Site visit requirements under EU MRV and FuelEU Maritime
Site visits for all vessels within the scope are mandated under EU Regulations 2023/2917 and 2024/2027, with 2026 marking the first FuelEU verification year. This statutory news provides guidance on site visit procedures and compliance responsibilities, addressing key regulatory and commercial implications.
Information for: Ship owners and managers.
Regulatory background
Site visits are mandatory for compliance undertwo EU regulations:
- EU MRV – under Commission Delegated Regulation (EU) 2023/2917
- FuelEU Maritime – under Commission Implementing Regulation (EU) 2024/2027
For both the EU MRV and FuelEU, site visits must be conducted either physically or virtually. The aim is to gain sufficient understanding of the company and ships’ monitoring and reporting systems and procedures as described in the Monitoring Plan (MP).
Types of site visits
Site visits can be physical or virtual, both with the same scope and purpose. Locations of site visits are chosen by the verifier depending on where relevant data is stored and where dataflow and control activities are conducted. A physical site visit does not necessarily require boarding the ship. Instead, the site visit may be carried out at an alternative location, such as the ISM company’s main office. If relevant activities are conducted by personnel at another location, it may be appropriate to visit that location instead of, or in addition to, the main office. DNV will credit a site visit carried out at the ISM company’s main office. or the entire fleet under the company’s responsibility, also when the owner is formally responsible for monitoring, reporting and verification (MRV). A site visit for a ship can only be credited for that ship.
Frequency of site visits for EU MRV and FuelEU reports
The following principles apply:
- A physical site visit is required only for the verification of a ship’s report if no such visit has occurred during the 3 previous reporting periods, which must be consecutive and begin after 1 January 2024.
- A physical site visit is required at least once every 4 years, starting in 2024.
- If certain conditions are met, verifiers can conduct a virtual site visit or even waive the site visit for a year (refer to Articles 18.6. and 18.7. of Regulation (EU) 2023/2917).
- It is important to note that conducting a virtual site visit does not replace or waive the requirement of a physical site visit.
- Site visits can only be waived for 2 consecutive years, but a virtual or physical site visit must be carried out in the 3rd year
- Site visits cannot be waived if the verifier, such as DNV, has never verified the report for a ship before, as in case of the 2025 FuelEU reports.
The graph above illustrates the recommended scheme for site visits.
To minimize customers’ efforts in meeting the requirements for site visits for the EU MRV and FuelEU, DNV recommends scheduling physical company level site visits every three years (“DNV’s recommendation” in graphic above). This would avoid the need for virtual site visits which would otherwise be required if selecting the minimum physical site visit requirement every four years (“Option 3” in graphic above). If the first visit is a virtual site visit (“Option 2”), two site visits may be waived, but thereafter a physical site visit is required.
DNV also recommends combining site visits with ISM company audits, with a recommended frequency of every third year. EU MRV / Fuel EU site visits may also be combined with SEEMP company audits depending on the flag’s requirements, and these site visits must be carried out by the EU MRV / FuelEU verifier.
Time required for a site visit
The time required for site visits and audits depends on the combination of services (EU MRV, FuelEU Maritime, SEEMP, ISM, ISO 50001) and fleet characteristics. Basic compliance checks typically take at least one day, with additional time needed for larger fleets or when ISM is included. ISO 50001 has minimal impact on duration but impacts the audit focus.
Site visit requirements related to Monitoring Plan (MP) assessments
The site visit requirements related to MP assessments are less stringent than for report verification, as there is no absolute requirement for physical site visits. A site visit is, however, required (can be virtual) in the following cases:
- DNV has never verified the MP for the ship
- During the reporting period, there have been certain modifications to the MP as specified in the regulation
Compliance responsibilities
- For EU MRV: Responsibility lies with either the registered owner or the ISM company if mandated by the owner.
- For FuelEU: Responsibility lies with the ISM company.
Consequences of non-compliance
The site visit is a prerequisite for a successful FuelEU report verification. Should site visits not take place, this may lead to the following disadvantages:
- Final compliance documents will not be issued
- Fines and PSC detentions
How to request a site visit
- The scheme for site visits is available for our customers on DNV’s My Fleet portal (Access “Fleet Status” view à Navigate to “Company Services” at the top of the page à Request audit under “Status” tab).
- If “EU MRV and FuelEU Company physical site visit” is missing, please ask DATE@dnv.com to add it. See illustration at the bottom of this page.
If no vessel in the company’s fleet has undergone an EU voyage in 2025, a site visit is not required at this point in time.
After successful completion of a physical site visit, a “Confirmation of physical site visit” is issued (valid for three years).
If a virtual site visit is carried out, the next physical site visit is postponed by one year (a postponement can only be applied once within a four-year period).
Physical and virtual site visits will be invoiced according to standard hourly rates.
Recommendations
To support timely compliance with EU MRV and FuelEU Maritime requirements, DNV recommends scheduling a site visit early on, ideally before the 2026 verification deadline, i.e. 31 March 2026, or, even better, during the remaining time in 2025.
To optimize resources, consider combining the EU MRV and FuelEU site visits with other planned audits.
Use the My Fleet portal to book your site visit and ensure timely issuance of all the necessary compliance documents.
References
DNV resource pages:
EU Regulations:
