Operational Guide · Registers & Logbooks

# SEEMP Part II and Part III

The plan that links data collection (Part II) to the improvement strategy (Part III): a deadline often treated as mere documentary compliance, with direct consequences for the CII rating.

SEEMP IMO DCS operational efficiency corrective action plan

## Operational Explanation

The Ship Energy Efficiency Management Plan (SEEMP) is structured into several parts: Part I sets out the ship's general energy efficiency strategy; Part II defines the data collection methodology for the IMO Data Collection System (DCS); Part III (mandatory since 2023) documents the three-year operational implementation plan for achieving CII targets, including any Corrective Action Plan.

The deadline for updating SEEMP Part II (31 December 2025, in line with the evolution of data collection requirements) and the requirement to update the three-year Part III plan (which now covers the 2026-2028 period) are often treated as documentary formalities, when in fact they define the very methodology on which the entire CII rating system is based.

## Regulatory Reference

MARPOL Annex VI, Chapter 4: SEEMP Part I (general strategy), Part II (IMO DCS data collection methodology, updated per the greater data granularity required from 1 August 2025, Res. MEPC.385(81)), Part III (three-year CII implementation plan, mandatory since 2023, with revision for the 2026-2028 three-year period).

## Scope of Application

Ships subject to IMO DCS and CII reporting, per the applicable size thresholds (generally ≥5,000 GT).

## Procedure / How to Complete It

1. Update SEEMP Part II per the data granularity requirements set out in the regulations in force, verifying consistency with onboard data collection systems.
2. Develop or update SEEMP Part III with a three-year implementation plan (e.g. the 2026-2028 period), including CII targets and planned operational/technical measures.
3. Integrate into Part III any Corrective Action Plan required by an insufficient CII rating.
4. Verify formal approval of SEEMP Part III per the procedure required by the Flag Administration or recognized organization.
5. Periodically review the three-year plan based on the CII results actually achieved, rather than waiting until the end of the three-year period for a substantial update.

## Practical Example

Three-year plan example: SEEMP Part III 2026-2028 including cruising speed optimization in the first year, installation of a trim monitoring system in the second year, and evaluation of a low-resistance hull coating in the third year, with specific CII rating targets for each phase.

## Real Cases

Several Companies, according to the most recent industry analyses, have recognized that a SEEMP Part III treated as a static document, without revision based on actual CII results, produces increasingly ineffective plans over time, precisely as the required reduction factors become stricter year after year.

## Common Mistakes Mistake Library

Mistake | Consequence | How to avoid it
--- | --- | ---
SEEMP Part II not updated per the greater data granularity required from 1 August 2025 | Data collected not compliant with the new requirements, CII reporting at risk of inaccuracy | Promptly update the data collection methodology per the requirements in force
SEEMP Part III developed as a generic document, without measures specific to the ship | Plan not effective at genuinely improving the CII rating | Develop the plan with specific measures calibrated to the technical and operational characteristics of the specific ship
Three-year plan not revised based on interim CII results | The plan becomes misaligned with operational reality before the end of the three-year period | Periodically review the plan based on the CII results actually achieved

## PSC Observations

PSCOs check for the presence and formal approval of the SEEMP (all applicable parts) and, for ships with an insufficient CII rating, the presence of the Corrective Action Plan integrated into Part III.

## Operational Tips

- Do not treat the SEEMP as a document to be updated only at its formal deadline: review it based on actual CII results.
- Always develop measures specific and calibrated to the ship, not a generic plan applicable to any unit in the fleet.
- Promptly update the data collection methodology (Part II) whenever the required granularity requirements change.

## Checklist

- SEEMP Part II updated per the granularity requirements in force
- SEEMP Part III with a three-year plan specific to the ship
- Corrective Action Plan integrated into Part III, if required
- Formal approval of the SEEMP verified
- Plan periodically reviewed based on actual CII results

## FAQ

What is the difference between SEEMP Part II and Part III?
Part II defines the data collection methodology for the IMO DCS; Part III (mandatory since 2023) documents the three-year operational implementation plan for achieving CII targets, including any Corrective Action Plan.
When was the deadline for updating SEEMP Part II?
31 December 2025, in line with the evolution of CII/DCS data collection requirements, including the greater granularity required from 1 August 2025 (Res. MEPC.385(81)).
Does SEEMP Part III always cover a 3-year period?
Yes, typically: the implementation plan is structured on a three-year basis (e.g. 2026-2028), with the possibility/need for earlier revision based on CII results actually achieved.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

CII (Carbon Intensity Indicator)MARPOL Annex VI — Prevention of Air Pollution

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