Enhanced IMO DCS Reporting & SEEMP Updates

In October 2016, the International Maritime Organization’s (IMO) Marine Environmental Protection Committee, at its 70th session (MEPC 70) adopted, by resolution MEPC.278(70), the IMO ship fuel oil consumption system (IMO DCS), which consists of requirements for ships to record and report their fuel oil consumption with a view to inform further IMO measures to reduce GHG emissions from ships  .

Starting from 1 January 2019, ships of 5,000 GT and above (which produce approximately 85% of the total CO2 emissions from international shipping  ) are required to collect and report annually the:

  • Fuel oil consumption by type
  • Distance travelled
  • Hours underway
  • Other specified operational data

By March 31st of each  following year, the above data must be submitted to the ship’s flag State or the DCS Verifier. After the DCS Verifier received and verified the data it will issue a Statement of Compliance to the ship by the 31st of May the same year. The data is then forwarded to the IMO Ship Fuel Oil Consumption Database within a month or by the 30th of June; completing the annual reporting cycle under the IMO Data Collection System.

Since 2023, the data collected under the IMO Data Collection System has been used to calculate the Carbon Intensity Indicator (CII), which assesses a ship’s operational efficiency. To maintain confidentiality, the IMO publishes  anonymized annual reports . All data is managed through the Global Integrated Shipping Information System (GISIS), which is accessible to member States . The system’s implementation is supported by several MEPC resolutions, including MEPC.395(82) for SEEMP development, MEPC.389(91) for verification procedures, and MEPC.349(78) for database management, to help ensure consistency and transparency across the reporting process.

In March 2024, MEPC 81 adopted amendments to Appendix IX of MARPOL Annex VI (resolution MEPC.385(81)), introducing increased data granularity requirements, including the reporting of fuel consumption by fuel oil type per consumer type and data on transport work. These amendments were initially intended to enter into force on 1 August 2025, but parties could submit an their applications early beginning 1 January 2025. Noting the fact that the amendments would enter into force halfway through a calendar year  , which would result in two distinct levels of granularity for the data gathered in that calendar year  , the IMO approved Circular MEPC.1/Circ.913, providing the following guidance on the timeline for the application of those amendments:

  • For ships flying the flag of an Administration that implements the amendments early (1 January 2025):
    • Revise   the SEEMP in accordance with the 2024 SEEMP Guidelines (Resolution MEPC.395(82)) prior to 1 January 2025 and collect data with increased granularity throughout the entire year of 2025 and beyond
  • For ships with flags that implement the amendments on the entry into force date (1 August 2025):
    • A revised SEEMP Part II, in accordance with the 2024 SEEMP Guidelines, as amended, and the new Confirmation of Compliance, must be onboard by 1 January 2026.
    • Data must be collected with the existing level of granularity throughout 2025. From 1 January 2026, data must be collected with the enhanced level of granularity.
  • For ships delivered on or after 1 August 2025:
    • A SEEMP Part II in accordance with the 2024 SEEMP Guidelines, as amended, and the associated Confirmation of Compliance must be onboard from the date of delivery.
    • Data must be collected with the enhanced level of granularity from the date of delivery.

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.

Ship type

Transport work metric

Bulk carriers

Cargo mass (metric tons) x distance

Tankers

Cargo mass (metric tons) x distance

Combination carriers

Cargo mass (metric tons) x distance

Gas carriers

Cargo mass (metric tons) x distance

LNG carriers

Cargo mass (metric tons) x distance

General cargo ships

Cargo mass (metric tons) x distance

Ro-Ro cargo ships (vehicle carriers) and Ro-Ro cargo ships

Cargo mass (metric tons) x distance

Containerships

Number of TEUs, Cargo mass + Container Mass (metric tons) x distance

Cruise passenger ships

Number of Passengers x distance

Ro-Ro passenger ships

Number of Passengers x distance and Cargo mass (metric tons) x distance


5. Laden distance (on a voluntary basis).

Laden distance, is 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[JK1] [SP2] ” and “not under way” while SEEMP Part III must be revised to reflect the updated Carbon Intensity Indicator (CII) reduction targets for 2026–2028, with completion of verification and issuance of a Confirmation of Compliance by 31 December 2025.

            1. Updated Definitions for the terms “underway” and “not underway”.

            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”, that relate to three key reporting parameters: fuel oil consumption, distance travelled, and hours under way.

 

            1. Underway

            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 underway

            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.   

            Consequently, the definitions of “distance travelled” and “hours underway” have been updated based on the term “under way,” replacing the previous term “under its own propulsion."

            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.

Year

Reduction factors relative to 2019 

2027

13.625%

2028

16.25%

2029

18.875%

2030

21.5%

 

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.

Based on this and following the adoption of the CII reduction factors for the years 2027 to 2030, a revised SEEMP Part III should be developed and submitted for review by 31 August 2025 allowing time for ABS [JK1] [SP2] to complete the review process. The revised SEEMP Part III and the associated Confirmation of Compliance must be on board by 1 January 2026.

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 years 2025–2027.
  • 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).

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 distance between FAOP and EOSP included only for calculating the attained CII?

 

No. All ships subject to Regulation 27 are required to measure and report distance travelled from FAOP to EOSP. This replaces the previous distance travelled “while the ship is underway under its own propulsion” term.

 

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 reported?

 

The reporting will depend on whether the period after the anchorage until berth is a “not under way” period or it includes an “under way” period. If the ship did not reach transit speed after the anchorage, the distance travelled from anchorage to berth is not to be included in the aggregated data of distance travelled for the reporting period. If the ship reached transit speed after the anchorage, the distance travelled between FAOP and EOSP after the anchorage is to be included in the aggregated data of distance travelled for the reporting period.

 

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.