for late or incorrect reports; up to €100,000 for a missing monitoring plan; registry account blocked	Official (DEHSt, TEHG § 49)	DEHSt, German fines (TEHG § 49) (opens in a new tab)
Netherlands	€5,000 fixed plus a variable part weighted by days late (0 to 5 days 0.05, 6 to 10 days 0.10, 11 to 30 days 0.15); daily penalty payments €250 to €3,500	Official (Beleidsregel NEa ETS)	Beleidsregel NEa ETS 2021 (opens in a new tab)NEa, enforcement of the surrender obligation (opens in a new tab)
Malta	By company emissions: €1,000 + €50 a day (under 10 kt); €5,000 + €100 a day (10 to 50 kt); €10,000 + €300 a day (50 to 500 kt); €50,000 + €600 a day (over 500 kt); no cap	Official (ETS Maritime Regulations 2024)	Malta ETS Maritime Regulations 2024 (opens in a new tab)
France	€15,000 per ship; €30,000 if deliberate	Official text; article number to confirm	Légifrance, Code de l'environnement sanctions (opens in a new tab)
Italy	€10,000 to €50,000 (reporting); €30,000 to €150,000 (monitoring)	Secondary source	Italian MRV sanctions (secondary source) (opens in a new tab)
Denmark	Set by courts, no fixed amount	Official	Energistyrelsen, Danish sanctions (opens in a new tab)
Norway	Transfers suspended if no report by 1 April; coercive fines; amounts not public	Official	Lovdata, Norwegian Greenhouse Gas Emission Trading Act (opens in a new tab)Miljødirektoratet, sanctions (opens in a new tab)
Greece, Cyprus, Belgium, Poland	Not confirmed	Unverified	No source yet

How often companies are late

What the authorities have published. Our own late count comes from each ship's verification date in the EU MRV data.

Measure	Figure	Source
Dutch-administered companies with a verified report by 31 March 2025 (first cycle)	60%, revised to 71%; 74% by mid-April	NEa, 22 Apr 2025 (opens in a new tab)
Same, second cycle (2025 emissions), 1,538 ships	84% by 1 Apr 2026	NEa, 30 Apr 2026 (opens in a new tab)
Allowances surrendered EU-wide by 30 Sep 2025, by volume	over 99%	European Commission, 2025 Carbon Market Report (opens in a new tab)
Shipping companies EU-wide not compliant on surrender, 2024 cycle	13% (494 companies)	NEa, 5 Nov 2025 (opens in a new tab)
Shipping non-compliance against other ETS sectors, 2024	about 3 times higher	Carbon Pulse (opens in a new tab)
Ships that paid a FuelEU penalty, first cycle	about 3.5%	Maersk Mc-Kinney Moller Center (opens in a new tab)

Under 1% missing by volume and 13% by company: late payers are mostly small emitters. The 30 September 2026 surrender figures are not published yet; the Commission's report is expected around early December 2026.

Each line of your saving

The price, then the formula and the dated constants behind every line, at 2026 rules and prices on your 2025 volumes. Rendered from the same file the calculation runs on.

2026 rules

100% surrendered: EU ETS phase-in: 100% of 2026 emissions
+2% methane and nitrous oxide: Methane and nitrous oxide in the ETS from 2026, about 2% on top of CO₂
€86.47: EUA close, 22 October 2026 (12-month range about €68 to €88)
€100: FuelEU surplus (pooling) price, about €100 per tCO₂e; 2026 range €87 to €225
0.0845 tCO₂e per t fuel: VLSFO at 91.4 gCO₂e/MJ against the 89.34 limit, 41,000 MJ per tonne

carbon bill = allowances × EUA price + FuelEU deficit × pooling price

What Halyard costs, and the terms

price a ship = €1,650 + plan rate × the ship's ETS-scope tCO₂e (Ledger €1.30, Forecast €3.15, Fleet €5.00)

Price a ship, a year: €1,650 + rate × tCO₂e. The ship's ETS-scope tCO₂e from the latest public EU MRV year, fixed for the contract year. No bands
Ledger rate: €1.30 a tCO₂e. On sale now
Forecast rate: €3.15 a tCO₂e. On sale now
Fleet rate: €5.00 a tCO₂e. From March 2027
Managed MRV service: €1,650. A ship under EU MRV only, with no ETS yet, on any plan
Company minimum and onboarding fee: none. Year one is the annual price: no onboarding fee and no company minimum
Renewal: same formula. On the ship's new MRV tonnes
Pilot: 25%. Of each ship's annual Ledger price, for 90 days on up to 3 ships; credited to year one
Volume discount: 10%, 15%, 20%. 10% off from 11 ships, 15% off from 26 ships, 20% off from 51 ships
Two-year term: 8% off. On the yearly price
UK ETS add-on: plan rate. UK-scope tCO₂e × the plan's rate
Deadline rescue, late ships only: one ship's Ledger price. One-off, credited to the first year if you subscribe by 30 June 2027
Pooling desk: €740 a ship. Per ship with a FuelEU deficit

Every on-time ship saves at least 3× its price on every plan at our default figures.

Team time

365 reports × minutes saved on each ÷ 60 × cost of an hour, per ship

365: noon reports a ship sends in a year, one a day
18 min and €46: the page's starting figures: 365 × 18 ÷ 60 × €46 = €5,037 a ship, about €5,000 a year; yours to edit above

Ledger value, estimated

ETS-scope tCO₂e × €4.00

€4.00: per tCO₂e a year: Halyard estimate: choosing the cheapest pooling, carbon recharge at every redelivery, verifier preparation

Inside the figure: verifier preparation about €1,000 a ship; carbon recharge missed or late without a carbon invoice, about 2% of the ETS bill; the cheapest pooling. A pilot measures your own.

Buying allowances early, estimated (Forecast and Fleet)

ETS-scope tCO₂e × €5.50

€5.50: per tCO₂e a year: buying allowances early on the forecast, estimated; range €3 to €8, theoretical maximum €20
€3 to €8: the range per tonne; the figure counted is the estimate, never the top of the range
€86.47: EUA close, 22 October 2026 (12-month range about €68 to €88)

A forecast can be wrong, and then buying on it can lose money.

Fuel efficiency, unmeasured (Fleet)

ETS-scope tCO₂e × €5.50

€5.50: per tCO₂e a year: fuel efficiency, about 2% of fuel, from about €190 per tCO₂ of VLSFO plus allowances avoided; unmeasured, Halyard estimate

Unmeasured: a Halyard estimate until the plan has run on your ships.

Pooling instead of penalty, late ships only

FuelEU deficit × (penalty − pooling price), at 100%

100%: pooling instead of the penalty, on the ship's whole FuelEU deficit, from its own fuel mix
€640.44: per tCO₂e: €2,400 per tonne of VLSFO-equivalent ÷ 3.7474 tCO₂e
€100: per tCO₂e: FuelEU surplus (pooling) price, about €100 per tCO₂e; 2026 range €87 to €225
0.0845: tCO₂e of deficit per tonne of fuel: VLSFO at 91.4 gCO₂e/MJ against the 89.34 limit, 41,000 MJ per tonne

A ship with no deficit (LNG or biofuel) has nothing to pool, so no saving here.

National fines avoided, late fleets only

€15,000 once per company with a ship verified late

€15,000: national fines avoided, once per company with at least one late ship

Counted once however many ships are late. What is left of the €50,000 stays under risk removed.

Risk removed, never a yearly saving

allowances × €135.31, and up to €50,000 in national fines once per company, less any fines counted as saved

€135.31: EU ETS excess emissions penalty, €100 indexed to European CPI: €135.31 per allowance for reporting year 2025 (DEHSt); flat, one day late equals six months; allowances still owed
€50,000: top of the Malta and Italy ranges; set by each administering state, mostly per company

Neither enters the saving, the return or the payback. No fine against a named shipping company has been published for 2024 or 2025.

Buying allowances early, and why it is an estimate

Allowances are financial instruments under MiFID II, so Halyard is built to stay outside investment advice. There is one forecast, the same for every subscriber, sold as software at a flat fee. No fee is linked to trades or to money saved, and we never buy or sell for you. Your own need and holdings are shown, and you decide what and when to buy. Sources: Reed Smith, EU ETS shipping and MiFID 2 (opens in a new tab); Finanstilsynet, investment firm licensing (opens in a new tab).

By size and by kind of company

Halyard estimates, for a vessel of the size shown. They show how the saving and the risk move with size and with habits.

Halyard estimates, per 10,000 tCO₂e vessel and year, of 23 October 2026. Penalty rates are official; the ranges are ours. They use a FuelEU example of 1.82 g/MJ; this page prices FuelEU on the engine's 91.4 g/MJ for VLSFO, so the two differ a little on that line.

By vessel size, per vessel and year: Halyard estimates
In-scope tCO₂e	Worst case	Realistic, regularly late company
5,000	about €0.80M	€93k to €128k
10,000	about €1.55M	€165k to €200k
25,000	about €3.80M	€384k to €419k
50,000	about €7.55M	€747k to €782k
100,000	about €15.0M	€1.48M to €1.51M

Realistic means pooling instead of the FuelEU penalty, plus fines, recharge and staff. The forecast's value is not in it. Year two is worse: FuelEU ×1.1 and the risk of expulsion after repeated non-surrender.

By kind of company, per 10,000 t vessel and year: Halyard estimates
Kind	Hard savings	On top	Where we lead
A: always late, pays FuelEU penalties	€165k to €200k	€1.35M surrender risk removed	Penalties avoided, deadlines never missed
B: sometimes late	€30k to €75k	The same risk, lower probability	Fines avoided, cheaper pooling
C: never late, manual or consultant	€18k to €55k	Fewer verifier queries	Cheaper pooling, recharge, staff time
D: already on a competitor	€5k to €20k	Switching cost	Daily position, audit trail, recharge invoices

Sources

Every figure above links to the page it came from. Each opens in a new tab.

Public EU MRV data (THETIS-MRV, "Publication of information"): 2025 reports, version 60 of 5 October 2026; 2024 reports, version 248. ETS-scope CO₂ is voyages between EU ports, half of voyages into or out of the EU, and time at berth in EU ports. A company's fleet is every report under the same Document of Compliance holder.

See it on your own reports.

A 30-minute walkthrough, then a pilot. Bring one ship's noon reports; we put a real one through the engine on the call, with these figures beside it.

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