regulation Compliance & regulationDecarbonization & energy BIMCO
BIMCO has adopted the FuelEU Maritime Clause for Memoranda of Agreement (MoAs) 2025, finalised in December 2025, marking an important addition to the organisation’s suite of decarbonisation-related contractual tools. Developed by a BIMCO subcommittee comprising shipowners, brokers, legal specialists and P&I expertise—and supported by broad stakeholder consultation—the clause provides a clear and practical framework for allocating responsibilities between buyers and sellers of vessels falling under the scope of the FuelEU Maritime Regulation. Purpose and Scope Seller’s Warranties Data Sharing and Verification Buyer’s Post-Delivery Delivery Support Financial Adjustments Reflecting Compliance Risk Transfer of Responsibility Use with Time Charter Parties Conclusion As shipping transitions toward lower emission operations, contractual certainty in sale and purchase transactions has become increasingly important. The clause ensures that MoAs reflect the compliance landscape vessels now face when trading within the European Economic Area (EEA), equipping parties with the means to manage regulatory, financial and data sharing sharing responsibilities when ownership changes during an active FuelEU Maritime reporting period. Purpose and Scope The purpose of the clause is to ensure that rights, obligations and liabilities arising under FuelEU Maritime are fairly allocated between sellers and buyers. Central to this is transparency regarding the vessel’s greenhouse gas (GHG) intensity performance and any compliance balance accrued during prior reporting periods. Because FuelEU Maritime obligations are tied to the GHG intensity of the energy used on board—measured in grams of CO₂ equivalent per megajoule—ownership transfer during a reporting period requires careful alignment between the seller’s completed reporting obligations and the buyer’s future compliance exposure. The clause provides this alignment by requiring clear disclosure of the vessel’s compliance position and ensur
An overview of BIMCO’s FuelEU Maritime Clause for Memoranda of Agreement 2025
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