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FuelEU Maritime · EU ETS shipping · IMO CII · EU MRV

Reconciled ±0.0000% vs EMSA 2023

Verifier-grade FuelEU + EU ETS + IMO CII compliance, reconciled to the exact euro.

Provenship computes your fleet's 2026 obligations from your bunker delivery notes and voyage data. Methodology reconciled against EMSA's published 2023 emission report on 12,637 vessels — ±0.0000% delta.

Pre-GA. Methodology review by appointment. No public self-serve.

Container ship at dawn on the open sea — maritime compliance ledger imagery

Engine reconciliation — 2026-06-26

535,884,359

Aggregate projected 2026 FuelEU Maritime penalty across the EMSA 2023 public dataset.

Vessels reconciled

12,637

Fuel-bearing entries in EMSA’s published 2023 emission report.

Calc-only vs full-stack delta

±0.0000%

67/67 regulator-fixture tests passing.

12,637
Vessels reconciled
Fuel-bearing entries in the EMSA 2023 public dataset
€535,884,359
Projected 2026 FuelEU penalty
Aggregate fleet liability, Reg. (EU) 2023/1805 Annex IV
0.0000%
Engine delta vs EMSA published
Calculation-only vs full-stack run, 2026-06-26 proof
9
Regulator fixtures
JSON fixtures pinning every formula to a citation

Inputs

Bunker delivery notes + noon reports

Calculate + reconcile

Provenship engine

Outputs

Verifier-ready compliance report

From bunker delivery note to verifier-signed PDF. One reconciled engine across FuelEU, EU ETS, and IMO CII.

The engine in motion

Ingestion. Calculation. Reconciliation. Export.

Master sends the noon report in whatever format the bridge produces. Provenship ingests, structures, computes FuelEU + EU ETS + IMO DCS + CII contributions, and surfaces them in real time. At year-end, the verifier signs one pack.

Container vessels at port at dawn — fleet at scale

What "reconciled" means

Two independent code paths. One fleet penalty number.

On 2026-06-26 the Provenship engine was run twice against the EMSA THETIS-MRV public 2023 dataset. The calculation-only path (ProofCli) computed €535,884,359 of aggregate 2026 FuelEU penalty across 12,637 fuel-bearing vessels. The full-stack path persisted every fuel and voyage row through the same Postgres-backed handlers production uses, then read each vessel back and recomputed from the rehydrated rows. The two paths agreed to ±0.0000%.

That is the bar this site is built around. Every number on the marketing pages comes from a single TypeScript constant (src/lib/reconciliation-data.ts) that is regenerated from the engine's proof run. There are no hand-typed totals.

Read the full reconciliation report →

Capabilities

Three regimes, one engine, one audit trail.

FuelEU Maritime, EU ETS shipping, and IMO CII share fuel data, voyage data, and the same reconciliation discipline. Each formula is anchored to a regulation citation and pinned by a regulator-derived fixture in the test suite.

FuelEU Maritime

GHG intensity computed per voyage from BDN-resolved fuel mix; compliance balance against the 2025-2029 target of 89.34 gCO2eq/MJ; pooling and banking modelled. Penalty €2,400 per tonne VLSFO-equivalent in deficit.

Reg. (EU) 2023/1805 Annex II + Annex IV

EU ETS — shipping

Scope CO2 from EU-relevant voyages × phase-in factor × EUA spot price. 40% in 2024, 70% in 2025, 100% from 2026. Surrender modelling and free-allocation handling.

Directive 2003/87/EC as amended by Directive (EU) 2023/959

EU MRV

Annual emission report shape per Annex II including verification status, EUA returned, and per-voyage attribution. Output reconciles to EMSA THETIS-MRV public publication.

Reg. (EU) 2015/757 Annex II (as amended)

IMO CII

Attained Carbon Intensity Indicator per vessel-year against the reference line and reduction factor. A-E rating output with three-year deteriorating-rating watchlist.

IMO Resolution MEPC.354(78)

Multi-fuel via BDN

Weighted GHG intensity across HFO, VLSFO, MGO, LNG, methanol, LPG and biofuel blends. Each fuel's Cf, LCV and well-to-wake emission factor pinned to the regulation table.

Reg. (EU) 2023/1805 Annex II Table 1; MEPC.1/Circ.866

Multi-tenant isolation

Postgres row-level security with fail-closed TenantGuard transactions. Every read and write carries a tenant_id predicate enforced at the database, not at the application boundary.

Provenship ADR-003 (tenant isolation)

Pipeline

From bunker delivery note to verifier-ready report.

A single fleet run is a three-stage pipeline. Each stage is independently auditable, and the resulting PDF is reconcilable line-by-line to the underlying fuel and voyage entries.

  1. 01

    Ingest BDNs + voyage data

    Upload bunker delivery notes (PDF) and noon reports (CSV / EDI). Provenship extracts fuel type, quantity, sulphur content, well-to-wake emission factor, and persists each field with citation provenance from the source document.

  2. 02

    Compute the three regimes

    The engine computes FuelEU Maritime GHG intensity vs target, EU ETS scope CO2 × phase-in × EUA spot, and IMO CII attained against the reference line. Every line of arithmetic is logged with the regulation article that grounds it.

  3. 03

    Export verifier-ready outputs

    Generate a verifier-ready emission report in the Reg. (EU) 2015/757 Annex II shape, plus machine-readable exports for fleet roll-up, pooling, and surrender accounting in your ERP.

Methodology preview

Same euro figure, two independent code paths.

The engine was run two ways against the EMSA 2023 public dataset: a calculation-only path that operates directly on parsed CSV rows, and a full-stack path that persists every fuel and voyage row through TenantGuard transactions and reads back through the same handlers production uses. Both paths produced the same fleet-aggregate FuelEU penalty.

FuelEU Reg. (EU) 2023/1805MRV Reg. (EU) 2015/757ISO 14083 2023Reconciled ±0.0000% vs EMSA 2023

FuelEU compliance gauge — illustrative

Surplus vessel-5.14 gCO2eq/MJMarginal+1.66 gCO2eq/MJMaterial deficit+8.16 gCO2eq/MJ

Intensities in gCO2eq/MJ against the 2025 yearly limit (89.34 gCO2eq/MJ) from Reg. (EU) 2023/1805. Live gauge in the operator dashboard.

Read the full reconciliation report

Reconciliation run — 2026-06-26

sextant-calc/1.0.0-SNAPSHOT

Calculation-only path

calculation-only ProofCli

€535,884,359

Full-stack path

Dagger → handlers → DB (TenantGuard transactions)

€535,884,359

Engine delta

Identical fleet aggregate to four decimal places

0.0000%

Vessels parsed

12,637 carried fuel data; 11,928 in 2026 deficit

12,829

Total runtime

53s ingest + 116s projection

170 s

Automated test suite

9 regulator-derived JSON fixtures pinning each formula

67 / 67

What Provenship does not do

Refuse before approximating.

Four capability boundaries we will not cross. Each one is a place a generic "maritime AI" platform would happily approximate; Provenship refuses because the cost of being wrong is real money or, in some cases, a safety event.

OUT OF SCOPE

Route or speed optimisation

Provenship does not propose voyage plans, slow-steaming windows, or weather routing.

Why not

That is a maritime operations decision with safety and chartering constraints we cannot model. Use your voyage planner, weather routing, or operations platform.

OUT OF SCOPE

Voluntary carbon offsets

Provenship does not source, price, or retire voluntary carbon credits.

Why not

FuelEU and EU ETS are compulsory regimes priced and surrendered in EUA. Voluntary offsets are not a substitute for either, and we will not blur that line.

OUT OF SCOPE

Bunker procurement or pricing

Provenship does not quote bunker prices, recommend suppliers, or trigger purchases.

Why not

That is a commercial relationship between the operator and the supplier. We consume the bunker delivery note; we do not generate it.

OUT OF SCOPE

Ship management or chartering

Provenship does not manage crews, schedule maintenance, or sign charterparties.

Why not

Reference category: maritime operations + chartering platforms. Provenship is the calculation and reporting layer, not the operating system.

Methodology reconciled against

  • EMSA THETIS-MRV

    75,587 vessel-years 2018-2023

  • Reg. (EU) 2023/1805

    FuelEU Maritime

  • Reg. (EU) 2015/757

    EU MRV

  • Directive 2003/87/EC

    EU ETS

  • IMO MEPC.354(78)

    CII rating

  • GLEC Framework v3.0

    Cross-reference

  • ISO 14083:2023

    Methodology

No customer logos, no fake testimonials. The trust signal is the public regulatory and methodology corpus the engine reconciles against. Independent verifier review is in progress; Provenship itself is not an accredited verifier.

Citation grounding

Every constant traces back to an article and a table.

Provenship does not invent emission factors, target lines, or penalty rates. Each numeric input is pinned to its Official Journal reference or IMO resolution number, and tested against a regulator-derived JSON fixture in the build.

How citation grounding works →

Sample formula provenance

  • HFO well-to-wake Cf

    3.114 gCO2eq/g

    Reg. (EU) 2023/1805 Annex II, Table 1Heavy fuel oil emission factor used in GHG intensity computation

  • FuelEU 2025-2029 target

    89.34 gCO2eq/MJ

    Reg. (EU) 2023/1805 Article 4(2)−2% from 91.16 baseline; applies to all reporting years 2025 through 2029

  • FuelEU penalty rate

    €2,400 / tVLSFOeq

    Reg. (EU) 2023/1805 Annex IVPer-tonne VLSFO-equivalent in compliance deficit, multiplied by deficit mass

  • EU ETS 2026 phase-in

    100%

    Directive 2003/87/EC Article 3gbFull scope of in-scope CO2 from 2026; 40% (2024) and 70% (2025) precede

Methodology review

Want a verifier letter of non-objection on our methodology?

Send a one-line email and we will return the 25-page methodology review document — formula derivations, fixture sources, EMSA reconciliation appendix, and the engine version that produced each number. No NDA required for the review document itself.

Provenship is not an accredited verifier. The accredited verifier signs the emission report; Provenship produces the report and the audit trail behind it.