Resilience & Compliance Advisory
RCA is an Athens-based practice that studies maritime carbon, resilience and cyber regulation and turns the findings into methods and tools that clients keep and run themselves. Its work covers EU ETS, FuelEU Maritime and the IMO framework on the carbon side, and NIS2, CER and DORA on the resilience side.
The cost is decided at the fixture; the bill arrives a year later, on someone else's desk
EU ETS and FuelEU Maritime are priced, in practice, after the fact: the allowances are bought and the penalty is settled months after the freight was agreed, by a department that was not in the negotiation. The chartering desk, the broker and the lender each see a piece. The tools that exist are either annual reporting systems or subscription platforms that keep the data and the method on their own servers.
It puts the regulation's arithmetic where the decision is made — on the desk, before the fixture, in a file that runs on the company's own computer — with every figure traced to the rule and the input that produce it, and the method handed over so the client is not dependent on us. The same engine serves the charterer, the owner and the bank, so the three read one number.
Not a verifier, not a registry, not a trading or hedging service, and not a source of freight or investment advice. The tools quantify; the judgement, the negotiation and the decision stay with the client.
Argyris Zafeiropoulos
Principal Advisor, Resilience & Compliance Advisory
Argyris Zafeiropoulos works as a scientific analyst in shipping and publishes on how carbon pricing and resilience rules reach the commercial and financial decisions of shipping companies: the allocation of carbon cost in charter contracts, the effect of FuelEU Maritime on fleet strategy and vessel values, and the cyber-governance evidence a listed group has to hold. The tools on this site are that research made operational — the same arithmetic, on the client's own desk.
What he brings to each of them comes from more than three decades in technology, banking and regulated organisations, and the three products follow that career closely.
He served as Executive Vice Chairman and later General Manager of a Greek bank and chaired its investment arm. MCCS-BV is written from the credit committee's side of the table: it says what a CRO can use (collateral haircut, LTV, an LGD input, Poseidon alignment) and what it refuses to be (a valuation, a probability of default, a rating).
A mathematician and computer scientist by training, with fourteen years in senior roles at two Fortune 500 technology multinationals — a decade at a global IT group, four years at a semiconductor leader — and several technology ventures of his own. That is why the tools are built from scratch rather than assembled from a platform, run on a single file with no server, and carry every figure back to the rule and the input that produce it.
He has chaired a public-sector pension fund and run a bank under supervision, and advises banks on DORA, NIS2 and CER. He knows how an examiner reads evidence — which is what the MCRC tamper-evident log and the Study's NIS2 / CER / SEC-SOX crosswalk are built for.
He studied Mathematics and Computer Science at the University of Athens and holds an MBA from the University of Sunderland, with postgraduate programmes in Computer Science, Business Administration and Real Estate. He has led Resilience & Compliance Advisory since 2025.
What the figures rest on
| Figure | Source text | How it is applied | Checked to |
|---|---|---|---|
| EU ETS maritime | Directive 2003/87/EC as amended by 2023/959; MRV Reg. (EU) 2015/757 | Phase-in by emissions year: 40% of 2024, 70% of 2025 (surrendered by 30 Sep 2026), 100% of 2026 emissions (surrendered in 2027); 50% of voyages with one EU end, 100% between EU ports, berth in full; CO₂e (CH₄, N₂O) from 2026 emissions; EEA ports included | 8 Nov 2026 |
| FuelEU Maritime | Reg. (EU) 2023/1805, Annexes II & IV | Baseline 91.16 gCO₂e/MJ; −2% from 2025, −6% 2030, −14.5% 2035, −31% 2040, −62% 2045, −80% 2050; €2,400 per tonne VLSFO-equivalent deficit; pooling, banking, borrowing; Art. 23 consecutive-deficit multiplier; Norwegian and Icelandic ports third-country ports until the regulation is incorporated into the EEA Agreement — no earlier than 1 Jan 2028 per the Norwegian Maritime Authority (11 Aug 2026) | 8 Nov 2026 |
| CII | IMO MEPC.352–355(78), MEPC.338(76) | Per-vessel AER against the required line, ship-type dd vectors, annual reduction factors | 8 Nov 2026 |
| Emission factors | IMO MEPC.364(79); FuelEU Annex II | Tank-to-wake CO₂, CH₄ and N₂O per fuel, combined as CO₂e (GWP₁₀₀); well-to-wake intensities per pathway | 8 Nov 2026 |
| IMO Net-Zero Framework | MEPC 83 approved text (April 2025); adoption adjourned at MEPC/ES.2 (October 2025); adoption to be attempted at MEPC 85, scheduled for December 2026 — a scheduled step, not an adopted rule | Scenario only, labelled as such: Tier 1 / Tier 2 remedial units at the 2028–2030 prices, Z-factors to one decimal; never added to an EU figure without saying so; dropped or re-dated the day the IMO decides otherwise | 8 Nov 2026 |
| Distances | NGA Pub 151 (public domain); junction compositions; voyage planners and sea-lane calculators for pairs Pub 151 does not tabulate | RCA Port Distance Reference v1.16 (7 Nov 2026): 237 ports, 479 legs in three grades — 91 verified (Pub 151 book value), 67 checked (named secondary source, dated), 321 curated (working figure, "verify before quoting"); the grade is shown on every leg in the tools | 7 Nov 2026 |
| Vessel archetypes | RCA reference archetypes, reviewed July 2026; checked against THETIS-MRV 2024 (see Validation below) | Class speed and consumption used only where the client has not entered the vessel's own figures; ±15–25% against a named ship, and the tools say so | 10 Nov 2026 |
No index-provider route or benchmark data is used in the tools; index route codes appear only as orientation. When a rule changes, the date in this table and in each build moves with it, and clients receive an updated build with the change named in its changelog.
The Capesize archetype against 161 reported ships
Every ship calling at an EU port reports its year to THETIS-MRV, the public EU register. We read the 2024 publication (v255, 10 Nov 2026) and placed the MCCS Capesize archetype in it. The archetype is not fitted to this data; it was set in July 2026 and the check was run afterwards.
| Quantity | MCCS archetype | Reported, Capesize-class 2024 | Where the archetype sits |
|---|---|---|---|
| Fuel per nautical mile — the basis of the voyage carbon cost | 149 kg/nm (52 t/day at 14.5 kn) | Q1 132 · median 148 · Q3 157 kg/nm (n = 161) | 54th percentile; 71% of the ships lie within ±15% of it — the class range the desk shows |
| Fuel per day at sea | 52 t/day at 14.5 kn · 29.5 t/day at 12 kn | Q1 32 · median 36 · Q3 40 t/day, at an implied average 10.4 kn | Per day the archetype is a design-speed figure (99th pct); at 12 kn it is at the 16th. Per mile the two agree because real ships sail slower and burn less per day |
| CO₂ per nautical mile | 465 kg/nm | median 460 kg/nm | +1% |
Method and limits. Source: THETIS-MRV "2024 Full ERs", 4,504 bulk carriers; 2,459 with at least 30 days at sea in MRV scope. The register has no deadweight, so Capesize-class ships are taken as those whose average cargo over all reported miles — fuel per mile divided by fuel per tonne-mile — is 80,000 t or more; 161 ships, with an attained EEDI around 2.4 gCO₂/t·nm, consistent with the class. Reported figures are annual averages of laden and ballast legs, port approaches and weather, at the speeds actually sailed; the archetype's per-day consumption is a design-speed figure and is not expected to match it, the per-mile figure is. The same check is repeated on each year's publication, and the script that does it is supplied with the Reference.
Every number is tied to the regulation and the data that produce it.
Methods are transferred to the client, with no ongoing dependency.
Tools run on the client's own machines.
A quantification layer beside existing systems, replacing none of them.