The major objective of the following FAQ’s is to assist on the implementation of the IMO DCS (Data Collection System) regulation.

What does IMO-DCS represents?
It’s an established “Data Collection System” for fuel oil consumption as part of a roadmap for developing a comprehensive IMO strategy for the reduction of GHG emissions from ships.
Why was it created?
On May 2015 IMO MEPC (Marine Environment Protection Committee) 68 agreed on a three-step approach to enhance the energy efficiency of ships. It comprises a data collection step, followed by data analysis and ending in decision-making on what further measures can be done, if any, are required.
What regulations were developed for this frame?
When is it going to take place?
Amendments to MARPOL Annex VI, Regulation 22A on fuel oil data collection of ships came into force on 1st March 2018. Starting from 1st January 2019, ships shall collect data according to procedures, systems, and responsibilities to be outlined in a Data Collection plan (DCP) included in the Ship Energy Efficiency Management Plan (SEEMP).
What is the focus of this regulation?
Ships of 5,000 GT and above engaged in international shipping will be required, from 2020 onwards, to submit to their Flag Administration or a Recognised Organisation (RO) nominated by the Flag (usually the ship’s Classification Society) annual reports on fuel oil consumption data, hours underway and distance travelled for the previous calendar year (e.g. 2019 data), using a methodology and procedures to be described in a Data Collection Plan and included in the Ship Energy Efficiency Management Plan (SEEMP Part II).The DCS shall be prepared in accordance with the 2016 Guidelines for the Development of a Ship Energy Efficiency Management Plan adopted by Resolution MEPC.282 (70) and shall be reviewed by the Flag Administration or an organization duly authorized by it. A Confirmation of Compliance is issued by the Flag Administration confirming the successful review of the DCS.

What voyages are included?
All international voyages.
Would it be any exemption on a per-voyage monitoring?
There is an exemption when a ship diverts from its scheduled passage to engage in search and rescue operations.
What is the most important information ship owners must report to the IMO Ship Fuel Oil Consumption Database?

  • The identity of the ship;
  • IMO Number;
  • Period of the calendar year for which the data is submitted: (Start date, End date);
  • Technical characteristics of the ship: Ship type, Gross Tonnage, Net Tonnage, Deadweight tonnage, Power output of main and auxiliary reciprocating internal combustion engines over 130 kW, EEDI, Ice class (for ships operating in polar waters);
  • Fuel Oil consumption by fuel type (tones) and methods used for collecting data;
  • Distance traveled;
  • Hours underway.

What about CO2 emissions to the atmosphere?
Unlike MRV Regulations, Direct CO2 Emissions measurements are not required on IMO-DCS.

Is it applied to all types of ships?
IMO-DCS is applied to all ships of 5,000 GT and above engaged on international voyages.  Nevertheless, there are some exemptions such as ships engaged on domestic voyages, or ships not propelled by mechanical means and Platforms, including FPSOs, FSUs, and drilling rigs.
Is the provided information confidential?
Yes, data provided by companies is anonymous such that identification of a specific ship will not be possible.

What information is reported by IMO Secretary-General to MEPC?

• Aggregated Fuel Consumed by ships with ≥ 5000 GT
• Distance Travelled;
• Hours underway;
• No. ships > 5000GT reported
• No. ships registered with the Party.

What should owners and operators do?
Owners and operators should start considering the means for collecting the fuel oil consumption data that is most appropriate for each ship and update the SEEMPs of their ships to reflect this process.

What are the most relevant deadlines to take in consideration?

  • 31st December 2018: submission of the amended SEEMP Part II for approval, in line with the 2016 Guidelines for the development of a Ship Energy Efficiency Management Plan adopted by Resolution MEPC.282(70).
  • 1st January 2019: start of the first reporting period.
  • 31st December 2019: end of the first reporting period.
  • 31st March 2020: submission of the report on fuel oil consumption data related to the first reporting period.
  • 31st May 2020: Statement of Compliance related to fuel oil consumption to be kept on board.
  • June 2020 onwards: annual submission of the aggregated and verified data to the IMO in accordance with the provisions of Regulation 22A of MARPOL Annex VI.

What should the SEEMP comprise?

Should Include a description of the methodology that will be used to collect the data required by regulation 22A and the processes that will be used to report the data to the ship’s Administration. It consists of 2 parts:

  • SEEMP Part I: is a tool to assist a company in managing the ongoing environmental performance of its vessels. Companies must develop procedures for implementing the plan in a manner which limits any on-board administrative burden to the minimum.
  • SEEMP Part II: is a guide for developing a ship-specific method to collect, aggregate and report ship data with regard to annual fuel oil consumption, distance traveled and hours underway.

What parameters should be described in SEEMP Part I?

Should be described the following ship and Plan information:

  • Name of the ship;
  • Gross Tonnage;
  • Ship type;
  • Capacity;
  • Data of development;
  • Developed by;
  • Implementation period (from/until);
  • Implemented by:
  • Planned date of next evaluation.


  • Energy Efficiency measures, how they are implemented and the person responsible;
  • Description of Monitoring Tools;
  • Measurable Goals;
  • Procedures of evaluation.

What parameters should be described in SEEMP Part II?

Ship Particulars:

  • Name of the ship;
  • IMO Number;
  • Company;
  • Flag;
  • Ship Type;
  • Gross Tonnage;
  • NT;
  • Deadweight;
  • EEDI;
  • Ice class.


  • Record of revision of Fuel Oil Consumption Data Collection Plan;
  • Ship Engines and other fuel oil consumers and fuel oil types used;
  • Emission Factor;
  • Method to measure fuel oil consumption;
  • Method to measure distance traveled;
  • Method to measure hours underway;
  • Processes used to report the data to the Administration;
  • Data Quality.

What consumers should be described in SEEMP Part II?

Should be included main engines, auxiliary engines, gas turbines, boilers or inert gas generators for each type of fuel consumed on board.

How are the communications established between companies and Flag Administrations or an organization duly authorized by them?

They are made electronically using a standardized form (appendix 3- MEPC 282(70)) still to be developed by the Organization.

What are the responsibilities of each figure involved in the process?


  • Must develop and assess a SEEMP for each ship, which must comply with Regulation.
  • Must collect data during the reporting period and submit to the Administration or any organization duly authorized the aggregated values within three months after the end of each calendar year (via electronic communication).
  • Must keep on board the Statement of Compliance proving the compliance with IMO-DCS

Administration or any organization duly authorized

  • Assess the ship’s SEEMP according to regulations;
  • Should verify and assure the reliability of the collected data;
  • Issue a Statement of Compliance;
  • Transfer within one month after issuing the Statement of Compliance of the ship to the IMO Ship Fuel Oil Consumption Database the reported data.


  • The IMO Ship Fuel Oil Consumption Database shall be undertaken and managed by the Secretary-General of the Organization. The Secretary-General of the Organization shall produce an annual report to the MEPC summarizing the data collected and maintain an anonymized database.
  • Annually produce a list of ships falling under the scope of the regulation by cross-referencing with the data from the Ship Particulars module of GISIS.
  • Send list of ships to the administration and the list produced with the reported data
  • Report the status of missing data to the Committee on an annual basis
  • Request non-reporting administrations to submit the data at all ships falling under the scope.

What is intended by the calendar year, distance traveled and hours underway?

By the calendar year, it is understood the period from 1st January to 31st December of a year.
Hours underway is the duration while the ship is underway under its own propulsion.
Distance traveled is a distance traveled over the ground in nautical miles (should be recorded in log-book). Should include distance traveled while the ship is underway under its own propulsion. Other method accepted by the Administration may be applied and described in the Data Collection Plan.

Does the Statement of Compliance have a specific form?

The Statement of Compliance shall be drawn up in a form corresponding to the model given in appendix X of MEPC 278(70) and shall be at least in English, French or Spanish.

What is the Validation of the Statement of Compliance?

The Statement of Compliance must be kept on board and its valid for the calendar year in which it is issued and for the first 5 months of the following calendar year.

What documentation should companies submit along with Annual Data Report?

  • Copy of the ship’s Data Collection Plan;
  • Summaries of BDNs with detail;
  • Summaries of disaggregated data on fuel oil consumption, distance traveled and hours underway;
  • Information to demonstrate the ship followed the Data Collection Plan set out in its SEEMP, including Data gaps, how they are filled and resolved;
  • Copies of documents containing the amount of fuel oil consumption, distance traveled and hours underway for the ship’s voyages during the reporting period (ex: official logbook, oil record book, BDNs, arrival/noon/departure reports).

What are the possible methodologies for collecting data on fuel oil consumption?

a) Using BDNs: Method determines the annual amount of fuel oil used. The BDN fuel oil quantities would be used to determine the annual total mass of fuel oil consumption to determine the difference between the amount of remaining tank oil before and after the period, the tank reading should be carried out at the beginning and the end of the period. Readings can be made by automated systems, soundings and dip tapes. The method should be specified in the Data Collection Plan. The amount of any fuel oil offloaded should be subtracted from the fuel oil consumption of that reporting period. This amount should be based on the records of the ship’s oil record book.

b) Using Flowmeters: determines the total annual amount of fuel oil consumption by measuring fuel oil flows on board by using flow meters. In case of the breakdown of flow meters, manual tank readings or other alternative methods will be conducted instead. Data of annual consumption of fuel oil = ∑data of daily consumption of fuel oil, in the Data Collection Plan must be:

  • Identified each flow meter;
  • Link between each specific consumer and the flowmeter;
  • Calibration of the flow meter, maintenance, records.

c) Using Bunker fuel oil tank monitoring: The amount of daily fuel oil consumption data measured by tank readings (automated systems, soundings, dip tapes). Readings will occur daily when the ship is at sea and each time the ship is bunkering or de-bunkering. Summary of monitoring data and any corrections (temperature, density) should be available onboard.

What if there is a transfer of ship from one Administration to another or a change of one company to another?

In case there is a transfer of a ship from one Administration to another, the ship shall report to the losing Administration the aggregated data for the period of the calendar year corresponding to that administration. In case of a change from one company to another, the ship shall, on the day of completion of the change, report to its administration the aggregated data for the portion of the calendar year corresponding to the company.

How can TecnoVeritas assist you?

TecnoVeritas is already accredited by Institute Portuguese of Accreditation (IPAC) under the ISO 14065 and can provide services associated with Regulation (EU) 2015/757 on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport known as the EU MRV Regulation.

Since both schemes are anticipated to run in parallel, our Society can act as a single Verification Body for both the IMO DCS and the EU MRV Regulation schemes.

Under the IMO DCS, our Society can provide the following services:

Contact us for further information.