Direct Compliance Target Annual GFI: Draft Reg 35.1.2

The direct compliance target annual GFI is the stricter of the two annual greenhouse gas fuel-intensity targets in draft regulation 35.1.2 of a new MARPOL Annex VI Chapter 5, the legal text of the IMO Net-Zero Framework circulated as MEPC/ES.2/2. For each calendar year it cuts a 2008 reference intensity of 93.3 gCO2eq/MJ by a factor in Table 4, from 17.0 percent in 2028 to 43.0 percent in 2035, giving 77.439 gCO2eq/MJ in 2028 and 53.181 in 2035. A ship whose attained annual GFI is at or below the target is “in direct compliance” under regulation 36.2, owes no remedial units, and receives one surplus unit for each tonne CO2eq of positive balance. The draft was approved at MEPC 83 on 11 April 2025 and has not been adopted.

What the direct compliance target is

The direct compliance target is the second of the two values that make up the target annual GFI. Draft regulation 2.3.18 defines the target annual GFI as the values of “the two-tier target annual GFI (base target and direct compliance target) in accordance with regulation 35”. The base target annual GFI is the looser value; the direct compliance target sits 12.129 gCO2eq/MJ below it in every year to 2035.

Each ship’s attained annual GFI , calculated under draft regulation 33.2 on a well-to-wake basis, is compared with both. The direct compliance target is the only one of the two that decides whether a ship owes anything at all:

“Direct compliance” is not itself a defined term in regulation 2.3. It is the status stated in regulation 36.2, and the target that produces it takes its name from that status.

Formula and reference value in draft regulation 35

Draft regulation 35.2 uses one formula for both tiers. The direct compliance target for calendar year T is the 2008 reference value reduced by the direct compliance factor for that year:

GFI_2008 is fixed in the text as “equivalent to 93.3 gCO2eq/MJ (well-to-wake), representing the average GFI of international shipping in year 2008”. The draft publishes no derivation, and regulation 44.1 names the reduction factors, not the reference value, as the item the five-yearly review “shall consider amending”. Emissions are weighted on AR5 GWP100 values under draft regulation 2.3.2.

One comparison per ship per calendar year

The subscript T is “the calendar year referred to in Table 4”. Under draft regulation 33.1 each ship calculates its attained GFI “over a 12-month period from 1 January to 31 December for the preceding calendar year (reporting period)”, and regulation 36.1 has “each ship” determine its own compliance balance. The word “company” appears in Chapter 5 only in regulations 37.2 and 37.7, on a change of company. No fleet average exists.

Direct compliance target values, 2028 to 2035

Table 4 of draft regulation 35 prints a direct compliance factor for every year from 2028 to 2035. The gCO2eq/MJ values are this site’s arithmetic on the draft formula, rounded to three decimals.

The factor rises 2.0 points a year to 2030 and 4.4 points a year from 2031 to 2035. Between 2030 and 2031 the target drops by 4.105 gCO2eq/MJ, more than twice the 1.866 step of each earlier year. A ship that is in direct compliance in 2030 by a margin of less than 4.105 gCO2eq/MJ falls into the Tier 1 band in 2031 on the same fuel.

The Secretariat note to MEPC/ES.2/2 records that percentage symbols were removed from Table 4, so a factor of 17.0 means a 17.0 percent cut. The full two-tier table and its comparison with the Strategy checkpoints are in the GFI reduction trajectory article.

Nothing set after 2035

Draft regulation 35.3 reads: “By 1 January 2032, the Committee shall determine the Z-factor (ZT) for the Base target and Direct compliance target for the years 2036 to 2040. The 2040 ZT for the Base target shall be set at 65%.” The 2040 base target factor is fixed; the 2040 direct compliance factor is not. Chapter 5 contains no value for any year after 2040, and no 2050 target.

Direct compliance under draft regulation 36.2

A ship is in direct compliance when its GFI compliance balance is zero or positive. Draft regulation 36.1 defines the balance in tonnes CO2eq:

Energy_total is the ship’s total energy for the year in megajoules under regulation 33.2. Grams per megajoule times megajoules gives grams, divided by one million for tonnes.

Regulation 36.2 then reads: “If the GFI compliance balance is equal to or greater than zero, the ship shall be considered in direct compliance and be eligible to receive surplus units for its positive compliance balance in accordance with paragraph 11 of this regulation.” A negative balance sends the ship to regulation 36.3, which requires it to determine a compliance deficit and balance it.

What direct compliance removes, and what it leaves

A ship in direct compliance buys no remedial units and makes no GHG emissions pricing contribution to the IMO Net-Zero Fund . Everything else in Chapter 5 still applies to it:

• the annual data report and verification under regulation 37;
• an account in the IMO GFI Registry , opened by 1 October 2027, and the annual administration fee due by 30 June 2028 and each 30 June after that (regulation 38.2);
• the Statement of Compliance under regulations 6.9 and 37.6.

Surplus units earned below the target

A ship below the direct compliance target turns its positive balance into surplus units . Draft regulation 2.3.16 defines a surplus unit (SU), “expressed in tonnes of CO2eq”, as “a transferable unit a ship in direct compliance is eligible to receive in accordance with regulation 36”.

Quantity: regulation 36.11

Regulation 36.11 reads: “The amount of surplus units a ship in direct compliance is eligible to receive shall be equal to its positive compliance balance, expressed in tonnes of CO2eq, taking into account guidelines developed by the Organization.” Footnote 89 records that the guidelines are still to be developed.

The text sets no cap, no floor and no multiplier. One tonne CO2eq of positive balance is one surplus unit, whatever fuel or technology produced it.

Issuance by the IMO GFI Registry

Surplus units are credited by the Registry, not by the Fund. Draft regulation 38.1 has the Secretary-General establish and administer the IMO GFI Registry, and regulation 38.4.1 requires it to “credit the amount of surplus units a ship in direct compliance is eligible to receive” to each ship account. The ship account statement , due by 31 August under regulations 37.5 and 38.5, records the units credited and what the ship did with them.

The Secretariat note to MEPC/ES.2/2 (paragraph 5.7.1) explains that regulation 36 was reworded so that how deficits are balanced and “how the surplus units are used by the ship have to be recorded in the ship account statement”.

Transfer, banking and voluntary cancellation

Draft regulation 36.12 reads: “A surplus unit, subject to paragraphs 6 and 15 of this regulation, credited to the ship account in the IMO GFI Registry may be used once for one of the following purposes”:

1. “transfer to another ship to balance that ship’s Tier 2 compliance deficit”;
2. “banked for use in the subsequent reporting periods”; or
3. “voluntarily cancelled as a mitigation contribution”.

Regulation 36.13 adds that a unit “shall only be transferred or cancelled once, but each one of a ship’s surplus units may be used for any of the purposes provided for in paragraph 12”. Regulation 36.14 banks any unassigned unit automatically. A banked unit can be used by the ship only against a Tier 2 deficit, because regulation 36.6.2 lists “surplus units banked from previous reporting periods” among the Tier 2 approaches and regulation 36.5 allows nothing but Tier 1 remedial units against a Tier 1 deficit.

The text leaves one point open. Regulation 36.12 treats banking as one of three uses, while 36.13 lets each unit be used for any of them and 36.14 makes banking the default. The draft does not state whether a unit banked in one year can be transferred to another ship in a later year.

Validity and expiry

Regulation 36.15 gives a surplus unit “validity of two calendar years following the calendar year of its issuance from the IMO GFI Registry”. A unit “not used by the ship in whose account it has been credited by its expiry date shall be cancelled by the IMO GFI Registry as a mitigation contribution ”. Regulation 38.4.4 lists the three cancellation events: use against a Tier 2 deficit, voluntary cancellation at the ship’s request, and expiry.

The draft does not fix the date of issuance. Units for a reporting period are credited after verification in the following year (regulations 37.3 and 38.4.1), and no provision says whether the year of issuance is the reporting year or the year of crediting, so no expiry date can be computed from the text alone.

What the draft does not provide

A full-text reading of regulations 30 to 44 finds no provision for:

• a price, sale or market for surplus units; the only prices in Chapter 5 are for remedial units (regulations 36.8 to 36.10);
• pooling, aggregation or fleet averaging of attained GFI;
• borrowing against a later year;
• any ownership or same-company condition on a transfer.

A transfer is a Registry entry between two ship accounts. Any payment for it is a private contract that the draft neither requires nor regulates. Regulation 38.9 requires the Secretary-General to report annually to the Committee on “transaction patterns in the issuance, transferring, usage and cancellation of surplus units”.

Missing the direct compliance target: the Tier 1 band and above

A ship above the direct compliance target has a compliance deficit. Where its attained GFI “is equal to or less than the base target but greater than the direct compliance target”, regulation 36.4.1 gives a Tier 1 deficit only:

The expression is negative for a ship in deficit; this article states deficits as positive tonnes. The only settlement is Tier 1 remedial units (36.5), priced at USD 100 per tonne CO2eq on a well-to-wake basis for the reporting periods 2028 to 2030 (36.8). Surplus units from another ship cannot be used here.

Above the base target, regulation 36.4.2 charges the full 12.129 gCO2eq/MJ band as Tier 1 and the excess over the base target as Tier 2, balanced with surplus units or Tier 2 remedial units at USD 380 (36.6, 36.9). The base target article covers that zone. Regulation 36.10 requires the Committee to adopt the mechanism for prices from 2031 by 1 January 2028; no price exists beyond 2030.

Mislabels: Tier 2 Direct Compliance Threshold, DCT and Required GFI

The label “Tier 2 Direct Compliance Threshold (DCT)” is wrong in each part against MEPC/ES.2/2:

• “Threshold” occurs in Chapter 5 only for zero or near-zero GHG fuels (regulations 39.1 and 44.2). The value is a target.
• “Tier 2” names the dearer deficit above the base target, not the direct compliance target. Missing the direct compliance target first creates a Tier 1 deficit.
• “DCT” is not an abbreviation the draft uses. Its short forms are SU, RU and ZNZ.
• “Required GFI” does not occur. The paired value is the base target.
• “Chapter 4 ter” and “regulations 28ter to 33ter” do not exist. The draft inserts Chapter 5, regulations 30 to 44.
• “Remediation unit” is “remedial unit” in regulation 2.3.11.

The IMO Secretariat’s presentation to the WTO Trade and Environmental Sustainability Structured Discussions on 12 May 2025 used the draft’s terms, describing “Two-tiered GFI reduction trajectories (‘base target’ and ‘direct compliance target’)”.

Ships measured against the direct compliance target

Draft regulation 30.1 applies Chapter 5 to ships of 5,000 gross tonnage and above, the size threshold of the IMO Data Collection System . Regulation 30.2 excludes ships solely on voyages within waters of their flag State’s sovereignty or jurisdiction, ships not propelled by mechanical means and platforms including FPSOs, FSUs and drilling rigs, and semi-submersible vessels until further review.

Every ship in scope faces the same number. Regulations 30 to 36 contain no correction factor and no ship-type, size, deadweight or ice-class term, so a container ship and a VLCC both face 77.439 gCO2eq/MJ in 2028. That differs from the Carbon Intensity Indicator , whose required values vary by ship type and size under MARPOL Annex VI regulation 28. The GFI measures fuel and energy per megajoule and ignores transport work.

Worked example: reaching the direct compliance target on VLSFO

The example is this site’s arithmetic on MEPC.391(81) Appendix 2 default components, not an IMO calculation. MEPC.391(81) prints no well-to-wake totals, so the intensity is derived from the printed components.

Inputs. VLSFO on pathway HFO(VLSFO)_f_SR_gm: WtT 16.8 gCO2eq/MJ, LCV 0.0402 MJ/g, CfCO2 3.114, CfCH4 0.00005, CfN2O 0.00018, with GWP100 weights of 28 for methane and 265 for nitrous oxide.

• Tank-to-wake = (3.114 + 28 x 0.00005 + 265 x 0.00018) / 0.0402 = 78.684 gCO2eq/MJ.
• Well-to-wake = 16.8 + 78.684 = 95.484 gCO2eq/MJ.

The VLSFO and MGO well-to-wake article sets out the same pathway in more detail.

Zero-intensity energy share needed

If the rest of the ship’s energy has zero well-to-wake intensity, the share of total energy it must supply to reach the target is 1 minus the target divided by 95.484:

The last column uses a fuel exactly at the 19.0 gCO2eq/MJ ZNZ threshold of regulation 39.1, computed as (95.484 minus the target) divided by (95.484 minus 19.0). A certified biofuel , e-methanol or ammonia carries its own intensity on its fuel lifecycle label , so the real share depends on that value. For a blend, the blend methodology article shows the energy weighting.

For comparison, the same VLSFO ship needs about 6.2 percent zero-intensity energy to reach the 2028 base target. Direct compliance in 2028 asks for about three times that share.

A ship between the targets

A ship with 402,000,000 MJ of energy (the energy in 10,000 t of VLSFO) and an attained GFI of 80.0 gCO2eq/MJ in 2028 sits in the Tier 1 band. Its deficit is (80.0 - 77.439) x 402,000,000 / 1,000,000 = 1,029.5 t CO2eq, about USD 102,950 in Tier 1 remedial units. Cutting its intensity by 2.561 gCO2eq/MJ removes the whole bill.

A ship below the target

The same energy at an attained GFI of 60.0 gCO2eq/MJ in 2030 gives a balance of (73.707 - 60.0) x 402,000,000 / 1,000,000 = 5,510.2 t CO2eq. The ship is in direct compliance and receives 5,510.2 surplus units.

A VLSFO-only ship of the same energy in 2030 carries a Tier 1 deficit of 4,875.9 t and a Tier 2 deficit of 3,878.5 t, about USD 1,961,400 at draft prices. If the first ship transfers 3,878.5 units to it, its Tier 2 deficit is balanced. Its Tier 1 deficit of 4,875.9 t is not, and it still pays USD 487,590 in Tier 1 remedial units. The first ship keeps 1,631.7 units to bank or transfer.

Value of reaching and beating the direct compliance target

Where a ship sits against the two targets decides what a tonne of fossil fuel displaced is worth. Replacing the 40,200 MJ in one tonne of VLSFO with zero-intensity energy leaves Energy_total unchanged and removes 95.484 x 40,200 g, about 3.838 t CO2eq. At 2028 to 2030 draft prices:

The value of each tonne falls as a ship moves down through the zones. Crossing the direct compliance target changes the payoff from an avoided charge at USD 100 per tonne CO2eq to a unit whose only outside use is another ship’s Tier 2 deficit. A ship holding that deficit has the Tier 2 remedial unit at USD 380 as its alternative for 2028 to 2030, and a ship in the Tier 1 band cannot use surplus units at any price.

A unit is valid for two calendar years following issuance (36.15) and is usable only against a Tier 2 deficit, the ship’s own in a later period or another ship’s by transfer. The draft gives no route to redeem a unit with the Fund. A unit not used by expiry is cancelled as a mitigation contribution.

ZNZ rewards and the direct compliance target

Rewards for zero or near-zero GHG fuels, technologies and energy sources (ZNZs ) sit in draft regulation 39, separate from the compliance balance. Regulation 39.1 sets the ZNZ threshold at “not greater than 19.0 gCO2eq/MJ for an initial period until 31 December 2034, and from 1 January 2035 … not greater than 14.0 gCO2eq/MJ”. Regulation 39.2 lets ships “receive rewards from the IMO Net-Zero Fund for the ZNZs used”, and regulation 41.1.1 lists ZNZ rewards among the Fund’s disbursements.

Regulation 39.3 requires the Committee to define the reward and its methodology “No later than 1 March 2027 and every five years thereafter”. Regulation 2.3.12 describes the reward as “annual compensation”. The emissions avoided are verified by the Administration under regulation 6.9.7 and recorded in the Registry under regulation 38.6.

The text does not make a ZNZ reward conditional on direct compliance, and does not remove rewarded energy from Energy_total or from the balance that produces surplus units. It is silent on how the two interact. Regulation 39.4 requires the Organization to “monitor and publish the share of ZNZs in the total annual energy used on board”.

Reporting and verification against the target

The comparison with the direct compliance target is made once a year after the calendar year ends, under draft regulations 33.1 and 37. The first reporting year is 2028.

The Statement of Compliance is issued under regulation 6.9 by the Administration or a recognized organization and may be checked by port state control under regulation 10.5. It is not an endorsement of the IAPP Certificate , and Chapter 5 adds no IAPP survey step. The ship’s SEEMP must describe the data methodology for regulation 37 on or before 1 January 2028 (regulation 26.4.1).

Values other than the MEPC.391(81) defaults come from a fuel lifecycle label certified by a sustainable fuels certification scheme recognized under regulation 34. The GFI Calculation Guidelines referred to in regulation 33 are still to be developed.

Adoption status of the direct compliance target

The direct compliance target is not law. MEPC 83 approved the draft amendments on 11 April 2025. IMO’s note to UNFCCC SBSTA 62 (June 2025) records a roll-call vote of 63 in favor, 16 against and 24 abstaining, after which the Committee approved the draft “with a view to circulation”. The amendments would revise MARPOL Annex VI, including regulations 2, 6, 10 and 26, and insert Chapter 5. The annex was revised in 2008 by resolution MEPC.176(58) and again in 2021 by resolution MEPC.328(76).

The MEPC/ES.2 extraordinary session convened to adopt them adjourned in October 2025 without adopting. MEPC 84 , 27 April to 1 May 2026, did not adopt them, and its summary records that Member States could submit new amendments and adjustments. ISWG-GHG 22 met from 1 to 4 September 2026 without a decision on substance. ISWG-GHG 23 is scheduled for 23 to 27 November 2026, MEPC 85 for 30 November to 3 December 2026, and the resumed ES.2 for 4 December 2026, subject to MEPC 85.

The draft carries hard-coded dates in 2027 and 2028, including the Registry account deadline of 1 October 2027 and the first reporting year of 2028. Under the tacit acceptance procedure of MARPOL Article 16(2)(f)(iii) and (g)(ii), which the draft adoption resolution invokes, deemed acceptance comes after a period the Committee sets at adoption of not less than ten months, and entry into force six months later. On this site’s arithmetic, adoption on 4 December 2026 gives entry into force no earlier than about April 2028, after the account deadline and after the 2028 reporting year had begun.

Proposals that would change the direct compliance target

An IMO officer’s presentation at the ISCC conference of 10 June 2026 lists four amendment proposals circulated by IMO circular letter. Three bear directly on the direct compliance target and surplus units:

• Circular Letter No.5214 (Brazil): “less steep reduction trajectories for the base target and the direct compliance target towards 2035 (more SUs)”;
• Circular Letter No.5215 (Tuvalu): no surplus units, with all emissions subject to remedial unit payment at a minimum of USD 300 per tonne CO2eq;
• Circular Letter No.5213 (Liberia): “no RUs, no Fund, GFI trajectory determined as the market share weighted average emissions intensity of all commercially viable fuels”.

MEPC 84/7/38 (Argentina, Liberia and Panama, 20 February 2026) proposes a single GFI target, surplus units for ships that “outperform the applicable GFI Target”, transfer “exclusively through the IMO GFI Registry”, banking, and borrowing from one subsequent calendar year for up to two consecutive years. The European Parliament briefing PE 780.423 (April 2026) reports that MEPC 84/7/28 and 84/7/36 (Fiji and others) would raise the Tier 1 price from USD 100 to USD 300 per tonne. All of these are proposals; the Table 4 factors above are the approved text.

Direct compliance target and the 2023 IMO GHG Strategy

Draft regulation 31 ties Chapter 5 to “the reduction targets set out in the 2023 IMO Strategy”, resolution MEPC.377(80) . The Strategy’s checkpoints in paragraph 3.4 are cuts in total annual GHG emissions from international shipping against 2008: at least 20 percent, striving for 30 percent, by 2030, and at least 70 percent, striving for 80 percent, by 2040.

The direct compliance factor of 21.0 in 2030 is a cut in intensity per megajoule, a different metric. Total emissions depend on energy use as well as intensity, so a 21 percent intensity cut does not produce a 21 percent emissions cut if activity grows. MEPC.377(80) contains no 2035 figure to set against the 43.0 direct compliance factor for 2035.

Direct compliance target, FuelEU Maritime and the EU ETS

For ships trading to the European Economic Area, the direct compliance target would run beside FuelEU Maritime , Regulation (EU) 2023/1805, which applies from 1 January 2025. Article 4(2) cuts a reference value of 91.16 gCO2eq/MJ by 2 percent from 2025, 6 percent from 2030, 14.5 percent from 2035, 31 percent from 2040, 62 percent from 2045 and 80 percent from 2050.

FuelEU moves performance between ships through a pool validated by the companies, and IMO would move it unit by unit through a registry, against the dearer deficit only. The intensity formulas also differ (FuelEU formula ), and FuelEU applies a multiplier of 1 + (n - 1)/10 to a penalty in consecutive years of deficit under Article 23(2) (FuelEU penalties ). The FuelEU compliance balance and pooling article covers Articles 20 and 21 in full.

The EU ETS for shipping prices tank-to-wake emissions in allowances, a third basis. The EU ETS and FuelEU double compliance article covers the overlap between the two EU instruments.

Surplus units, charter parties and cost recovery

The draft credits surplus units to the ship account and says nothing about charter parties. Regulation 36.7 states that a ship which has balanced its deficit “shall be considered as being compliant with its target annual GFI”, without prejudice to recovering costs relating to the operational responsibility of the ship, defined as “determining the fuel used or the cargo carried or the route or the speed”.

Under a time charter party the charterer usually buys fuel and sets speed and route, so the fuel choice that produces direct compliance is often the charterer’s while the units sit in the ship’s account. Who holds the commercial value of those units is left to contract. FuelEU Article 23(8) leaves the company liable but allows contractual reimbursement by a commercial operator that buys the fuel or sets cargo, route and speed. Article 3gc of Directive 2003/87/EC gives the ETS shipping company a statutory entitlement to reimbursement (EU ETS cost pass-through ). Chapter 5 has only the cost-recovery saving in regulation 36.7, and it addresses costs, not units. The cost recovery provision and the BIMCO FuelEU Maritime clause are covered separately.

Common errors about the direct compliance target

• Calling it the Tier 2 threshold. Missing it creates a Tier 1 deficit; Tier 2 starts above the base target.
• Using surplus units against a Tier 1 deficit. Regulation 36.5 allows Tier 1 remedial units only.
• Giving surplus units a price or a market. The draft sets prices for remedial units only; a transfer is a Registry entry.
• Describing fleet pooling. Chapter 5 has no pool; each ship has its own balance.
• Giving surplus units five years of life. Validity is two calendar years following the year of issuance (36.15).
• Starting the table in 2027 or interpolating. Table 4 starts in 2028 and prints every year to 2035.
• Quoting a 2040 or 2050 direct compliance target. The draft fixes only the 2040 base target factor.
• Treating the Net-Zero Fund as the unit ledger. The IMO GFI Registry credits and cancels surplus units (38.4).
• Adding a ship-type correction. Every ship in scope faces the same value.
• Stating that the framework was adopted. It was approved at MEPC 83 and has not been adopted.

A ship 20 percent below the 2008 reference, at 74.64 gCO2eq/MJ, is in direct compliance in 2028 and 2029 and falls into the Tier 1 band in 2030, when the target drops to 73.707.

Limitations

• Draft text. Every regulation number, factor and price here comes from MEPC/ES.2/2 as approved at MEPC 83. The Brazil proposal would flatten both trajectories, and the Tuvalu and MEPC 84/7/38 proposals would remove or restructure surplus units, so the figures should be re-read against any adoption resolution.
• Guidelines pending. The surplus unit guidelines in regulation 36.11 (footnote 89) and the GFI Calculation Guidelines are still to be developed. The treatment of wind and solar energy in Energy_total is not settled, and MEPC.391(81) sets the onboard carbon capture term to zero pending guidance.
• Derived intensities. The 95.484 gCO2eq/MJ VLSFO value and the energy-share tables are this site’s arithmetic on MEPC.391(81) components; the GESAMP-LCA work reporting to MEPC 85 may revise default factors.
• Prices. USD 100 and USD 380 apply to reporting periods 2028 to 2030 only (regulations 36.8 and 36.9). Surplus units have no price in the draft, so the value column for a ship below the target has no figure.
• Open points in the text. The draft does not state the year of issuance of a surplus unit, whether a banked unit can later be transferred to another ship, or how a ZNZ reward interacts with surplus units.
• FuelEU text. The FuelEU figures are from the Official Journal text of Regulation (EU) 2023/1805 as published on 22 September 2023.

Related Articles

• Base target annual GFI
• GFI reduction trajectory
• IMO global fuel standard: how attained GFI is calculated
• Surplus units under the IMO Net-Zero Framework
• Remedial units under the IMO Net-Zero Framework
• GFI compliance balance
• IMO GFI Registry
• GHG fuel intensity under the IMO Net-Zero Framework
• IMO levy and economic measure
• ZNZ rewards
• Green shipping corridors
• FuelEU compliance balance and pooling