IMO DCS reporting deadline on 31 March 2021 – be prepared

Now with the second DCS reporting year recently ended, it is again time for reporting data on fuel oil consumption to your DCS verifier. To ensure a Statement of Compliance (SoC) is issued in due time before 31 May 2021 as required, the deadline in MARPOL for reporting 2020 data for verification is 31 March 2021. This statutory news is a reminder on how to stay compliant with regulation 22A of MARPOL Annex VI.

IMO DCS Reporting deadline on 31 March 2021 – Be Prepared

Relevant for ship owners and managers as well as flag states.

Be ahead of the deadline

Regulation 22A of MARPOL Annex VI requires ships to collect and report data on their fuel consumption following a yearly cycle. Compliance is evident through the SoC issued annually on behalf of the flag, confirming that the required data for the previous year was submitted in accordance with the methodology and process in the ship’s SEEMP. Flag administrations are important stakeholders in this process too. They have an obligation towards the IMO to ensure their ships comply. Hence, not having a valid SoC may not only be an issue with PSC, but also directly with the flag administration.

For ships to which this regulation applies, it is important that a valid SoC is readily available on board for inspection, together with the Confirmation of Compliance (CoC) for the SEEMP Part II. The CoC (SEEMP Part II) and the validity of the SoC (DCS) will be checked at each periodical statutory survey regardless of whether the DCS verifier having issued the SoC is the flag administration, class (Recognized Organization), or any other verifier approved by the flag administration.

In other words, if DNV GL is your verifier, you need to submit your 2020 data to us as soon as possible, at the latest on 31 March 2021, to ensure that an SoC is issued on time before 31 May 2021 as required.

The DCS data is yours – use them smartly

The DCS data submitted document the status and progress of your ship’s and fleet’s GHG emission performance towards meeting the IMO emissions targets. The DCS data is also of interest to other stakeholders for reporting and benchmarking, for instance, charterers, financial institutions, and ESG (Environment Social Governance) reporting.

When choosing DNV GL as a DCS verifier, you will also gain access to your data in our Emissions Insights dashboard available in My Services on our Veracity data platform. Emissions Insights is a monitoring tool and a smart solution for your environmental emissions management, providing easy data sharing, monitoring, benchmarking, and suggestions for improvement of individual ships and on a fleet level.

EU MRV reporting to THETIS

Equally important and not to be forgotten is the EU MRV reporting, in addition to the DCS reporting for vessels calling at EU ports. By 30 April 2021, companies need to submit the verified MRV Emissions Report to the EU Commission (THETIS). To ensure timely verification, companies should submit their MRV Emissions Reports for verification no later than 31 March 2021.


Early submission of DCS data is required, by 31 March 2021 at the latest. If there are any outstanding issues for any reason concerning the data reporting for 2020, or other reasons to believe that the SoC will not be issued before the deadline, we encourage ship owners/managers to contact their DCS verifier to avoid becoming non-compliant on 1 June 2021.



  • For customers: DATE – Direct Access to Technical Experts via My Services on Veracity 
  • Otherwise (including approved radio service suppliers): Use our office locator to find the nearest DNV GL office.
29 April 2022

IMO maritime safety committee (MSC 105)

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  • Maritime
11 April 2022

IMO sub-committee on pollution prevention and response (PPR9)

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  • Maritime
24 March 2022

SEEMP Part III and the upcoming SEEMP Generator from DNV

Since 2019 ships of 5,000 GT and above have been reporting their fuel oil consumption data mandated by the IMO DCS. From 2023, cargo, cruise and RoPax ships must calculate CII with a required rating of C or better. This means some ships will have to improve their carbon intensity. A verified Ship Operational Carbon Intensity Plan, or SEEMP Part III, is to be kept on board from 1 January 2023 to document how you plan to achieve your CII targets. This statutory news provides an update on the SEEMP Part III and recommends next steps.

  • Maritime
07 March 2022

IMO Sub-Committee on Ship Systems and Equipment (SSE 8)

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  • Maritime
14 February 2022

IMO Sub-Committee on Human Element, Training and Watchkeeping (HTW 8)

The 8th session of the IMO’s Sub-Committee on Human Element, Training and Watchkeeping (HTW 8) was held remotely from 7 to 11 February. Highlighting the human element as a key factor both for safety and environmental protection, HTW 8 agreed on a revised checklist for considering the human element in the review, development and implementation of new and existing IMO requirements. HTW 8 also agreed on amendments to the STCW Convention and Code to accommodate the use of seafarers’ electronic certificates and documents.

  • Maritime
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