1 August 2025Following our previous article on the increased fuel oil data collection requirements under MARPOL Annex VI, commencing 1st August 2025, shipowners and operators are encouraged to update their Ship Energy Efficiency Management Plan (SEEMP) Part II & III. Part III of the SEEMP mandates continuous monitoring and improvement of the Carbon Intensity Indicator (CII). IMO resolution MEPC.395(82) offers guidance to:Develop a SEEMP.Produce and implement a three-year plan detailing the specific measures needed to meet the required annual operational CII targets.Whilst MEPC.338(76) sets out the methodology for calculating the required CII, it doesn’t specify reduction factors beyond 2026. However, MEPC.400(83) was recently approved, providing updated annual carbon intensity reduction targets. The targets set out below will help owners and operators to fine tune their technical and operational approach. YearReduction factor relative to 2019202713.625%202816.250%202918.875%203021.500%A further update to the SEEMP guidelines is provided in MEPC.401(83) further clarifying definitions, most notably the definitions of “Underway” and “not underway” which may influence how vessels collect and report their operational data.24 December 2024Starting 1 August 2025, amendments to MARPOL Annex VI require ships to report further details.Ships over 5,000 GT must comply with IMO resolution MEPC.385(81) by collecting and reporting increased fuel oil data.MEPC.385(81) is an amendment to MARPOL Annex VI (regulation 27, Appendix IX), which states requirements for ships to report their fuel consumption data for the previous year. The increased data requirements include:Total fuel oil consumption by fuel type in metric tonnes including a breakdown for each individual consumer, for example auxiliary engine, main engine, or auxiliary boiler.Total fuel oil consumption by fuel type while not underway for each consumer in metric tonnes.Total distance travelled and total laden distance travelled in nautical miles, as well as total hours spent under way.Total amount of onshore power supplied in kWh.Additionally, there is increased data required for vessels complying with regulation 28 for Carbon Intensity Indicator (CII). This includes total transport work (at the time of writing this refers to the cargo carried, in tonnes, multiplied by the distance carried in nautical miles across the full reporting year) and any installations of innovative technology.Vessels must update and have their Shipboard Energy Efficiency Management Plan (SEEMP) Part II verified by the relevant authorities to approve the enhanced data collection and confirm the methods used for gathering the data.Furthermore, vessels should complete any planned or ongoing retrofits of flowmeters before submitting for approval to their relevant authority as this will alter the methods used for data collection.To aid with the implementation of these amendments, IMO released circular MEPC.1/Circ.913 with further guidance which is outlined below.New vessels delivered on or after 1 August 2025 must comply with the new fuel oil data collection requirements.Vessels delivered before 1 August 2025 have two options:Voluntarily compliance with the updates effective from 1 January 2025.To start collecting the increased data from 1 January 2026 and ensure the SEEMP Part II is updated and verified for the changes after 1 August 2025.These options allow the data to remain consistent within each reporting period. We recommend early voluntary compliance to ensure systems are in place before becoming mandatory, helping to avoid potential commercial impacts in the future.For more on 2025 incoming regulations read here.