Both the EU and the IMO have clear ambitions to reduce GHG (greenhouse gases) emissions from ships, and two similar albeit separate regimes have been introduced:

  • EU MRV – EU Monitoring, Reporting and Verification of CO2 emissions (data collection started 1 January 2018)
  • IMO DCS - IMO Data Collection System on fuel consumption (data collection started 1 January 2019)

Both EU MRV and IMO DCS requirements are mandatory, and intend to be the first step in a process to collect and analyze emission data related to the shipping industry.


Whilst the EU scheme has focus on CO2 emissions from shipping activities to, from and within the EU area, the IMO scheme covers emissions from shipping globally. Whether, how and when the two regimes will converge is not yet decided. The below table provides an overview of the requirements from the two initiatives in terms of scope and reporting:


EU MRV (Monitoring, Reporting and Verification)
IMO DCS (Data Collection System)


EU MRV (Monitoring, Reporting and Verification)
Ships > 5,000 gross tonnage (GT) calling any EU ports.
IMO DCS (Data Collection System)
Ships ≥ 5000 gross tonnage (GT) trading globally. 
First reporting period:
EU MRV (Monitoring, Reporting and Verification)
  • 2018 (1 Jan - 31 Dec 2018)
  • Reporting to verifier by end of January 2019
IMO DCS (Data Collection System)
  • 2019 (1 Jan - 31 Dec)
  • Reporting to verifier by end March 2020 
Monitoring plan:
EU MRV (Monitoring, Reporting and Verification)
  • Separate document describing the methodology for data collection and reporting. 
  • Pre-defined format published by the European Commission (EC). 
  • Subject to verification by an independent accredited verifier.
  • Deadline for submission of Monitoring plan was 31 Aug 2017.
IMO DCS (Data Collection System)
  • Data collection and reporting methodology shall be described in a SEEMP, Part II.
  • SEEMP Part II is an integrated part of the Ship Energy Efficiency Management Plan, SEEMP. 
  • Conformation of compliance by Flag/Recognized Organization (RO).
  • Deadline for submission of SEEMP Part II is 31 Dec 2018. 
Reporting details:
EU MRV (Monitoring, Reporting and Verification)
  • Amount and emission factor for each type of fuel consumed in total
  • Total CO2 emitted and additionally differentiated to aggregated CO2 emitted
    - Voyages to and from EU ports
    - Voyages between EU ports
    - At berth
  • Total transport work
    - Time at sea and in port
    - Cargo carried
  • Average energy efficiency
IMO DCS (Data Collection System)
  • Period of calendar year for which the data is submitted
  • Distance travelled
  • Amount of each type of fuel consumed in total
  • Hours underway under own propulsion
  • DWT to be used as cargo proxy
Reporting to:
EU MRV (Monitoring, Reporting and Verification)
  • European Commission:
    - Company reports annual emissions to the EMSA data base (“THETIS MRV”).
    - Annual report to be verified by an accredited verifier (such as DNV GL)
IMO DCS (Data Collection System)
  • Flag state:
    - Annual emission report to be verified by Flag Admin./RO (such as DNV GL)
    - Flag State (or RO) reports to IMO data base
EU MRV (Monitoring, Reporting and Verification)
  • European Commission will make data publicly available
IMO DCS (Data Collection System)
  • Individual ship data will be kept confidential

Timeline for EU MRV and IMO DCS:

IMO DCS and EU MRV milestones

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Delegated Regulation on Verification Activities and Accreditation including competence requirements for shipping MRV auditors

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CONSOLIDATED VERSION: Regulation (EU) 2015/757 as amended by Commission Delegated Regulation (EU) 2016/2071