EU ETS and FuelEU Maritime have turned compliance into a continuous commercial process. Exposure tracking, forecasting, statements, invoicing, and settlement now need to function reliably throughout the year. When these processes depend on a single individual, compliance risk increases materially.
This article outlines a real case from a European ship manager that illustrates how dependency risk emerges in practice, and how it can be stabilised through structured workflows.
When Compliance Becomes a Single Point of Failure
In 2024, a mid-sized ship manager in Europe faced a situation that is increasingly common across the industry. The company operated with a compliance team of two people. When the compliance manager left the organisation, responsibility for EU ETS and FuelEU compliance effectively disappeared overnight. What followed was predictable.
Operational Consequences
Without a clear structure or system to absorb the transition:
Exposure tracking and forecasting stopped
Excel files could no longer be updated for FuelEU Maritime and the 2025 EU ETS changes
Statements and requests to charterers and owners were no longer issued
No one in the organisation felt able to take over the work
A replacement was hired, but left again after seven months. During this period, management lacked a clear view of ETS and FuelEU exposure, open positions, and pending obligations. Operational uncertainty translated directly into financial risk.
Loss of Visibility Increases Commercial Risk
For several months, the company did not have reliable answers to basic management questions:
What is the current ETS and FuelEU exposure?
Which voyages have been invoiced, and which have not?
What positions are still open or unresolved?
Without structured workflows, the compliance process stalled. The risk was not regulatory in theory; it was commercial and immediate.
Restoring Control Through Structured Workflows
OceanScore supported the company in stabilising its compliance processes.
Using Compliance Manager:
All EU ETS and FuelEU statements were generated automatically for the full year-to-date
Exposure and surrender requirements were reconciled against EUAs already collected
Ongoing workflows were stabilised while the internal organisation was rebuilt
OceanScore’s customer service team, drawing on experience from more than 100 client implementations, supported the transition and ensured continuity.
Financial Impact
The restored structure safeguarded approximately €450,000 per year that would otherwise have remained exposed through missed invoicing, unresolved positions, or delayed settlements. This outcome was not driven by speed or manual effort, but by reinstating clarity and process control.
The Broader Takeaway for Shipping Companies
This case reflects a broader pattern across shipping. EU ETS and FuelEU compliance cannot rely on individual knowledge holders. When compliance depends on one person, the organisation carries unnecessary commercial risk.
Structured, transparent systems reduce dependency risk by ensuring that exposure tracking, statements, and settlement workflows continue regardless of personnel changes.
Conclusion
EU ETS and FuelEU compliance will not reward speed. It will reward clarity, accuracy, and timing. For shipowners, managers, and charterers, reducing dependency risk is not a technical exercise; it is a commercial necessity.
If this situation reflects your organisation, structured compliance workflows can restore control and reduce exposure. For further discussion, contact: info@oceanscore.com
