Scenario 1: Maritime compliance costs are no longer confined to regional regulation. Based on current policy timelines and market assumptions, the industry’s annual compliance bill could rise from around USD 2.7 billion in 2024 to more than USD 57 billion by 2032, with the IMO framework becoming the largest driver of future cost exposure.
The maritime industry has spent the past few years in a transition that does not seem to end. It is in a race to become an industry where decarbonisation is measured, priced, and felt on a global scale.
We no longer operate in an era where a shipowner worries about one regulation, or one bunker price. Every stakeholder now sits on the bench of a regulatory show, wondering what comes next. To understand what these regulations mean commercially for a vessel, you have to understand what each one adds to the stack.
The maritime compliance market is uncertain. It is not unpredictable.
Over time, more regions will recognise the revenue sitting inside this transition and move to capitalise on their geographical leverage. What follows is a market built around a few heavy hitters, complemented by a handful of regional schemes that chose to move first.
Based on current visibility, this is our estimate.
On our assumptions, the annual cost of maritime compliance grows from around 2.7 billion USD in 2024 to roughly 57 billion USD in 2032. Two moments define the shape of that curve.
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The first is EU ETS, which carries the market on its own through the early years as the maritime phase-in completes. The second, and larger, is IMO GFI. It is planned to enter in 2028 but can have an altered version on a slightly adjusted timeline, however it would quickly become the single biggest line in the stack, close to two thirds of the total by 2032. EU ETS settles into second place at around 16 billion USD, with FuelEU, UK ETS, and the regional schemes filling out the rest.
The point is simple. The center of gravity moves from a regional carbon price to a global one inside a single decade.
A. EU ETS
Emissions eligible for EUAs are derived from the public MRV database, then adjusted for the scope of the regulation, the greenhouse gases covered and the phase-in. To stay conservative, we hold the industry emitted volume constant across the period and apply EUA price projections from several sources, growing at around 8% a year on average. Currency forecasts are applied throughout, so the USD figures reflect projected EUR forward swap rates rather than a fixed conversion.
B. UK ETS
With the announced inclusion of the domestic maritime sector in the UK ETS, the stack builds further. Base emissions are derived from impact studies produced by several policy groups, then prorated for the timeline and the future inclusion of international emissions, as the administration has signalled it intends. UKA price projections come from a range of sources, with the same FX treatment applied.
C. FuelEU
Public data is limited here, so we use the IMO study for fuel consumption and prorate it to EU consumption, joined to the MRV data. To date the big majority of vessels chose pooling over penalty, so we are not aware of a single case where vessels chose to pay the default penalty instead of an alternative such as pooling, so we model the pooling route rather than the penalty.
We hold the pooling cost constant across the period. Even so, the industry's compliance deficit grows as certain fuels lose the advantage they once held in generating surplus. The step change in 2030 reflects the tightening of the GHG intensity target, which both widens the deficit and lifts the cost of closing it.
D. IMO GFI
We believe the regulation may face delays, but we hold to what is on the table and model it as it was intended to start. Fuel consumption is again derived from the IMO studies. We assume the industry pays the Tier 1 penalties in full and settles the Tier 2 balance at a discount, which mirrors the discount a vessel achieves on FuelEU compliance.
The curve steepens because the thresholds keep falling. As the limits tighten year on year, more fuels lose their compliant status and a larger share of consumption moves into deficit. The revenue this produces also lines up with other public studies estimating the financial impact of the regulation.
Regional
We see implementation, and commitments to implement, from a number of regions. We group these under "Regional", acknowledging their presence while recognising that the overall impact stays low. The current names include Gabon, Djibouti, and a commitment from Turkey. They are first movers capturing geographic leverage, and a sign of where the rest of the market may eventually go.
The number on the chart will move. Prices shift, timelines slip, and a single political decision can redraw a line. But the direction does not change. Compliance stops being a regional carbon price an owner can plan around and becomes a global cost embedded in every voyage.
The owners who treat this as a fixed bunker-style line item will keep paying the full price. The ones who read the stack early, see where each regulation overlaps, and position their fuel and pooling strategy against it will pay a good deal less. The market is uncertain, but it has already told us where it is going.
Scenario 1: Maritime compliance costs are no longer confined to regional regulation. Based on current policy timelines and market assumptions, the industry’s annual compliance bill could rise from around USD 2.7 billion in 2024 to more than USD 57 billion by 2032, with the IMO framework becoming the largest driver of future cost exposure.
The maritime industry has spent the past few years in a transition that does not seem to end. It is in a race to become an industry where decarbonisation is measured, priced, and felt on a global scale.
We no longer operate in an era where a shipowner worries about one regulation, or one bunker price. Every stakeholder now sits on the bench of a regulatory show, wondering what comes next. To understand what these regulations mean commercially for a vessel, you have to understand what each one adds to the stack.
The maritime compliance market is uncertain. It is not unpredictable.
Over time, more regions will recognise the revenue sitting inside this transition and move to capitalise on their geographical leverage. What follows is a market built around a few heavy hitters, complemented by a handful of regional schemes that chose to move first.
Based on current visibility, this is our estimate.
On our assumptions, the annual cost of maritime compliance grows from around 2.7 billion USD in 2024 to roughly 57 billion USD in 2032. Two moments define the shape of that curve.
The first is EU ETS, which carries the market on its own through the early years as the maritime phase-in completes. The second, and larger, is IMO GFI. It is planned to enter in 2028 but can have an altered version on a slightly adjusted timeline, however it would quickly become the single biggest line in the stack, close to two thirds of the total by 2032. EU ETS settles into second place at around 16 billion USD, with FuelEU, UK ETS, and the regional schemes filling out the rest.
The point is simple. The center of gravity moves from a regional carbon price to a global one inside a single decade.
A. EU ETS
Emissions eligible for EUAs are derived from the public MRV database, then adjusted for the scope of the regulation, the greenhouse gases covered and the phase-in. To stay conservative, we hold the industry emitted volume constant across the period and apply EUA price projections from several sources, growing at around 8% a year on average. Currency forecasts are applied throughout, so the USD figures reflect projected EUR forward swap rates rather than a fixed conversion.
B. UK ETS
With the announced inclusion of the domestic maritime sector in the UK ETS, the stack builds further. Base emissions are derived from impact studies produced by several policy groups, then prorated for the timeline and the future inclusion of international emissions, as the administration has signalled it intends. UKA price projections come from a range of sources, with the same FX treatment applied.
C. FuelEU
Public data is limited here, so we use the IMO study for fuel consumption and prorate it to EU consumption, joined to the MRV data. To date the big majority of vessels chose pooling over penalty, so we are not aware of a single case where vessels chose to pay the default penalty instead of an alternative such as pooling, so we model the pooling route rather than the penalty.
We hold the pooling cost constant across the period. Even so, the industry's compliance deficit grows as certain fuels lose the advantage they once held in generating surplus. The step change in 2030 reflects the tightening of the GHG intensity target, which both widens the deficit and lifts the cost of closing it.
D. IMO GFI
We believe the regulation may face delays, but we hold to what is on the table and model it as it was intended to start. Fuel consumption is again derived from the IMO studies. We assume the industry pays the Tier 1 penalties in full and settles the Tier 2 balance at a discount, which mirrors the discount a vessel achieves on FuelEU compliance.
The curve steepens because the thresholds keep falling. As the limits tighten year on year, more fuels lose their compliant status and a larger share of consumption moves into deficit. The revenue this produces also lines up with other public studies estimating the financial impact of the regulation.
Regional
We see implementation, and commitments to implement, from a number of regions. We group these under "Regional", acknowledging their presence while recognising that the overall impact stays low. The current names include Gabon, Djibouti, and a commitment from Turkey. They are first movers capturing geographic leverage, and a sign of where the rest of the market may eventually go.
The number on the chart will move. Prices shift, timelines slip, and a single political decision can redraw a line. But the direction does not change. Compliance stops being a regional carbon price an owner can plan around and becomes a global cost embedded in every voyage.
The owners who treat this as a fixed bunker-style line item will keep paying the full price. The ones who read the stack early, see where each regulation overlaps, and position their fuel and pooling strategy against it will pay a good deal less. The market is uncertain, but it has already told us where it is going.
