Enhanced IMO DCS Reporting & SEEMP Updates

New Requirements for Enhanced Granularity Reporting

In addition to the existing DCS parameters, shipowners  and operators are now required to document, report and submit for verification the following:

 1. Fuel oil consumption per consumer type.

A new requirement to split fuel consumption per consumer type was introduced. Consumer types include main and auxiliary engines, fired boilers and others.

To comply, shipowners must implement one of the following methods for measuring fuel consumption per consumer type, and update accordingly the SEEMP Part II:

1.  Method using flow meters

The flow meters should be located so as to measure all fuel oil consumption for each consumer type. Each flow meter and its link to a specific consumer type must be clearly identified in the SEEMP Part II. Any individual consumer not monitored by a flow meter should also be explicitly listed, and an alternative fuel oil consumption measurement method should be included.             

2.  Method using bunker fuel oil tank monitoring on board

Tank readings, which are carried out by appropriate methods such as automated systems, soundings, and dip tapes, should normally occur daily when the ship is at sea and each time the ship is bunkering or de-bunkering.

3.  Alternative methods

If there is a consumer type for which neither of the above methods can be applied, one of the following methods may be used:

a. Method using subtraction

If fuel consumption for only one of the consumer types is not available, the fuel consumption of this consumer type may be derived by subtracting the consumption of other consumer types from the total annual fuel oil consumption, which is measured according to the established methodologies in the current SEEMP Part II.

b. Method using estimated fuel oil consumption

If none of the above methods can be applied, an alternative method, such as one based on manufacturer data or historical fuel consumption records for a specified period, may be used subject to the satisfaction of the flag Administration or a recognized organization (RO). 

Note: Each consumer type may use a different method to measure fuel oil consumption. 

2. Fuel oil consumption when the ship is not under way, by fuel oil type per consumer type.

Fuel oil consumption must be reported separately when the ship is not under way, by fuel oil type per consumer type. The methodology for measuring this consumption should be included in SEEMP Part II.

3. Onshore power supplied.

The amount of onshore power supplied should be recorded based on a relevant document from the power supplier, which must be securely stored. The total amount of onshore power supplied should be calculated as the sum of the amount of onshore power supplied in kWh. A relevant methodology should be developed and included in SEEMP Part II.

4. Transport work for ships.

Ships subject to Regulation 28 of MARPOL Annex VI (Carbon Intensity Indicator (CII)) must report the total transport work. This is the annual sum of each voyage's transport work, which is the distance sailed multiplied by the cargo carried during a voyage. Subsequently, for each voyage, operators must also report the cargo carried, specific to the ship type, as outlined below.  A corresponding methodology for these calculations should be developed and included in SEEMP Part II.

5. Laden distance (on a voluntary basis).

Laden distance, calculated as the distance sailed when the ship is loaded, may be reported voluntarily.

6. Installation of any innovative technology.

Ships subject to Regulation 28 of MARPOL Annex VI (Carbon Intensity Indicator (CII)) should report the installation of innovative technology, if applicable. As outlined in MEPC.1/Circ.896, innovative technologies are categorized as follows:

1. Category A: such as low friction coating, rudder resistance, propeller design etc.

2. Category B-1: such as hull air lubrication systems.

3. Category B-2: such as any type of wind assistance (sails, Flettner-Rotors, kites).

4. Category C-1: such as waste heat recovery systems that convert exhaust heat into electric power.

5. Category C-2: such as photovoltaic cells.

SEEMP Parts II and III amendments

Ships must comply with amended SEEMP Parts II and III requirements: SEEMP Part II must include the enhanced granularity information explained above and the revised definitions for the terms “underway” and “not under way”.

1. Updated Definitions for the terms “under way” and “not under way”.

To improve clarity and consistency in reporting, MEPC 83 adopted amendments to the 2024 SEEMP Guidelines (Resolution MEPC.401(83)), which provide revised definitions for the terms “underway” and “not underway”, replacing the previous term “under its own propulsion.

1. Under way

The period between full ahead on passage (FAOP), where transit to the next port starts, and end of sea passage (EOSP), where the ship decelerates from transit speed.

FAOP is commonly referred to as Begin of Sea Passage (BOSP), as defined in the IMO Compendium on facilitation and electronic business (IMO Compendium) under IMO 0597 (Code EV10).

2. Not under way

The period between the end of sea passage (EOSP) and full ahead on passage (FAOP) of the following sea passage. Due to frequent maneuvering, acceleration, and deceleration, the period between Begin Canal Passage (EV08) and End Canal Passage (EV09) is considered not under way.

These new definitions relate to the following reporting parameters listed in Appendix IX of MARPOL Annex VI:

• Fuel oil consumption while the ship is not under way, by fuel oil type per consumer type

• Hours under way

Total distance travelled is unaffected by the new definition of "under way" introduced by MEPC.401(83).

2.  CII reduction targets for 2026–2028

To support the IMO’s objective of achieving at least a 40% reduction in CO₂ emissions per transport work by 2030 compared to 2008, the reduction (Z) factors for the required annual operational CII for the years 2027 to 2030 were adopted by resolution MEPC.400(83), introducing an annual reduction increment of 2.625 percent.

In accordance with Regulation 28 of MARPOL Annex VI, ships of 5,000 GT and above (excluding certain exempted types) are required to determine their Required Annual CIIs for the next three years, as benchmarks against the ship’s actual performance (Attained CII). The SEEMP Part III must include:

• The Required Annual Operational CIIs for the next three years.
• An implementation plan detailing how these CIIs will be achieved.
• A self-evaluation and improvement procedure.

Actions for Compliance

Ships delivered on or after 1 August 2025:

• Develop the SEEMP Part II, in accordance with the 2024 SEEMP Guidelines (IMO Resolution MEPC.395(82), as amended by Resolution MEPC.401(83)).
• Develop the SEEMP Part III, to include the Required Annual Operational CIIs for the next years (year – year+2).
• Submit SEEMP Part II and III for review and issuance of the Confirmations of Compliance (CoC) before the date of delivery.
• Monitor data at the enhanced level of granularity starting from the date of delivery.
• Submit for verification the data collected with enhanced granularity no later than 31 March 2026 and each calendar year, for the issuance of the Statement of Compliance (SoC).

Existing Ships:

• For ships flying the flag of an Administration that implements the amendments early (1 January 2025):
  • SEEMP Part II amendments:
    • Revision in accordance with the 2024 SEEMP Guidelines (IMO Resolution MEPC.395(82), as amended by Resolution MEPC.401(83)).
    • Submit it for review by 31 August 2024 and issuance of the Confirmation of Compliance by 31 December 2024.

• For ships flying the flag of an Administration that implements the amendments on the entry into force date (1 August 2025):
  • SEEMP Part II amendments:
    • Revision in accordance with the 2024 SEEMP Guidelines (IMO Resolution MEPC.395(82), as amended by Resolution MEPC.401(83)).
    • Submit it for review by 31 August 2025 and issuance of the Confirmation of Compliance by 31 December 2025 at the latest.
  • SEEMP Part III amendments:
    • Revision to include the Required Annual Operational CIIs for years 2026–2028. In accordance with the amendments to the 2021 CII reduction factors guidelines G3, adopted by resolution MEPC.400(83).
    • Submit it for review by 31 August 2025 and issuance of the Confirmation of Compliance by 31 December 2025 the latest.
  • Implement any necessary changes to the equipment, reporting system to enable monitoring at the enhanced level of granularity.
  • Start collecting data at the enhanced level of granularity from 1 January 2026.
  • Submit the collected data for verification no later than 31 March 2027 and each calendar year, for the issuance of the Statement of Compliance (SoC).

SEEMP Company Audit

Regulation 26.3.3 of MARPOL Annex VI requires that the Ship Energy Efficiency Management Plan (SEEMP Part III) be subject to company audits by the Flag Administration or Recognized Organization (RO) in accordance with the Guidelines for the Verification and Company Audits by the Administration of Part III of the Ship Energy Efficiency Management Plan (SEEMP) (Resolution MEPC.347(78)).

Audit Requirements

SEEMP Company audits: Though company audits are mandatory to conduct, the periodicity of company audit with mandatory nature is not specified. Companies may be audited every three years, unless the flag administration specifies a different frequency.

Additional company audit: In the case of a ship rated as D for three consecutive years or a ship rated as E, in accordance with Resolution MEPC.347(78), additional company audit may be conducted to ensure that the plan of corrective actions has been properly established.

SEEMP shipboard audits: Would typically not be required, unless specifically requested by the ship’s Flag Administration. ABS may recommend/require shipboard audits if serious issues are found during Company audits.

In addition, any company and shipboard audits, if undertaken, must be completed within six months of the Statement of Compliance issuance and no later than 30 November, unless the flag administration specifies a different frequency

SEEMP audits and ISM audits may be carried out during the same visit, as a combined audit. However, when these two audits are carried out by two different ROs, at different dates, Company should be able to make available reports of previous audits.

Upon successful completion of the audit, a report confirming the performance of the company SEEMP audit will be issued.

Scope of Audits

The focus of the SEEMP audits is to assess the company’s policies and approach for implementation, monitoring, self-assessment, improvement, and corrective actions for its fleet. SEEMP implementation for individual vessels should be assessed on a sampling basis. Audits may include the following elements:

1. Compliance with the SEEMP for which the Confirmation of Compliance has been previously issued. Remedial actions in cases of non-compliance.

2. Operation of each of the sampled ships in accordance with the SEEMP Part III.  Evidence that each measure in accordance with SEEMP Part III plan has been implemented.

3. Progress made on the actions to be taken in accordance with the three-year implementation plan and, if applicable, the corrective actions plan.

4. Completion of self-assessment and improvement actions.

5. Assignment of responsibilities for implementation and monitoring of measures in accordance with the SEEMP.

Non-compliance, corrective actions and follow up

1. The company is responsible for determining and initiating the corrective action needed to correct a non-compliance or to correct the cause of a non-compliance.

2. The follow-up action may include additional company or shipboard audit(s), as appropriate, to verify that corrective actions have been properly implemented.

3. Corrective actions and any subsequent audits should be completed within the time period agreed. For corrective actions, this should not normally exceed three months.

Audit execution and Reporting

The audit shall be carried out in accordance with documented procedures. The audit result and any non-compliance identified at the audit shall be documented and brought to the attention of the Company. The verification audits may be carried out in accordance with guidelines on implementation of the ISM Code by Administrations, referred to in Chapter 15 of the ISM Code.

ABS may perform Company SEEMP audit on behalf of the flag Administration as requested by the client regardless of who issued Company DOC. A report confirming that the company SEEMP audit has been carried out will be issued.  Please contact your local ABS office for details or any questions.

1.      What are the deadlines for updating SEEMP Part II and III?

Existing ships shall have onboard the new Confirmations of Compliance for SEEMP Part II and III by 1 January 2026, and new ships delivered after 1 August 2025 by the date of delivery. A revised SEEMP Part II and III should be developed and submitted for review by 31 August 2025 allowing time for ABS to complete the review process.

2.      The ship was delivered in 2025 before August. Should it collect data with enhanced level of granularity from 1 August 2025?

No, if the ship was delivered before 1 August 2025 the requirement for collecting data with enhanced level of granularity applies from 1 January 2026 unless  the ship is flying the flag of an Administration that implements the amendments early.

3.      Should ships subject only to Regulation 27 requirements (DCS) also report cargo carried?

No, the requirement to report cargo carried and subsequently the total transport work is applicable only for ships subject to Regulation 28 on the reporting of annual operational Carbon Intensity Indicator (CII).

4.      Is the newly included actual transport work used for the CII Calculation?

No, the supply‑based transport work (based on DWT or GT, as applicable) continues to be used for the calculation of the CII. The newly included actual transport work is not used for the attained CII calculation.

This remains subject to review pending completion of Phase 2 of the CII review.

5.      If the SEEMP Part III currently in place has a Corrective Action Plan (CAP) including the required CII for the next years, does it need to be revised?

If the current SEEMP Part III already includes the required CII for 2026, its revision may be carried out in 2026.

6.      Is the incinerator considered a fuel consumer, for which the fuel consumption shall be reported?

Yes, incinerators are also to be included as fuel consumers and a method to measure their fuel consumption by fuel oil type shall be developed and implemented.

7.      In the event of anchorage before berth how will the distance travelled between anchorage and berth be included in hours under way?

The reporting depends on whether the interval after the anchorage until berth qualifies as “not under way” or includes an “under way” segment.

• If the ship does not reach transit speed after the anchorage, the time from anchorage to berth is not included in the aggregated data for hours under way.
• If the ship does reach transit speed after the anchorage, the time between FAOP and EOSP after the anchorage is included in the aggregated data for hours under way

8.    Will the new definition of "under way" reduce the total distance travelled and negatively impact the attained CII?

No. All distance travelled—not limited to the distance while the ship is "under way"—is included in the IMO DCS reporting of "total distance travelled" and used in the calculation of the attained CII.

8.      How is the transport work of a voyage calculated in the case of STS operations?

For voyages involving STS operations, the transport work shall be calculated as a weighted average.

9.      Can the total consumption by fuel oil type be calculated as the sum of the total fuel consumption by fuel oil type per consumer?

No, the total consumption must continue to be measured using one of the established methods for the total annual fuel oil consumption already described in SEEMP Part II.

10.   Is the quantity of residue/sludge to be subtracted from the fuel oil consumed when the method for measuring fuel consumption per consumer type is flow meters?

If the flow meter is installed after the daily tank, it should not be necessary to correct this fuel oil measurement, as sludge will be removed from the fuel oil prior to the daily tank.

11.   Is boil-off gas (BOG) required to be reported under the DCS?

The data relating to boil-off gas (BOG) consumed on board the ship for propulsion or operation (e.g. BOG used for propulsion, operational needs such as in a boiler, or burnt in a gas combustion unit (GCU) for cargo tank pressure control or other operational purposes) is required to be collected and reported as fuel.

12.   Is the fuel consumption adjusted for methane slip for the calculation of attained CII (e.g. when LNG is consumed as fuel)?

The CII is an IMO metric that evaluates a ship’s carbon intensity based on CO₂ emissions. CII does not account for methane emissions; therefore, no adjustment is needed for methane slip.

13.   What are the SEEMP audit requirements for Liberian flagged vessels, with a D or E rating?

For ships flying the Liberian flag, an additional company audit is required if a vessel receives a D rating for two consecutive years (the audit must be conducted in the third year), instead of the three-year interval.

If a ship receives an E rating for two consecutive years, a shipboard audit is required in the following year.

14.   How are biofuels treated under IMO DCS and CII Framework?

Biofuels that have been certified  as sustainable by an international certification scheme ( provided with a Proof of Sustainability or similar documentation along with the Bunker Delivery Note) and that provide a well-to-wake GHG emissions reduction of at least 65% compared to the well-to-wake emissions of fossil MGO of 94 gCO2e/MJ (i.e. having an E value not exceeding 33 gCO2e/MJ) will be assigned a Cf equal to: Cf = E * LCV

A biofuel not certified as sustainable or that does not fulfil the well-to-wake emission factor criterion, should in its entirety be assigned a Cf equal to the Cf of the equivalent fossil fuel type.

15.   How are the biofuels blends treated under IMO DCS and CII Framework?

According to MEPC.1/Circ.905/Rev.1, from 1 January 2027, the Cf for biofuel blends should be calculated as a weighted average by mass of the respective fuels, instead of energy. For the previous reporting years (before 2027), the Cf have been calculated as weighted average by energy.

The biogenic components within biofuel blends, that are not certified as sustainable or do not fulfil the well-to-wake emission factor criterion, should in their entirety be assigned a Cf equal to the Cf of the equivalent fossil fuel type.

16.   Can ABS perform a Company SEEMP audit even if another class society issued the DOC?

Yes. ABS may perform the Company SEEMP audit on behalf of the flag Administration upon the client’s request, regardless of which class society issued the Company DOC.

17. For ships affected by the Strait of Hormuz crisis, can the voyage adjustment be applied to CII to deduct the fuel consumed while the ship was waiting inside or outside the Strait of Hormuz due to applicable restrictions?

The fuel consumed while a ship was waiting inside or outside the Strait of Hormuz due to safety‑related considerations may be excluded from the calculation of the attained CII, in accordance with Regulation 3.1.1 of MARPOL Annex VI and section 4.1 of CII Guidelines G5, subject to confirmation by the flag Administration.

Regulation 3.1.1 of MARPOL Annex VI provides that “the regulations of this Annex shall not apply to any emission necessary for the purpose of securing the safety of a ship or saving life at sea.”

To date, ABS has received responses from the major flag Administrations listed below.

• Bahamas: Concurs with the interpretation of Regulation 3.1.1 of MARPOL Annex VI. Onboard records shall reflect the details of dates of entry into the imposed 'restricted area', which must be consistent with any formal documented evidence issued by the Port authorities. At such time as vessel moves to loading berth, then the reporting of records for CII shall commence.

• Cayman Islands: Ship owners are still expected to meticulously document the exact hours, fuel consumed, and coordinates during the Hormuz blockage, with a view to presenting the evidence to the vessel’s Flag State administration and RO, where exclusions on the basis of MARPOL VI/3(1)(1) can then be formally agreed against supporting information, to adjust the attained CII via the SEEMP where required. Regarding the CII rating, it is recommended to document the force majeure conditions to then appeal to the Flag State.

• Cyprus: Such cases should be further reviewed by the Administration on a case-by-case basis following the submission of a relevant application by the responsible Classification Society.

• Denmark: Regulation 3.1.1 of MARPOL Annex VI cannot be used as a basis for excluding time and fuel consumption in the CII calculation due to the waiting time until the ship can sail through the Strait of Hormuz.

• Liberia: With respect to vessels required to wait inside or outside the Strait of Hormuz due to safety‑related considerations, the emissions generated during such waiting periods may be excluded from the calculation of the attained CII, taking into consideration Regulation 3.1.1 of MARPOL Annex VI.

• Malta: Agrees that in pursuant to Regulation 3.1.1 of MARPOL Annex VI, the emissions generated during such waiting periods inside or outside the Strait of Hormuz due to safety related considerations may be excluded from the calculation of the attained CII. The emission data should still be collected and reported (specifying the exceptional conditions encountered) as per MEPC.355(78).

• Panama: Yes, the exemption can be applied. Provided the ship's presence in the strait is verified, it can be authorized to reduce its emissions calculations for the days during which it was subject to those circumstances.

• Portugal: Considering the provisions in reference to Regulation 3.1.1 of MARPOL Annex VI, the Administration concurs the emissions generated during such waiting periods may be excluded from the calculation of the attained Carbon Intensity Indicator (CII).

• Republic of the Marshall Islands: MARPOL Annex VI, Regulation 3.1.1 is clearly applicable in such circumstances – however the data should still be collected and reported (specifying the exceptional conditions encountered) as a voyage exclusion per the G5 CII calculation Guidelines (MEPC.355(78) – Appendix 2).

• Singapore: The Maritime and Port Authority of Singapore (MPA)’s current position is that it is open to considering cases where vessels are trapped within the Persian Gulf, subject to supporting evidence and case-by-case evaluation. However, application for vessels which are outside the Persian Gulf, and have chosen to be waiting there will not be considered.