SEEMP II and III: What Ship Operators Must Know Before Audits

With tightening global regulations around carbon emissions and energy efficiency, ship operators must stay prepared for rigorous audits tied to the Ship Energy Efficiency Management Plan (SEEMP)—specifically SEEMP Part II and III. These documents are not just regulatory checkboxes; they are vital compliance tools under IMO’s MARPOL Annex VI.

As we step further into a decarbonised maritime future, understanding the structure, expectations, and audit-readiness requirements of SEEMP II and III is essential for every ship owner and operator. Here’s what you need to know.

What is SEEMP? A Quick Recap

The Ship Energy Efficiency Management Plan (SEEMP) is a mandatory document aimed at improving a vessel’s energy efficiency and reducing emissions. It is divided into three parts:

  • SEEMP Part I: Ship-specific energy efficiency improvement plan (mandatory since 2013).
  • SEEMP Part II: Introduced under the IMO Data Collection System (DCS), mandates collection of fuel oil consumption data (mandatory since 2019).
  • SEEMP Part III: A relatively newer addition, introduced as part of the Carbon Intensity Indicator (CII) regulations (effective from January 2023), requiring ships to set out a plan for continuous improvement in their CII rating.

Key Components of SEEMP Part II

SEEMP II is applicable to ships of 5,000 gross tonnage and above engaged in international voyages. It focuses on the collection, reporting, and verification of fuel consumption data.

Key Requirements:

  • Inclusion of procedures for data collection, quality control, and submission to the IMO DCS.
  • Annual submission of verified fuel oil consumption data to the flag administration or a Recognized Organization (RO).
  • Alignment with EU MRV if applicable.

Key Components of SEEMP Part III

SEEMP III was introduced to support the IMO’s CII rating mechanism, which rates ships from A (best) to E (worst) based on their carbon intensity.

Key Requirements:

  • Description of the ship’s CII calculation and rating plan.
  • Measures and procedures to improve CII performance over a 3-year period.
  • Alignment with IMO’s reduction targets for GHG emissions.
  • Must be approved by the flag administration or RO and onboard by January 1, 2023.

Audit Triggers and Preparation for SEEMP Audits

When Can You Expect an Audit?

  1. Initial Verification – Approval of SEEMP III by the flag state or RO.
  2. Annual Verification – For DCS data submission and CII rating.
  3. Port State Control Inspections – Especially if your ship receives a D or E rating for three consecutive years.

Checklist: What Ship Operators Must Prepare Before Audits

✅ SEEMP Part II and III documents must be ship-specific and updated to reflect actual operational data and planned improvements.
✅ Ensure data consistency between SEEMP, bunker delivery notes, and logbooks.
✅ Align with EU MRV and other regional reporting regimes (like FuelEU Maritime).
✅ Clearly document and implement operational and technical measures listed in SEEMP III (e.g., weather routing, engine tuning, slow steaming).
✅ Maintain records of crew training and awareness sessions on energy efficiency.
✅ Monitor and document CII improvement progress with yearly targets.
✅ Be prepared for corrective action plans if the vessel is rated D or E.

Common Mistakes That Lead to Non-Compliance

  • Submitting generic templates instead of ship-specific plans.
  • Inadequate or inconsistent data logging.
  • Failure to align SEEMP III measures with actual ship operations.
  • Not updating the SEEMP III when operational profiles change.
  • Lack of evidence to show that improvement measures are being implemented onboard.

How Varuna Marine Services B.V. Can Help

At Varuna Marine Services B.V., we help ship operators:

    • Draft and update SEEMP II and III tailored to vessel-specific operations.
    • Prepare for IMO DCS and CII audits through pre-verification checks.
    • Implement digital monitoring solutions for real-time performance data.
    • Align SEEMP III actions with FuelEU Maritime, EU ETS, and IMO DCS frameworks for holistic compliance.

Conclusion

SEEMP II and III are more than compliance documents—they’re blueprints for operational excellence and sustainability. With stricter enforcement from both flag states and port authorities, early preparation and a ship-specific, data-driven approach are key to smooth audits and long-term competitiveness.

Don’t wait for a poor rating to force a reaction—proactive compliance is the smarter route.

For detailed information about our services, please email us at info@varunamarine.eu.

Reference Links