Billing Accuracy Index · Q3 2026 (July 1 to September 30)
State of ocean carrier D&D billing accuracy.
28,133 invoices from nine ocean carriers and three marine terminals, audited against 46 CFR Part 541.
Headline findings
Most invoices still miss something.
64.2%
of invoices in the index lacked at least one § 541.6 element
Completeness remains the biggest gap.
The container availability date and the certification that the billing party did not contribute to the charge were the most frequently missing elements.
35.8%
Fully complete invoices
Weighted by invoice volume across all twelve billing parties.
66.1%
Disputes credited
Full or partial credit on ATAHSKIA relief requests.
Terminals lag less on timing
Marine terminals issued faster than carriers but resisted disputes more.
Late issuance is rare but decisive
Day-31 invoices are a small share and an easy win.
The full index
| Billing party | Most-missed element | |||||
|---|---|---|---|---|---|---|
| Carrier A 4,812 inv. | 52.1% | 2.1% | 9 d | 58.4% | 17 d | Container availability date |
| Carrier B 3,967 inv. | 45.3% | 3.4% | 12 d | 61.9% | 21 d | Certification of no contributing performance |
| Terminal 1 1,688 inv. | 43% | 1.8% | 6 d | 49.2% | 14 d | Specific dates charged |
| Carrier C 3,410 inv. | 38.6% | 6.8% | 16 d | 66.2% | 24 d | Container availability date |
| Carrier D 2,896 inv. | 34.2% | 4.9% | 14 d | 70.8% | 26 d | Dispute URL or QR code |
| Terminal 2 1,240 inv. | 33.5% | 3.1% | 8 d | 55.6% | 19 d | Dispute timeframes |
| Carrier E 2,541 inv. | 29% | 9.7% | 19 d | 73.5% | 28 d | Start date of free time |
| Carrier F 2,207 inv. | 24.8% | 11.2% | 22 d | 76.1% | 29 d | Applicable tariff rule |
| Terminal 3 905 inv. | 22.8% | 5.5% | 11 d | 63.4% | 23 d | Basis for billed-party liability |
| Carrier G 1,875 inv. | 21.5% | 8.3% | 18 d | 69.7% | 27 d | Basis for billed-party liability |
| Carrier H 1,460 inv. | 17.9% | 14.6% | 25 d | 79.3% | 30 d | Container availability date |
| Carrier I 1,132 inv. | 14.2% | 12.9% | 23 d | 81% | 30 d | Both certifications |
Methodology
How the index is built.
Invoices are audited on receipt against the twenty § 541.6 elements and the § 541.7 issuance rule. Relief requests are tracked to closure. Billing parties enter the index after 500 audited invoices in the period.
Codes are blinded and stable across quarters. Customers see named scorecards for their own book inside the platform. The index is published quarterly.
Don't let your 30-day dispute window expire.
Send your recent D&D invoices for a free audit. We report what is recoverable within 48 hours.