Innovative compliance pooling for fuels facing offtake challenges

Introduction

The number of vessels capable of operating on alternative fuels is rapidly increasing and, for the first time, beginning to outnumber conventional vessels in global orderbooks. Today, there are already significant numbers of liquified natural gas (LNG)-capable vessels in operation and on order, alongside more than 100 methanol-capable vessels in service with more than 300 on order, and a growing pipeline of nearly 50 ammonia-capable vessels.

However, a fundamental challenge remains. The fuels required to fully decarbonise these vessels, such as methanol, ammonia, and bio- and e-LNG, are not yet available at scale. While technological barriers to deploying these ships have largely been addressed, most planned fuel production facilities have not yet reached a final investment decision (FID). A key barrier is the lack of long-term offtake agreements, which are typically required to secure financing for such fuel projects. For shipowners, such agreements entail not only a cost commitment but also significant risk. In many cases, long-term offtake contracts exceed $1 billion over a period of 10 years or more, representing a level of financial and operational risk that only a limited number of shipowners are currently willing or able to assume.

Addressing the challenge of unlocking fuel FID requires commercial innovation, particularly from first movers. One promising approach is demand aggregation. Demand aggregation refers to platforms, mechanisms, and business arrangements that enable consolidated purchasing across multiple actors and/or sectors, particularly in markets where demand is fragmented or emerging. By pooling demand, such approaches can create larger, more predictable offtake volumes over longer durations, thereby improving bankability for fuel producers.

Demand aggregation offers several advantages. It can introduce flexibility in procurement, reduce costs per offtaker through economies of scale, and enhance overall financial feasibility for both buyers and suppliers. There are different models of demand aggregation, including supply-led approaches (such as engaging multiple offtakers or “time-stacking” demand), demand-led approaches (such as joint procurement), and third-party-led mechanisms (such as double auctions or hydrogen hubs). Aggregation frameworks can also take various organisational forms, ranging from informal networks and sourcing facilitators to purchasing service providers and fully integrated group buyers.

Several real-world examples of demand aggregation, particularly third-party-led initiatives, have already emerged, including H2Global and the Zero Emission Maritime Buyers Alliance. These models demonstrate the potential to mobilise demand and support early market formation. However, participation in such initiatives remains relatively limited, often concentrated among larger companies with the capacity to engage in competitive tenders and absorb associated risks. These initiatives also tend to work better in more predictable markets, such as the container segment.

Against this backdrop, and informed by stakeholder consultations with fuel producers, shipowners, and green corridor consortia, this brief examines how regulatory frameworks and compliance mechanisms could help aggregate demand, reduce risk, and accelerate investment in zero-emission fuel supply.

FuelEU Maritime is driving compliance thinking

While voluntary action remains key, regulatory compliance has become an immediate and growing reality for the maritime sector. A combination of regional and international measures is reshaping investment and operational decisions:

• The EU’s FuelEU Maritime regulation introduces progressively stricter greenhouse gas (GHG) intensity targets for energy used by vessels.

• The EU Emissions Trading System (EU ETS) is tightening over time, increasing the cost of emissions through a declining cap on allowances.

• At the international level, the International Maritime Organization (IMO) is developing a global framework, potentially combining carbon intensity targets with a credit-trading mechanism.

Figure 1: Balancing compliance with over- and under complying vessels

Together, these measures are shifting the industry from voluntary decarbonisation efforts toward a compliance-driven transition.

Zooming in on FuelEU Maritime, this regulation sets five-year emissions-reduction targets for the sector, dividing it into under-complying, complying, and over-complying vessels. A key feature of this measure is the ability to share compliance obligations across vessels through compliance pooling. This flexibility mechanism allows shipowners to balance over- and under-compliance within a fleet, effectively spreading risk. As such, it represents an important area for commercial innovation, enabling more efficient and strategic approaches to meeting regulatory targets. 2026 was the first compliance year for vessels trading with or within the EU.

As shown in Table 1, shipowners face several compliance pathways, each with distinct trade-offs.

Compliance pathway	Upside	Downside
Non-compliance fee of €2400 per tonne of very low sulphur fuel oil equivalent (VLSFOe)	Predictable cost and “easy” way out, no need to trade	High costs compared to other pathways
Buying surplus credits from overcompliance	Relative low cost, no need to invest in new assets or source fuels	Exposure to future increases of surplus unit prices as targets become more stringent and demand for credits increases

	Operating on low-carbon fuels
Conventional vessel with biofuel blend	- No CAPEX investments needed - Less exposed to high-cost fees of non-compliance or volatile credit prices - Ability to over-comply with a large portion of biofuels if available	- Limited availability of biofuels on all routes, uncertain prices and scalability in the long-term - Price of buying credits is generally cheaper than the cost of biofuels
LNG vessel with fossil LNG	- Able to generate surplus credits until 2034 - Currently lowest cost-compliant fuel	- Requires investments in LNG dual-fuel vessels - Limited compliance window
LNG vessel with bio-LNG	- Drop-in fuel capacity to meet compliance levels at low volumes, including via mass balance when bunkered in the EU - Able to generate significant volumes of surplus credits at larger consumption - Currently available and technically mature	- Exposure to price increases as competition from other sectors and increasing demand drives up prices - The more scalable e-methane pathway is currently less available and expected to be less price competitive compared to other e-fuels
Methanol or ammonia vessel	- Bio-methanol and cheaper blue ammonia able to meet compliance levels or generate surplus units in the medium term - Scalable e-fuel pathways able to meet compliance levels or generate surplus in the long run	- Fuels require long-term offtake, which comes with significant cost and risk - More scalable e-fuel versions of molecules face limited availability - High CAPEX investments needed throughout the value chain

Table 1: The up- and downsides of various compliance pathways under FuelEU Maritime

Fuel producer-led pools

Within the broader credit market, compliance pooling led by fuel producers and traders has gained traction, particularly in the biofuels and bio-LNG segments. Producers and traders such as FincoEnergies, STX, and Gasum have begun offering pooling services, positioning themselves as intermediaries between over-compliant and under-compliant actors. In terms of structure, fuel producer–led pools share several common characteristics, including time commitment, pricing mechanisms, and commercial structure.

Time commitment

All pools indicated currently operate on single-year commitments. This provides flexibility for both sellers and buyers: shipowners can decide annually how many credits to contribute, while compliance buyers can adjust their strategy depending on market conditions. This structure also allows prices to more closely reflect real-time market dynamics.

Pricing mechanisms

Credits are generally traded at market-based prices, even where the underlying cost of abatement (e.g., for biofuels) exceeds the value of the credit. In the initial stages, halfway through the first compliance year, credits were traded at around €250 per tonne of carbon dioxide equivalent (CO₂e). As the first compliance year progressed and reporting periods began, prices stabilised at lower levels, generally around or below €200, with some reported as low as €170 in the beginning of 2026. This early price evolution reflects both increasing market participation and emerging supply-demand dynamics. The prices were especially pushed down by the large availability of LNG-generated credits, which have a lower abatement cost than, for example, biofuels.¹

The approach to the price of surplus units in relation to fuel price differs across pools. An emerging question within this model is who receives the surplus revenue:

Option A: The shipowner pays full price for the fuel and keeps the surplus revenue. The risk of credit price volatility is therefore on the offtaker.

Figure 2A: Option A, the shipowner carries the risk of credit price volatility

Option B: The shipowner pays a reduced price for the fuel, with a form of “buyback clause” in the fuel supply agreement. Under such arrangements, fuel producers offer discounted prices on low-carbon fuels to shipowners in exchange for access to the compliance credits generated. The producer effectively assumes the risk of future credit price volatility, monetising the credits later in the market. In some cases, these agreements may include conditional clauses that link discounts to price thresholds or market conditions, allowing producers to manage downside risk and capture upside through arbitrage opportunities.

Figure 2B: Option B, the fuel producer carries the risk of credit price volatility

Commercial structure

Fuel producers typically act as intermediaries, facilitating pools rather than directly aggregating or owning the credits through a central counterparty or joint venture. Shipowners using their fuels generate compliance surplus and may choose to allocate a portion of these credits to the pool. Importantly, there is generally no contractual obligation for shipowners to share credits; they retain the flexibility to bank them or sell them independently. This may pose a significant risk to fuel producers, as they will need to provide the required surplus to compliance buyers at the end of the year.

Role of compliance pooling for fuels facing offtake challenges

While current fuel pools have mostly been limited to bio-based fuels, such as bio drop-in and producer–led pools, several strategic advantages for producers have been identified that are also applicable to pools for scalable zero-emission fuels (SZEFs), such as e-fuels.

First, pools provide a value-added service for shipowners by simplifying access to compliance markets. Even shipowners initially participating as compliance buyers may transition into fuel customers over time, particularly as compliance costs increase, making pooling a potential commercial and marketing channel for fuel producers. Second, these models help fuel producers secure demand directly by building relationships with shipowners and enabling more predictable revenue streams through credit sales without requiring each customer to manage trading activities independently. Thirdly, it spreads risk across multiple actors. If one actor defaults on the purchase of credits, the remaining parties will still be able to pay for their commitments, and the total default is manageable from a risk perspective.

However, key challenges remain for applying this mechanism to e-fuels, as the current structures do not fully address the core challenges associated with scaling long-term zero-emission fuels such as methanol and ammonia. These fuels face a fundamentally different set of barriers, including the need for long-term offtake agreements, price certainty, and credible counterparties to underwrite large-scale investments:

• The credit prices are currently influenced by lower-cost abatement options, most notably through fossil LNG, which can drive prices down. This was considered a significant downside for ammonia and methanol, which have a significantly higher abatement cost.

• The yearly pool building is not sufficiently reliable for long-term offtake agreements. The high volatility already visible in the first year of the framework makes planning future cash flow highly uncertain.

• If the surplus-generating shipowner receives the revenue from the sale of the surplus credits, it will take on price volatility risk, which compounds the risks that the shipowner is already taking in the case of a long-term offtake agreement.

Compliance pooling as an innovative commercial structure for demand aggregation

“Traditional” compliance pooling mechanisms can be adjusted to be more attractive for e-fuels and supporting long-term offtakes. This would require a shift in several key characteristics of current pooling models.

Figure 3: Elements for adapting traditional fuel producer-led pooling to support SZEF offtake

Time commitment

Moving from annual to multi-year commitments could help cover the time horizon required for long-term offtake agreements, providing greater certainty of future revenue streams. This would support investment decisions by fuel producers while enabling a more proactive approach to compliance, in which participants plan future surplus and deficit positions rather than reacting year-by-year. For shipowners, this could offer a hedging opportunity against rising credit prices as regulatory targets become more stringent. However, appetite for multi-year commitments seems limited. The market is still nascent, and many shipowners lack confidence in forecasting future credit prices. In addition, near-term targets remain relatively stable over the next few years under FuelEU Maritime, reducing the immediate incentive to hedge. As a result, demand for long-term credit purchasing may remain muted in the short term, potentially strengthening closer to 2030–2034 as targets tighten and surplus availability declines.

Pricing structures

Market-based pricing enables competitive outcomes and reflects broader value chain dynamics, potentially increasing revenues for early movers if some participants demonstrate a higher willingness to pay. However, fixed or semi-fixed pricing structures could play an important role in enabling long-term aggregation. Fixed pricing offers certainty and transparency, allowing shipowners to clearly understand their commitments while providing predictable revenue streams for fuel producers or “anchor” vessels.² This, in turn, can support the risk profile of long-term offtake agreements. At the same time, fully fixed pricing may not be necessary in a volatile and evolving market. Hybrid approaches could emerge, such as:

• Fixed offtake volumes combined with market-based pricing with defined caps and floors

• Baseline pricing with adjustment mechanisms linked to market developments

While credit prices have been pushed down by LNG abatement costs, even at current levels, there are opportunities for pooling to support the use of zero-emission fuels. The figure below highlights a scenario with the lowest-cost compliance pathway for a conventional vessel, as well as three surplus scenarios highlighting the range that the credits have been trading at.

_{1] Scenario in which the lowest cost option is complying through low sulphur fuel oil (LSFO) with an 8% biofuel blend-in
2] Scenario in which methanol is used at 100% and surplus units are sold at $170/tonne CO2e
3] Scenario in which methanol is used at 100% and surplus units are sold at $200/tonne CO2e
4] Scenario in which methanol is used at 100% and surplus units are sold at $250/tonne CO2e}

Figure 4: The cost gap for e-methanol at different surplus credit prices

Without the sale of surplus units, the cost gap between e-methanol as an example SZEF, trading at $2000 LSFO equivalent, and the lowest-cost compliance option with conventional vessels, trading at $1067 including the bio-blend and compliance costs, is $933. This means that even at the lowest end of the credit price range, the cost gap would be covered up to 60+%, up to 88% in the highest scenario. Other, lower-cost alternative fuels, such as bio-methanol or e-ammonia, can see their cost gaps closed in the scenarios with the higher credit prices.

Even at the lower-end price levels, these models can be designed to support offtakes rather than short-term supply. In various Getting to Zero Coalition workshops, many first-mover shipowners indicated a need for clarity about the cost gap rather than the need to fully close it. To this end, a pricing structure in which the cost gap is relatively stable (depending mostly on exogenous factors such as LSFO and biofuel prices) is likely to help shipowners plan their investments and transition.

From the fuel producers’ perspective, the relevance of surplus unit revenues lies not only in the share of the cost gap they can cover, but also in whether they provide sufficient certainty to underpin project bankability. For e-methanol producers, for example, the total cost stack includes renewable power procurement, biogenic or captured carbon feedstocks, conversion costs, financing, and an adequate return on investment. In this context, surplus unit revenues in the range of $170–250/tCO₂e could represent a material contribution toward the premium required above conventional fuel prices, particularly when combined with long-term offtake agreements and demand aggregation. While these revenues alone may not fully close the remaining gap to the production cost levels required for final investment decisions, they can significantly reduce revenue uncertainty and improve the risk profile of projects. This highlights the importance of designing pooling and pricing structures not only around short-term compliance value, but around sufficiently predictable and durable revenue streams to support investment in scalable zero-emission fuel production.

Commercial structure

Enabling multi-year, compliance-based aggregation may require more robust commercial arrangements than current broker-led pools. One option is the creation of a dedicated joint venture or special purpose vehicle, designed to aggregate demand, manage credit flows, and underpin long-term offtake agreements. While this introduces challenges, such as a potentially lower credit rating for a new commercial structure, it would be better positioned to pool balance sheets and share credit risk, particularly credit price risk, across multiple participants. This could strengthen the financial credibility of aggregated demand and provide the counterparty with the assurance that fuel producers and investors need.

Alternative models potentially involving financial intermediaries or credit risk–bearing entities could fulfil a similar function. Over time, such entities could evolve into a form of market maker or financial institution for compliance credits, bridging the gap between fragmented demand and long-term fuel investment needs.

Offtake characteristics	Description of offtake characteristic	Current models of fuel producer-led pools	Innovative compliance pooling
Long term duration	Offtake commitments need to be long enough (10-15 years) to amortise the upfront investment in the fuel plant	Annual contracts do not de-risk the long-term commitment due to fluctuations in the credit price	Long-term credit buyers allow for reducing the risk of long-term offtake
Fixed price	While benchmark-based pricing is considered, fixed price contracts are preferred to provide a steady, predictable revenue stream	Depends on the model. Most pools do not have a fixed price mechanism and apply market-based pricing. Uncertainty around credit prices introduces more uncertainty around the final cost gap	Fixed credit price reducing the risk of price volatility as the credit market develops – credit pricing allows more flexible sharing of risk not only between off-takers but also between shipowners and fuel producers
Large volumes	A significant majority (e.g., 65%+) of the plant’s planned capacity must be covered by upfront commitments	Depends on fuel demand and the number of anchor vessel(s)	Depends on fuel demand and the number of anchor vessel(s)
Mix of reputable counterparties	Offtakers need to be creditworthy in the eyes of project investors to provide reassurance they will fulfil their obligations and deliver a return	The compliance buyers together provide the financial backing for the offtake agreement	The compliance buyers together provide the financial backing for the offtake agreement

Table 2: Applying the criteria for long-term offtake to compliance pool designs

Example of a compliance pool for bio-methanol

The proposed model to exemplify how this could work in practice is a way to bridge the gap between FuelEU surplus credit generation and long-term methanol offtake. It operates through a dedicated commercial vehicle; either a joint venture with anchor shipowners or a special-purpose vehicle (SPV) managed by the fuel producer. Surplus compliance units generated by methanol-capable vessels burning their methanol are sold to compliance buyers on multi-year, semi-fixed pricing terms.

Key structural features:

1. Multi-year commitment from credit generators aligned to their facility’s offtake tenor (seven to ten years)

2. Semi-fixed credit pricing with floor-and-cap mechanism, reducing price volatility risk for both fuel buyer and credit purchaser

3. The SPV consolidates counterparty risk, providing project lenders with a single, rated compliance revenue stream rather than a fragmented pool of annual commitments

4. The SPV would maintain a revolving credit facility to bridge the timing mismatch between shipowners’ upfront premium fuel costs and the realisation of surplus credit revenues at year-end settlement, reducing the working capital burden on anchor offtakers and improving the practical viability of long-term commitments.

This structure directly addresses the four barriers identified above: duration, price certainty, counterparty quality, and cash call requirements for shipowners’ balance sheet. It does not eliminate the cost gap, but provides a stable, auditable contribution toward closing it that is sufficient, in the experience of first-mover shipowners, to support investment decisions even where full parity is not achieved.

Archetypes for credit generators and buyers

Not all types of shipowners are likely to be equally suited to be either credit generators or buyers in an e-fuel-focused compliance pool.

Segment	Likely compliance role
Tankers	Ammonia or methanol carriers are more likely to be compliance generators because they can burn their own cargo. The same applies to LNG carriers for e-LNG. Traditional tankers are more likely to be compliance buyers, if they cannot source enough biofuels to comply. Their role is complicated by their more unpredictable trading. This means a tanker won’t know its deficit at the beginning of the year and would need to under-commit to buying compliance.
Bulk carriers	More likely to be a compliance buyer in the short run. Their ability to run on ammonia/methanol is challenged by limited value chain readiness. In this sector, a fuel such as ammonia is attractive but faces challenges of unpredictable tramp shipping.
Feeder vessels	More likely to be a compliance generator due to existing high levels of zero-emission vessel orders, predictable routes, and zero-emission fuel uptake.
Ocean-going container	Likely to be neither: Container liners are already significant generators of surplus credits but are less likely (with the exception of container feeders) to be participating in compliance pooling, because they either sell their credits as higher-value insets to cargo owners or manage their own deals. Any deficit generated in container liners is more likely to be offset by internal pooling rather than external compliance pooling.
Ferries	More likely to be compliance generators as they run on predictable routes and consume predictable volumes of fuel.
Cruise	More likely to be a compliance buyer as they will be able to more closely predict their compliance needs.

Table 3: Likely role of the various segments in a compliance pool

Looking at Table 3 above, various segments stand out as potential compliance anchors. Three main segments stand out as particularly promising credit generators: ammonia and methanol tankers (if also fitted with their respective engines), feeder container vessels, and ferries. Tankers are well-positioned because they can burn their own cargo as fuel. Given that they move their cargo based on demand, these vessels have a greater security of fuel availability than traditional tramp tankers. Feeder container vessels and ferries are also well-positioned anchors because of their stable trading patterns. Running on predictable routes makes it easier to plan for fuel sourcing, bunkering, fuel volumes, expected costs, and freight rates. However, one risk here is that these vessels have relatively lower fuel consumption and may therefore not generate the required volumes for a long-term offtake. While cruise ships also generally run on predictable routes and likely have higher volumes of fuel consumption, their demand for SZEFs remains relatively low due to remaining safety concerns of alternative fuels in relation to passengers.

The tramping segments are the most likely to have a stake in being compliance buyers. Due to their unpredictable trading, sourcing drop-in biofuels or committing to long-term SZEF offtake is challenging. At the same time, it is in these vessel owners’ interests to ensure an early general build-out of SZEF infrastructure, so that their unpredictable trades will have bunker availability later. In other words, committing to a long-term credit purchase allows them to support the value chain of a fuel pathway that they would like to transition to in the long term, but are unable to commit to in the short term. However, there is a risk that their unpredictable trading patterns will create uncertainty about their compliance needs each year, leading to undercommitment on credit purchases from each buyer and a need for each pool to source more compliance buyers to bridge the gap.

Another option on the buying side would be for the bunker provider and port to set up a joint venture, buy enough credits to provide compliance for all or part of their bulk traffic bunkering at their port, and then build this compliance fee into their bunker service. Companies that are unable to predict their compliance needs in advance can address them at the point of fuel purchase via this service.

The role of green corridors

Green corridors could provide a particularly relevant testing ground for innovative compliance pooling for SZEFs. Green corridors are specific trade routes where the feasibility of zero-emission shipping is catalysed by public and private action. By design, these initiatives bring together concentrated groups of actors around specific trade routes, often involving early-adopting large companies, ports, fuel suppliers, and cargo owners, all aligned around a similar ambition and a commitment to voluntary action, thereby increasing their willingness to commit to long-term commercial structures.

One of the central difficulties with green corridors is converting commitments to workable commercial structures. Compliance pooling could address this by moving the involved parties towards fuel investment decisions. This could happen in one of two ways:

1. The compliance buyers and anchors are part of the same green corridor

Such a structure would build on the commitment of shipowners/charterers in a green corridor to their shared ambition and voluntary action, thereby increasing their willingness to commit to long-term credit purchases.

However, a downside is that shipowners in these consortia are generally competitors on the same route, which may make them less willing to share compliance credits.

2. The anchors are the participants in the green corridor and their buyers come from outside

This structure would allow shipowners to commit to high volumes of SZEF and avoid having to share compliance with competitors. However, a likely barrier in this system would be the inability to find compliance buyers willing to commit to a long-term purchase, given the liquidity that the credit market showed during 2025/2026. This willingness may increase closer to 2030, when the FuelEU Maritime targets become more stringent, and shipowners may expect a rise in credit prices as credit supply tightens.

A limited number of green corridor initiatives have progressed to implementation. Of the four initiatives that have successfully done so, two have used pooling to support their business cases: Vaasa-Umeå and Stockholm-Turku.

Since August 2025, Wasaline has operated its existing hybrid Aurora Botnia ferry on the route between Vaasa, Finland, and Umeå, Sweden, on biomethane. An initial one-year supply of biomethane was secured for the vessel from the Nordic energy company Gasum. The fuel is waste-based and certified to reduce emissions by an average of 90% compared to fossil fuel on a mass balance basis.

Meanwhile, Viking Line has increased the use of biogas on its two existing ferries—the Viking Glory and Viking Grace—on the route between Turku, Finland, and Stockholm, Sweden, from around ten tonnes in 2023 to a projected 3,800 tonnes this year. The vessels are now running on 50% waste-based biogas. This is also supplied by Gasum and is similarly certified to reduce emissions by 90% based on a mass balance basis.

Both Wasaline and Viking Line have entered pooling agreements and sell the credits generated by running on biomethane to close the cost gap facing the fuels. Wasaline sells its credits to Stena Line, while Viking Line sells its credits through a pool run by Gasum. The companies point to two enablers to explain their success in leveraging the pooling mechanism: the ability to draw on long-standing relationships and the relatively low cost gap for using biomethane compared to, for example, bio-methanol or e-fuels, which helped ensure there was demand for the credits.

Conclusions

• The maritime transition is becoming compliance-driven rather than voluntary
  FuelEU Maritime, the EU ETS, and the upcoming IMO framework are turning emissions reductions into a direct commercial and operational requirement. As targets tighten, shipowners will increasingly need predictable and scalable compliance strategies rather than relying on short-term voluntary action.

• Scalable zero-emission fuels still face a financing challenge, while the technology challenge is slowly resolving
  Methanol- and ammonia-capable vessels are entering the market rapidly, but fuel production projects still struggle to reach a final investment decision. The main barrier remains the lack of long-term, bankable offtake agreements that can provide fuel producers with revenue certainty.

• Current compliance pooling models work well for biofuels and LNG, but are not yet designed for e-fuels
  Existing fuel producer-led pools successfully reduce compliance costs and simplify access to the FuelEU credit market. However, annual commitments, volatile credit prices, and exposure to lower-cost abatement options such as fossil LNG make these models insufficient to underpin long-term SZEF investments.

• Innovative compliance pooling could become a form of demand aggregation for e-fuels
  Innovative compliance pooling could become a form of demand aggregation for e-fuels Moving toward multi-year commitments, more stable pricing structures, and stronger commercial entities (such as joint ventures or special-purpose vehicles) could help convert fragmented compliance demand into bankable, long-term fuel demand. Such models, exemplified by the case study for bio-methanol, would not fully eliminate the cost gap for e-fuels, but could significantly reduce risk exposure and improve investment certainty for both shipowners and fuel producers.

• Green corridors are well-positioned to pilot these models
  Green corridors could be a strong testing ground for compliance-based demand aggregation models that could later be scaled across wider maritime markets and segments, but risk either running into competition issues or limited willingness from outside compliance buyers to commit to long-term credit purchase.

• Innovative compliance pooling is not a silver bullet but can play a critical enabling role
  Compliance-based demand aggregation will not remove all barriers facing SZEFs. It does not by itself eliminate the underlying cost gap, remove fuel supply constraints, or fully de-risk long-term investments. However, it can reduce uncertainty, distribute risk across multiple actors, create more predictable revenue streams for fuel producers, and provide shipowners with greater visibility over future compliance costs. Even if these mechanisms only partially close the gap, they could help unlock early projects, support market formation, and accelerate learning-by-doing at a stage where waiting for perfect market conditions risks delaying the transition.