Shipping's Autumn In-Tray: Four Files Left Behind by the Summer of 2026
Shipping was granted no summer recess. Between the hardening of Iran's toll on the Strait of Hormuz, a Red Sea reopening that remains fragile, a Rhine that fell to its lowest reading since gauging began, and a European carbon deadline set for 30 September, the summer of 2026 has left shipowners with a crowded autumn.
The essentials
By 30 September, every company must have surrendered allowances covering 70% of its 2025 emissions, against 40% last year.
Iran's Hormuz toll now runs through two companies, both designated by OFAC.
The Red Sea is reopening, yet traffic remains 41% below pre-crisis levels.
The Rhine fell to six centimetres at the Kaub gauge, a record since 1880.
Three of these files weigh directly on operating costs and internal procedures. The fourth, the Red Sea, governs the routing assumptions of the coming months. What follows is a closer look, beginning with the most pressing.
Carbon: a bill multiplied by 1.75 on 30 September
This is the deadline technical departments would be unwise to leave until mid-September. By 30 September, every shipping company must have surrendered allowances covering 70% of its 2025 emissions, against 40% last year for the preceding period. The rate rises to 100% from 2027.
At constant emissions, the bill is therefore multiplied by 1.75 from one year to the next. Carbon is leaving the reporting column and settling in among the operating costs, alongside bunkers and insurance.
Three checks are called for before month end:
Reconcile the accounts. Set the CO₂ in the verified March report against the allowances actually held in the Union Registry account: any gap needs identifying now rather than in the closing days.
Test the access. Active accounts, up-to-date authorised representatives, working two-factor authentication: every year, surrenders fail over an expired password or a representative who has left the company.
Plan the top-up purchases. Where allowances are short, buying ahead pays: in 2025, those who moved late bought into a tight market, at the highest price of the period.
Even so, it is the quality of operating data that is paid for in cash here. An emissions report is built from bunker consumption and running hours; where those records live in separate workbooks, reconciliation can take several weeks. We set out the consequences in our comparison of a maritime CMMS and a spreadsheet.
The longer horizon lies with the International Maritime Organization, which will bring its global carbon price back to the table at MEPC 85 in late November. After April's adjournment, the outcome remains uncertain, as we argued in our analysis of the IMO's carbon framework.
Hormuz: when a de facto toll becomes an organised scheme
What in the spring was merely a troubling precedent, the first de facto toll imposed on an international strait, took on the shape of a structured arrangement over the summer. Two entities, Persian Gulf Marine Insurance Company and HormuzSafe Marine Services Authority, now sell vessels a “transit insurance” presented as the condition of passage.
The arrangement is not without irony, since the cover protects against seizure risks that are largely created by the regime itself. The US Treasury settled the question of vocabulary by describing an “extortion scheme” backed by the Islamic Revolutionary Guard Corps. Payments are accepted in digital assets, bitcoin over the Lightning network, Tether or USDC, with the avowed aim of circumventing sanctions.
Washington answered in two stages:
On 29 July, OFAC designated both companies together with eight further tankers attached to Iran's shadow fleet.
On 24 August, it clarified the scope of the risk, and it is this second step that concerns operators most directly.
The exposure does not fall on the payer alone: accepting a guarantee, an insurance policy or certain “safe passage” services can be enough to attract sanctions risk.
Owners are left with a dilemma in which neither branch is comfortable. Declining to pay exposes the vessel and her crew; paying exposes the owner, its underwriter and its banks. As for the recourse to cryptoassets, it changes nothing about the nature of the counterparty, since changing the means of payment does not change who is being paid. On the human dimension of the crisis, we would refer readers to our reporting on the seafarers held up in the strait.
A significance that reaches beyond the strait
The industry now finds itself caught between several sets of jaws: sanctions, tariffs, geopolitical risk, war-risk insurance and straits under pressure. Commercial rules can change within days, whereas a ship is financed, insured and operated across decades. That mismatch of timescales is, more than the sanctions themselves, the underlying difficulty.
Our conviction is that compliance, in the classic sense of the word, no longer suffices to secure legal safety. What is required now is the ability to demonstrate, almost transaction by transaction, who asked for what and why, where the money went, what was received in return and on what legal basis.
In a world where flags of convenience, ship-to-ship transfers and layered insurance structures multiply the grey areas, traceability becomes a form of protection. Before a regulator, an incomplete file will not merely be a documentary weakness: it may serve to establish that the owner did not in fact control its compliance chain. The same logic applies to port state control inspections, as our article on the ISM Code and the errors that lead to detention sets out.
Red Sea: a genuine return that remains a wager
This is the least bad news of the period. The major carriers are gradually shifting services back through Suez: Maersk reports that more than 30% of its Asia-Europe volumes previously diverted around the Cape of Good Hope have returned to the canal, while MSC restored four services at the end of August after a series of test transits.
The counters confirm the movement without permitting euphoria. Between 20 July and 16 August, close to 1,090 transits were recorded at the Red Sea's northern chokepoint, according to Lloyd's List Intelligence: a high since January 2024, which nonetheless remains 41% below pre-crisis levels.
The attack of 12 August off Yemen, which cost six seafarers their lives, is a reminder that the return is decided vessel by vessel. In practice, operators must keep two routing scenarios running in parallel, hence two sets of consumption assumptions and, by extension, two carbon trajectories. All of which needs building into the 2027 budgets from the outset.
The Rhine at six centimetres, or the crisis that went unnoticed
On 14 August, the Kaub gauge, the Rhine's reference point, read six centimetres. An absolute record since gauging began in 1880, the previous low of twenty-five centimetres dating from October 2018.
At such a level, the consequences read right along the basin:
A barge carries no more than 10 to 20% of its nominal capacity.
Duisburg, Europe's largest inland port, ran at a third of normal throughput.
Berlin produced an emergency freight plan: additional rail paths and relaxed heavy-goods traffic rules in four Länder.
Chemical producers in the Rhine basin, BASF and Lanxess foremost among them, reworked their logistics for the second time in eight years.
In France, the drought closed the Canal de Bourgogne and the Canal latéral à la Loire and forced restrictions on north-south links. Part of the French inland fleet was thus left idle in mid-season.
From the field: forced downtime turned into maintenance brought forward
One operator running several units on the Rhône-Saône corridor chose to invert the logic. Rather than absorb the lay-up, its technical manager reviewed every job scheduled over the following six months in order to bring forward whatever could be done: engines, deck equipment, statutory inspections.
The triage took no more than a morning. With history, due dates and certificates centralised in the BoatOn Book, the list of jobs that could be advanced came out vessel by vessel, parts to order included. In the end, three weeks of imposed downtime were converted into maintenance done in advance, and as many trading windows preserved for the restart, at a point when every navigable day counts twice over.
The contract review, an autumn obligation
War clauses have moved out of the annexes and back into the body of contracts, and three points deserve revisiting before month end:
War-risk policies, for which underwriters now revise excluded areas, cancellation notice periods and transit conditions case by case.
Charterparties drafted before 2024, frequently silent on who pays for a deviation and who decides the route, when they are not outright treacherous.
Counterparties, which call for systematic sanctions screening of the vessel, the owner and the insurer before every fixture: since 29 July, the good-faith argument protects very few.
A common denominator
A strait, a canal, a river and a carbon market: four files with no apparent connection, which nonetheless pose the same requirement. In all four, what protects the operator is not the capacity to forecast but the ability to document and redeploy quickly: to prove a consumption figure, to justify a counterparty, to pull up a maintenance plan in a morning.
That is precisely the purpose of the BoatOn Book, which brings together the maintenance plan, time-stamped records, consumption figures, certificates and documents in a single tool that works on board even without a connection. For ISM and ISPS compliance work, BoatOn Consulting takes over.
This article expands on the monthly briefing written by Bertrand Gerbaud, devoted each month to maritime regulatory developments. Subscription is free.
Sources: US Department of the Treasury (29 July 2026); European Commission, maritime ETS FAQ; Lloyd's List Intelligence, Red Sea Brief; Bloomberg and Insurance Journal (Rhine); RailFreight (German freight plan); Holland & Knight (legal analysis of the OFAC designation). Illustrative photos: Pexels, free licence.
