CII: 2027-2030 Reduction Factors and New SEEMP Granularity
The revised SEEMP Part II with the new Confirmation of Compliance is not a 2027 obligation: it was already required on board from 1 January 2026, with transport work data that many ships were not yet collecting.
Operational Explanation
MEPC 83 approved amendments to Regulation 27 of MARPOL Annex VI, expected for formal adoption at MEPC 84, introducing reduction factors (Z) for the annual operational CII required for the years 2027, 2028, 2029 and 2030. The review of the CII framework has been structured in two phases: Phase 1, completed before 2026, introduced these reduction factors; Phase 2, concerning more structural changes to the AER metric (including the SEEMP), will be examined at MEPC sessions from 2026 to 2028.
On the immediate operational front, from 2026 the resolution of collected data increases, including transport work ("ton-miles"), and requires a revised SEEMP Part II with a new Confirmation of Compliance (CoC): the revised SEEMP Part II had to be on board existing ships already from 1 January 2026. Ships that had an approved SEEMP Part III also had to revise it by 31 December 2025.
Regulatory Reference
MARPOL Annex VI, Regulation 27, amendments approved at MEPC 83 and expected for formal adoption at MEPC 84: operational CII reduction factors (Z) for 2027-2030 (Phase 1, completed); review of the AER metric/SEEMP (Phase 2) under MEPC examination from 2026 to 2028. Revised SEEMP Part II with new Confirmation of Compliance required on board from 1 January 2026, with data granularity extended to transport work. SEEMP Part III to be revised by 31 December 2025 for ships that already had one approved.
Scope of Application
Every ship subject to CII under MARPOL Annex VI, with a requirement for the revised SEEMP Part II on board from 1 January 2026 and attention to the new operational CII reduction factors required for the 2027-2030 period.
Procedure / How to Complete It
- Verify that the revised SEEMP Part II, with the new Confirmation of Compliance, is on board from 1 January 2026 as required.
- For ships with an already-approved SEEMP Part III, verify that the revision required by 31 December 2025 has been completed.
- Adapt data collection systems to include transport work (ton-miles) with the granularity required from 2026.
- Plan the fleet's operational CII trajectory against the new reduction factors (Z) expected for 2027, 2028, 2029 and 2030.
- Monitor developments in Phase 2 of the CII review (AER metric changes) at MEPC sessions from 2026 to 2028, since they could further change the requirements.
Practical Example
Example: a Company verifies at the start of 2026 that every ship in the fleet has the revised SEEMP Part II with the Confirmation of Compliance, adapts onboard systems to collect the required transport work data, and launches a preliminary assessment of the impact of the 2027-2030 reduction factors on the existing fleet's CII trajectory.
Real Cases
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Revised SEEMP Part II not prepared in time for the 1 January 2026 deadline | Documentary non-compliance with the new CII requirements | Verify and complete the SEEMP Part II revision well ahead of the deadline |
| Transport work data (ton-miles) not collected with the granularity required from 2026 | Incomplete CII documentation relative to the new data resolution requirements | Promptly adapt onboard systems to collect the required transport work data |
| 2027-2030 reduction factors (Z) not considered in fleet strategic planning | Fleet CII trajectory misaligned with future requirements, with risk of penalizing ratings | Integrate the 2027-2030 reduction factors into fleet strategic planning now |
PSC Observations
Operational Tips
- Do not wait for formal adoption at MEPC 84 to comply: the revised SEEMP Part II was already required on board from 1 January 2026.
- Promptly adapt data collection systems to the new transport work requirement, which increases granularity compared to the past.
- Integrate the 2027-2030 CII reduction factors into fleet strategic planning, not just the annual management of individual ships.
Checklist
- Revised SEEMP Part II with Confirmation of Compliance on board from 1 January 2026
- SEEMP Part III revised by 31 December 2025, if already previously approved
- Data collection systems adapted to the transport work granularity required from 2026
- 2027-2030 CII reduction factors integrated into fleet strategic planning
- Developments in Phase 2 of the CII review (2026-2028) monitored