A lot has been written about the Shadow Fleet in recent years, but with our (November 2025) symposium in mind, it may be a moment to dive back into the aspect of the Shadow Fleet, what is it, how big is the problem and what is the problem actually.
A quick search online will give you an enormous amount of information in no time, both in Dutch and English (Shadow- or Dark Fleet).
- There is a commonly used definition as follows: These dark fleets or shadow fleets are generally ships that use various methods and strategies to disguise their existence and presence in order to avoid sanctions, circumvent various regulations (both in the field of safety and the environment) or engage in other illegal activities.
- Due to the scale of the problem, the IMO has even decided to use a definition which was adopted on December 6, 2023 as follows: ‘Dark fleet’ or ‘shadow fleet’ mean ships that are engaged in illegal operations for the purposes of circumventing sanctions, evading compliance with safety or environmental regulations, avoiding insurance costs or engaging in other illegal activities, which may include:
- Carrying out unsafe operations which do not adhere to international regulations and well-established and strict industry standards and best practices.
- Intentionally avoiding flag State and port State control inspections.
- Not maintaining adequate liability insurance or other financial security intentionally avoiding commercial screenings or inspections.
- Not operating under a transparent corporate governance policy that assures the welfare and safety of those on board and the protection of the marine environment.
Works Council
- Intentionally taking measures to avoid ship detection such as switching off their AIS [automatic identification system] or LRIT [long-range identification and tracking system] transmissions or concealing the ship’s actual identity when there is no legitimate safety or security concern sufficient to justify such action.’
- Finally, as far as definitions are concerned, some authorities are of the opinion that a nuance should be made around the concept of Shadow Fleet, specifically when it comes to tankers, by seeing three types of ships or fleets, as follows:
Cleared Fleet
These are the ships for which there is no concern and where no ‘red flags’ are known. These red flags can be found, for example, in a (often) changing owner construction and also (many) changes of flag. On the other hand, the Dark Fleet; with these ships one sees an almost continuous withholding of ID and location. These ships can be found (if they are found) in the dark activities, where at least the AIS is almost continuously switched off/disabled. Ships within this fleet are in fact continuously engaged in illegal shipping practices. Thirdly, the Gray Fleet. In this case, an attempt is made to make the origin of the ship (both in terms of owner and movements) difficult to trace. From a distance, it may look like the activities and movements are legal and not to evade sanctions, but in reality the size of this fleet has actually grown and is purely used to evade the sanctions as they came into force after the Russian invasion of Ukraine.
So much for the definition of Shadow Fleet. Why does this phenomenon exist?
Let’s be clear, illegal practices, shady ownership constructions, (many) flag changes and indeed the dismissal of AIS are not new as such. However, these things and the growth of the Shadow Fleet phenomenon have taken off enormously following Russia’s invasion of Ukraine and the world’s response to it.
The calls for and indeed the introduction of a comprehensive package of measures and global sanctions aimed at hitting Russia’s economy have had a huge impact.
Russia’s exports are about 60% dependent on the energy/oil and gas activities and therefore a primary goal of the sanctions.
With the loss of a large part of the market for Russian oil (EU/US), Russia started looking for new customers, of course in countries that did not participate in the various sanctions packages. This meant a further need for transport around the world from Russia.
One of the most important sanctions is therefore that related to a ban on the purchase/sale and transport of Russian Oil, but perhaps more importantly, linked to a price cap for oil that can still find its way into the world. This has been done to prevent a complete outage and therefore possible global supply problems, but, with a limitation of the profit on it, again to ensure an economic impact, a restriction of Russia to earn (a lot of) from exports and thus support the war activities.
Finally, this last measure, the price cap (US$ 60 for a barrel) was linked to the restriction/sanction that companies that provide technical support, chartering, but also insurance could only do so if it was proven that the price cap was applied to a certain contract/ship movement. If this is not the case, the services in question may not be provided. Since the combination of countries within the EU and G7 dominate the world of Chartering and Insurance, this meant a huge restriction and made it impossible for Russia to contract tankers with the desired insurances and thus transport Russian Oil.
Size
Precisely because of the ‘shadow’ effect, it is difficult to determine with complete certainty how many ships are involved in the shadow fleet.
A tour of the various estimates shows that the shadow fleet is already more than 10% of the total world tanker fleet.
According to conservative estimates, the gray fleet consists of about 1000 ships and the dark fleet of a little more, around 1300.
Where
Crude data are also available about the destination of part of the shadow fleet, with India, China and Turkey the leading final destinations with an estimated amount of oil (combined) of almost 4 million barrels per day. Other (significant) destinations are Singapore, United Arab Emirates, Brazil and Saudi Arabia.
However, we all know that this is not just a destination problem, the shadow fleet (just like the oil trade) moves worldwide. In addition, ships of the shadow fleet are known to make ship to ship transfers in various places and even more worryingly, bunkering operations around the world and crossing waters within the EEZ. A recent study showed that in the first six months of last year alone, more than 400 ships from the shadow fleet passed the Dutch North Sea coast. This is a global but at the same time local problem.
The care
It will be clear, the concern about the existence of this fleet has a direct tactical part, namely the sanctions to hit the economy and thereby reduce the war capacity. The existence and use of these vessels reduces the impact of the sanctions and generates significant revenues. Here, too, estimates are made by various agencies and they quickly run in the direction of several billions per year.
In addition to the aforementioned methodologies that make it possible for these ships and companies to be active in transport, they are being expanded in response to attempts to stop or limit this. A good example here is the existence of false flags. A recent article by the Royal Association of Dutch Shipowners pointed to research that indicates the use of false flags, ostensibly of the Kingdom of the Netherlands. This is as an action on other flags that try to prevent the use of their flag when it concerns ships of the shadow fleet. In the example mentioned, an additional problem is that it can affect the reputation of the Netherlands and Curaçao, not to mention the safety and working conditions of the colleagues on that fleet.
The flags of Panama, Malta, Marshall Islands and Liberia along with about 15% of Russia are currently flown on about 70% of the shadow fleet.
Perhaps an even greater concern is that of the possible use of ships from the shadow fleet for, for example, gathering information, espionage and even actively causing damage to infrastructure. In an unstable world, shipping in general, but also ports, terminals, pipelines and communication/data pipelines occupy an increased strategic value. This possibility of using merchant ships for espionage and sabotage is now being recognized, and a striking example of this is when Finland seized the tanker Eagle S at the beginning of this year on suspicion of (deliberately) damaging a submarine power cable.
In conclusion
We have already talked briefly about the age of the ships in the shadow fleet. Research shows that a particularly substantial part of that fleet are indeed the older ships.
The age and ‘shelf life’ of tankers is largely driven by pressure from various users (charterers) where age limits are applied, often in combination with a more intensive check on older ships through inspections and review of Class records and Structural Surveys. Research shows that more than 70% of the shadow fleet (Crude Oil, Products and Oil/Chemicals) consists of vessels that are older than fifteen years, with even an estimated average age of more than twenty years.
Although even without the shadow fleet, the world tanker fleet has recently seen a slow increase in average age, everyone agrees that the existence and growth of the shadow fleet has created an interesting market for reselling what is considered older vessels in normal terms and in the eyes of the average charterer/user.
Add to this the shady ownership structures, poor flag state control and no, limited or shady insurance and it will be clear that we also have to be increasingly concerned about safety and the environment.
The combination of old ships, dubious owners, questionable maintenance and control and certainly a very limited form of overview and supervision creates the kind of risks that we, as a collective in the maritime industry, and so far successfully, try to limit and control.
Information paper provided by NVKK (Netherlands) which has been a member of IFSMA since 1974.