IMO DCS: Transport Work and Advanced Granularity from 2026

DCS: ordinary enhanced granularity from 2026, 2025 early-implementation or delivery branches, transport work, data gaps and access.

Operational Explanation

Resolution MEPC.385(81), adopted on 22 March 2024 and in force since 1 August 2025, does not add fields to Appendix IX of Annex VI: it replaces it entirely. The resolution is blunt about it — “Appendix IX is replaced by the following” — and the reporting form that results carries several novelties: total transport work, advanced fuel consumption granularity, broken down by onboard consumer group — four of them, not three: “Main Engine(s)”, “Auxiliary Engine(s)/Generator(s)”, “Oil-fired Boiler(s)”, “Others (specify)” — and by operating condition (underway/not underway), the “Total amount of onshore power supplied (kWh)” and the “Laden distance travelled (nm) (on a voluntary basis)”.

Under MEPC.401(83), paragraph 7.6, underway is the FAOP–EOSP period, but canal transit is not under way. MEPC.413(84), paragraph 7.7.2 and appendix 4, separates underway and not-underway distance: record the two distances separately and reconcile them to the total using the SEEMP method. CII uses total distance, not only underway distance, and capacity as a proxy, not actual cargo (MEPC.412(84)).

For shore power retain total kWh and the not-underway portion with invoices/evidence and consistency checks. This does not create a universal obligation to install a new meter: document the method in the SEEMP.

Regime applicable from 1 August 2025

The new Appendix IX is split into two parts, and the split is the whole point. The first collects the data every DCS ship reports: ship identifiers and particulars, reporting period, consumption by fuel type and by consumer group, distance travelled, hours under way, total amount of onshore power supplied in kWh. The second carries an explicit heading — “For ships to which regulation 28 of MARPOL Annex VI applies” — and contains, in order: “Total transport work”; the applicable CII, to be ticked between AER and cgDIST; the required annual operational CII; the attained annual operational CII before any correction; the attained annual operational CII; any installation of innovative technology; and the operational carbon intensity rating, to be ticked between A, B, C, D and E.

Regulation 27 DCS covers ships of 5,000 GT and above within chapter 4: retain regulation 19 exclusions, including ships solely operating in waters under their flag State's sovereignty/jurisdiction and ships not propelled by mechanical means, platforms including FPSOs/FSUs and drilling rigs. Transport work applies only to the regulation 28 subset, also defined by ship type. Tonnage alone does not determine both duties.

What total transport work is, and how it is calculated

Total transport work is the annual sum of cargo × distance for each voyage, using Table 1 metrics in MEPC.395(82). Original paragraph 7.11 became 7.12 after MEPC.401(83) inserted paragraph 7.6. The table below gives the metrics by ship type:

Containerships and ro-ro passenger ships must retain both listed metrics. The cited Table 1 has no explicit refrigerated-cargo-carrier row, although that type appears in regulation 28: do not infer an exemption. For that category, verify the metric and SEEMP-documented method with the Administration or authorized organization.

DCS transport work is not the CII denominator

AER and cgDIST remain capacity-based indicators, using DWT and GT respectively as cargo proxies. Actual transport work does not replace that denominator. Under MEPC.401(83), paragraph 7.6, underway is the FAOP–EOSP period, but canal transit is not under way. MEPC.413(84), paragraph 7.7.2 and appendix 4, separates underway and not-underway distance: record the two distances separately and reconcile them to the total using the SEEMP method. CII uses total distance, not only underway distance, and capacity as a proxy, not actual cargo (MEPC.412(84)).

When it actually starts: calendar year 2026, and 2025 on one condition

Granularity must be consistent throughout the relevant collection and reporting period. The calendar depends on flag implementation and delivery date:

MEPC.1/Circ.913 distinguishes the ordinary branch (existing ships: enhanced granularity from 1 January 2026, with Part II revised and verified beforehand), early implementation (from 1 January 2025 where adopted by the Administration, with revision/verification before that date or at delivery for ships delivered from 1 January 2025), and ships delivered on or after 1 August 2025, collecting enhanced data from delivery. Retain the Part II Confirmation of Compliance before the applicable period: it is not the annual DCS/CII Statement or the IAPP.

The regime before 1 August 2025

Before 1 August 2025 Appendix IX called for ship identifiers and particulars, reporting period, fuel consumption by type, distance travelled and hours under way. It contained no transport work item at all, nor any breakdown of consumption by consumer or by operating condition. Anyone re-reading a DCS report for a calendar year up to 2024 should not expect to find transport work in it: it was not provided for, and its absence is not an omission. The temporal distinction matters the other way round too: a page describing “the DCS” with no date attached, and putting transport work inside it, is describing a regime that did not exist before 2025.

Who sees the data: the regime in force, and the change already adopted

Distinguish four levels: the public aggregated annual report, institutional database access, non-anonymized reports for company-owned ships made public at that company's request (regulation 27.15, MEPC.385(81)), and future public-account access to the anonymized database from 1 September 2027 (new 27.14, MEPC.407(84)). Confidential sharing with consultants/researchers is a separate channel, not public access.

Under the 2026 regime, Parties' anonymized access and access to their own flag data are not unrestricted public access. The annual report is available through the IMO DCS page.

From 1 September 2027 MEPC.407(84) also changes Parties' access to non-anonymized data for all ships, allowing a flag Administration to require express approval for inclusion of its ships. Do not anticipate this regime in 2026. The same resolution updates appendix IX, reporting periods and the Fired Boiler(s) entry.

Regulatory Reference

MEPC.407(84): the direct IMO link is still an awaiting-certification notice; the adopted text is available in ClassNK T1378, attachment 1. The DCS-access paragraphs and 1 September 2027 commencement were checked against this reproduction. This reference does not bring entry into force forward.

Ordinary reporting: submit annual aggregated data to the Administration or authorized organization within three months after year end (regulation 27.3); applicable CII reporting follows 28.2. The ordinary deadline for 2026 is 31 March 2027. Transfers of flag, company or both follow the specific 27.4–27.6 branches.

Scope of Application

Regulation 27 DCS covers ships of 5,000 GT and above within chapter 4: retain regulation 19 exclusions, including ships solely operating in waters under their flag State's sovereignty/jurisdiction and ships not propelled by mechanical means, platforms including FPSOs/FSUs and drilling rigs. Transport work applies only to the regulation 28 subset, also defined by ship type. Tonnage alone does not determine both duties.

Regulation 28 references the relevant regulation 2.2 ship types: bulk carrier, combination carrier, containership, cruise passenger ship, gas carrier, general cargo ship, LNG carrier, refrigerated cargo carrier, ro-ro cargo ship, ro-ro cargo ship (vehicle carrier), ro-ro passenger ship and tanker. The metrics table does not replace this regulatory filter.

Procedure / How to Complete It

1. Regulation 27 DCS covers ships of 5,000 GT and above within chapter 4: retain regulation 19 exclusions, including ships solely operating in waters under their flag State's sovereignty/jurisdiction and ships not propelled by mechanical means, platforms including FPSOs/FSUs and drilling rigs. Transport work applies only to the regulation 28 subset, also defined by ship type. Tonnage alone does not determine both duties.
2. Identify the metric or two metrics for the ship type; retain cargo and distance for each voyage.
3. Separate consumption by fuel type, main engines, auxiliaries/generators, fired boilers and specified other consumers, under the applicable format.
4. Under MEPC.401(83), paragraph 7.6, underway is the FAOP–EOSP period, but canal transit is not under way. MEPC.413(84), paragraph 7.7.2 and appendix 4, separates underway and not-underway distance: record the two distances separately and reconcile them to the total using the SEEMP method. CII uses total distance, not only underway distance, and capacity as a proxy, not actual cargo (MEPC.412(84)).
5. Reconcile total shore power and its not-underway portion with invoices or other evidence.
6. MEPC.1/Circ.913 distinguishes the ordinary branch (existing ships: enhanced granularity from 1 January 2026, with Part II revised and verified beforehand), early implementation (from 1 January 2025 where adopted by the Administration, with revision/verification before that date or at delivery for ships delivered from 1 January 2025), and ships delivered on or after 1 August 2025, collecting enhanced data from delivery. Retain the Part II Confirmation of Compliance before the applicable period: it is not the annual DCS/CII Statement or the IAPP.
7. A gap does not authorize skipping the year. Identify missing periods and fields; retain originals; recover disaggregated evidence from BDNs, engine logs, voyage/cargo data and other available records. Apply SEEMP methods and agree acceptable treatment with the Administration/authorized organization; document estimates, reconciliations, uncertainty and residual gaps for verification. If recovery is impossible, disclose the gap: do not invent zeroes or a new exemption. Manage the non-conformity and reporting for the relevant period, without automatic deferral to the following year.

Practical Example

A 40,000 GT containership makes forty voyages in a calendar year. For each it records cargo mass and container mass, the number of TEU and the distance sailed. At year end it reports two transport work figures — the sum of (cargo + containers) × distance and the sum of TEU × distance — because Table 1 assigns containerships both metrics. A general cargo ship in the same fleet reports one. A 6,000 GT workshop vessel, subject to the DCS but not to Regulation 28, reports none: it adapts fuel granularity and stops there.

What Typically Goes Wrong

Common Mistakes Mistake Library

• Incomplete period: recover, reconcile and submit gaps to the verifier, not delete the year.
• Aggregated consumption only: check disaggregation and evidence required by the method.
• Only one metric for container/ro-ro passenger ships: check Table 1.
• Canals classified underway: correct both distance categories without losing the total.
• Transport work used in CII: retain capacity and total distance in the regulatory denominator.

What the PSCO Checks

Operational Tips

• Check evidence continuity monthly as a management measure, without inventing a statutory monthly deadline.
• A gap does not authorize skipping the year. Identify missing periods and fields; retain originals; recover disaggregated evidence from BDNs, engine logs, voyage/cargo data and other available records. Apply SEEMP methods and agree acceptable treatment with the Administration/authorized organization; document estimates, reconciliations, uncertainty and residual gaps for verification. If recovery is impossible, disclose the gap: do not invent zeroes or a new exemption. Manage the non-conformity and reporting for the relevant period, without automatic deferral to the following year.
• Distinguish four levels: the public aggregated annual report, institutional database access, non-anonymized reports for company-owned ships made public at that company's request (regulation 27.15, MEPC.385(81)), and future public-account access to the anonymized database from 1 September 2027 (new 27.14, MEPC.407(84)). Confidential sharing with consultants/researchers is a separate channel, not public access.

Preparation checklist

Educational checklist. This summary supports learning and preparation only. It does not replace the vessel’s approved procedures, manuals, statutory documents, company SMS, or applicable official requirements. Completing it demonstrates neither compliance nor readiness for an inspection: it shows that a list has been read, not that the ship is in order. Always verify the current documents carried on board.

• Regulation 27 DCS covers ships of 5,000 GT and above within chapter 4: retain regulation 19 exclusions, including ships solely operating in waters under their flag State's sovereignty/jurisdiction and ships not propelled by mechanical means, platforms including FPSOs/FSUs and drilling rigs. Transport work applies only to the regulation 28 subset, also defined by ship type. Tonnage alone does not determine both duties.
• Identify the metric or two metrics for the ship type; retain cargo and distance for each voyage.
• Separate consumption by fuel type, main engines, auxiliaries/generators, fired boilers and specified other consumers, under the applicable format.
• Under MEPC.401(83), paragraph 7.6, underway is the FAOP–EOSP period, but canal transit is not under way. MEPC.413(84), paragraph 7.7.2 and appendix 4, separates underway and not-underway distance: record the two distances separately and reconcile them to the total using the SEEMP method. CII uses total distance, not only underway distance, and capacity as a proxy, not actual cargo (MEPC.412(84)).
• Reconcile total shore power and its not-underway portion with invoices or other evidence.
• MEPC.1/Circ.913 distinguishes the ordinary branch (existing ships: enhanced granularity from 1 January 2026, with Part II revised and verified beforehand), early implementation (from 1 January 2025 where adopted by the Administration, with revision/verification before that date or at delivery for ships delivered from 1 January 2025), and ships delivered on or after 1 August 2025, collecting enhanced data from delivery. Retain the Part II Confirmation of Compliance before the applicable period: it is not the annual DCS/CII Statement or the IAPP.
• A gap does not authorize skipping the year. Identify missing periods and fields; retain originals; recover disaggregated evidence from BDNs, engine logs, voyage/cargo data and other available records. Apply SEEMP methods and agree acceptable treatment with the Administration/authorized organization; document estimates, reconciliations, uncertainty and residual gaps for verification. If recovery is impossible, disclose the gap: do not invent zeroes or a new exemption. Manage the non-conformity and reporting for the relevant period, without automatic deferral to the following year.

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Last substantive revision of this page: 15 September 2026 · page fingerprint 0f00a98dbe8f