Heads-up on EU MRV and IMO DCS in 2022

Some important milestones for the EU MRV and IMO DCS are coming up in the first half of 2022. This statutory news contains some recommendations relevant to both regulations.

Heads-up on EU MRV and IMO DCS

Relevant for ship owners and managers

The most important milestones for the MRV and DCS are:

  • EU MRV: The verified EU MRV annual emission reports for 2021 should be submitted to the EU Commission by 30 April 2022, and the related documents of compliance should be on board by 30 June 2022.
  • IMO DCS: The 2021 year-end reports for IMO DCS should be submitted to the verifier by 31 March 2022, and the Statements of Compliance (SoCs) should be on board by 31 May 2022.

The usual milestones are unchanged to previous years. This includes DNV’s recommendation to submit the reports as early as possible, at the latest by 31 March, to ensure timely verification. Here are more details:

EU MRV deadline: 30 April 2022

After verification, the XML files of the annual Emissions Reports (ER) are provided for download from the Fleet Status portal on Veracity. Our MRV customers must take those files and upload them as ERs to THETIS-MRV and submit them to DNV for verification in THETIS. After DNV has marked the ER as “verified as satisfactory” in THETIS, companies responsible for vessels subject to the EU MRV scheme shall, as per EU Regulation 2015/757 Art. 11.1, submit the verified ER to the EU Commission by 30 April. Then the vessel’s Document of Compliance (DoC) can be downloaded from THETIS and must be placed on board no later than 30 June.

IMO DCS deadlines: 31 March (FOCR) and 31 May (SoC) 2022

By 31 March, companies must (according to MARPOL Annex VI, Reg. 22A.3) submit the year-end fuel oil consumption report (FOCR) to their DCS verifier. DNV is fully authorized for DCS verification by most flag states. Customers should, however, note that the authorization levels may be limited for some flags. After verification, depending on the authorization level from the flag, DNV will provide customers either with a Statements of Compliance (SoCs) on the FOCRs or DNV will issue a verification letter, for download from the Fleet Status portal on Veracity.

By 31 May, the SoC on the FOCR must be placed on board. Summary of the deadlines:

SubmissionDoC on board
EU MRVVerified ER submitted to EU Commission by 30 April30 June
IMO DCSYear-end FOCR submitted to verifier (DNV) by 31 March31 May

Self-check of voyage data using DNV’s data checks

Throughout the year, but certainly prior to submission of reports (MRV or DCS), customers should make sure to benefit from the data checks available in their customer portal on Veracity. These are automated checks applied on the submitted voyage data per vessel. The checks support you in identifying if and how any data might need to be corrected. If there are no warnings or issues for the voyage data, the aggregated reports (ERs or FOCRs) are ready to be submitted for verification.

Ordering of MRV and DCS with same verifier

DNV recommends submitting the MRV/ER and DCS/FOCR and ordering the verification together. Once the voyage data are prepared, it should be beneficial to handle both at the same time. Combined submission (MRV and DCS) will also ensure a more favourable price for verification rather than performing, for example, only MRV with DNV.

Improved reporting for ports of call

Particularly cruise ship operators will welcome the extended possibilities to report ports of call by using the optional parameter “time_elapsed_loading / unloading”, available from 1 January 2022. For further information, please also refer to the “Notes” sheet of the interface description and of the CSV converters, which will be available on the customer portal on Veracity in February 2022.

Compliance with UK MRV

The monitoring, reporting and verification of CO2 emissions from voyages according to the UK MRV commences on 1 January 2022. To benefit from DNV’s service offering, customers simply need to continue monitoring and reporting as they do today. By carrying the verified EU MRV monitoring plan together with DNV’s statement letter, the vessel will comply with both the UK MRV and the EU MRV regulations. The statement letter is provided in the Fleet Status portal on Veracity. For further details, please read the latest T&R news on the UK MRV (see link below).

DNV’s CII dashboard lets you monitor your CII today

The CII regulations use DCS data as the basis for calculating a ship’s carbon intensity trajectory. Based on our estimates, many ships will be challenged to meet the CII targets. On or before 1 January 2023, cargo, ro-pax and cruise ships above 5,000 GT need to have an approved SEEMP III. The SEEMP III includes an implementation plan on how to achieve the CII targets.

DNV’s CII dashboard lets you monitor your CII performance today. It is available for all IMO DCS customers in our Emissions Insights tool under My Services on Veracity.

Stay tuned in 2022 for more news on CII, SEEMP III and related news and updates.


We recommend that our customers note the mentioned milestones in your to-do lists, including our recommendation to submit the reports as early as possible and at the latest by 31 March 2022 to ensure timely verification.



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