Vessel Energy Efficiency Audits

The Ship Energy Efficiency Management Plan is a mandatory requirement under MARPOL Annex VI for vessels of 400 GT and above engaged in international voyages. In its original form, SEEMP established a framework for monitoring fuel consumption and driving continuous efficiency improvement. Since the entry into force of CII requirements in January 2023, however, SEEMP has been significantly elevated in regulatory importance. SEEMP Part III is now the central operational carbon compliance instrument for vessels of 5,000 GT and above, embedding annual CII targets, corrective action planning, and IMO Data Collection System obligations directly into the vessel’s formal management framework. For owners and operators who treat SEEMP as a documentation exercise rather than a live management tool, the regulatory and commercial consequences are increasingly material.

Our services are structured to transform SEEMP from a statutory obligation into a functioning operational management system — one that delivers measurable fuel savings, supports CII rating performance, and provides the documentary foundation required for port state control, flag state oversight, and charter counterparty scrutiny.

The Three-Part SEEMP Structure

Understanding SEEMP requires clarity on its three distinct components, each carrying different compliance obligations and operational implications.

SEEMP Part I establishes the vessel’s energy efficiency management framework. It documents the measures, practices, and responsibilities through which the vessel will monitor and improve its energy performance. This includes voyage planning optimisation, speed and power management, hull and propeller maintenance scheduling, waste heat recovery utilisation, and crew engagement in efficiency practices. While Part I does not impose quantified targets, it must reflect the vessel’s actual operational context and be kept current as trading patterns and technical condition evolve. Our services include Part I development, review, and revision to ensure it functions as a genuine management document rather than a generic template with no operational connection to the vessel’s deployment.

SEEMP Part II governs compliance with the IMO Data Collection System, requiring vessels of 5,000 GT and above to collect, report, and verify annual fuel oil consumption data. The DCS reporting cycle underpins both CII calculation and broader IMO fleet emissions monitoring. Our services cover DCS methodology review, data collection procedure assessment, and verification preparation — ensuring that the data submitted accurately reflects operational reality and withstands third-party verification scrutiny.

SEEMP Part III is the most operationally consequential component for vessels subject to CII requirements. It must contain the vessel’s annual CII target, the methodology by which attained CII will be calculated, a plan of corrective actions where required, and confirmation of management review. Critically, a vessel rated D for three consecutive years or E in any single year is required to include a Corrective Action Plan within SEEMP Part III — a mandatory, documented response to sustained underperformance that is subject to flag state and port state review. Our services encompass Part III development and annual updating, CII target setting and attainment methodology documentation, corrective action plan preparation where triggered, and integration of Part III with the vessel’s broader operational performance management processes.

What Our Services Cover

Our SEEMP advisory and implementation services address the full lifecycle of the plan — from initial development and regulatory gap assessment through to annual review, performance monitoring integration, and corrective action planning.

For vessels that have not yet established a compliant and operationally meaningful SEEMP, our services begin with a structured gap assessment against current MARPOL Annex VI requirements, identifying deficiencies in documentation, data collection procedures, and CII target methodology. Where existing SEEMPs are in place but were developed as compliance formalities rather than management tools, our services include a comprehensive review and restructuring to ensure the plan reflects actual vessel operations, trading patterns, and technical condition.

Annual SEEMP review and updating is a core service offering. Because CII targets tighten each year and a vessel’s operational and technical profile evolves continuously, a SEEMP that was adequate in one compliance year may be materially deficient in the next. Our services ensure that Part III is updated annually with accurate CII targets, current attainment methodology, and — where performance deterioration risk is identified — proactive corrective measures documented before regulatory triggers are reached rather than in response to them.

Corrective Action Plan development is a specialist service within our SEEMP offering. A CAP is not simply a statement of intent; it must identify specific, actionable measures, assign responsibility, establish timelines, and demonstrate a credible pathway back to C-rating or above. Our services draw on the analytical outputs of our CII gap analysis work to ensure that corrective action plans are grounded in quantified performance data and operationally realistic intervention options — spanning speed optimisation, voyage planning improvements, hull and propeller maintenance scheduling, energy-saving device deployment, and fuel management practices.

Integration with fleet performance monitoring systems is another dimension of our services. SEEMP is most effective when it is connected to live operational data rather than reviewed only at annual intervals. Our advisory work includes assessment of existing performance monitoring infrastructure and guidance on integrating SEEMP targets and thresholds into fleet dashboards, enabling continuous visibility of CII trajectory and early identification of deterioration risk before it reaches regulatory consequence.

Interaction with Other Regulatory Frameworks

SEEMP sits at the intersection of multiple regulatory obligations. CII performance, which SEEMP Part III governs, is directly affected by the operational decisions documented in Part I and the data quality established through Part II’s DCS compliance. SEEMP also intersects with EEXI, since power limitation measures adopted for EEXI compliance affect the vessel’s speed and fuel consumption profile and must be reflected in SEEMP efficiency planning. For vessels trading in EU waters, SEEMP efficiency measures have direct implications for EU ETS allowance liability and FuelEU Maritime GHG intensity performance. Our services ensure that SEEMP development and management is integrated with the vessel’s full regulatory profile rather than managed as a standalone document.

Outputs and Deliverables

• • SEEMP regulatory gap assessment against current MARPOL Annex VI Part II and Part III requirements
  • SEEMP Part I development and operational contextualisation
  • IMO DCS methodology review and data collection procedure assessment
  • SEEMP Part III development including CII target setting and attainment methodology documentation
  • Annual SEEMP review and updating service
  • Corrective Action Plan development for D- and E-rated vessels
  • Integration advisory for fleet performance monitoring and dashboard connectivity
  • Port state control and flag state documentation readiness review
  • Cross-regulatory interaction assessment covering CII, EEXI, EU ETS, and FuelEU Maritime