IMO DCS: Transport Work and Advanced Granularity from 2026
From 1 August 2025 Appendix IX to Annex VI is replaced: total transport work is due only from ships subject to Regulation 28, while advanced consumption granularity applies across the DCS from calendar year 2026.
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)”.
The underway/not underway pair is not defined in Appendix IX: it is defined in the SEEMP guidelines as amended by Res. MEPC.401(83) of 11 April 2025 — “Under way is defined as the period between full ahead on passage (FAOP) and end of sea passage (EOSP)” and “'Not under way' is therefore the period between end of sea passage and full ahead on passage.” The same resolution replaces, at §§7.1 and 7.3 of the guidelines, the term “boilers” with “fired boilers”. Res. MEPC.413(84) of 1 May 2026 in turn amends the same guidelines, as previously amended by MEPC.401(83), so that the aggregated annual data distinguish the distance travelled under way from that not under way.
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.
One consequence follows, and it comes before everything else: total transport work is not a datum every DCS ship owes. Regulation 27 catches every ship of 5,000 GT and above; Regulation 28 — the CII one — catches a subset of those, defined by ship type. A ship subject to the DCS but outside Regulation 28 reports advanced fuel granularity and reports no transport work at all.
What total transport work is, and how it is calculated
The operational definition is not in Appendix IX: it is in the SEEMP guidelines, resolution MEPC.395(82) of 4 October 2024, at §7.11 — “Total transport work is the annual sum of each voyage's transport work, which is distance sailed multiplied by cargo carried during a voyage. Relevant transport work metrics per ship types are provided in table 1 below.” So it is neither the distance sailed nor the cargo: it is the product of the two, summed voyage by voyage over the calendar year. Table 1 assigns the metric per ship type:
| Ship type | Transport work metric |
|---|---|
| Bulk carrier, tanker, combination carrier, gas carrier, LNG carrier, general cargo ship, ro-ro cargo ship (including vehicle carriers) | sum over voyages of (cargo mass × distance sailed) |
| Containership | sum of ((cargo mass + container mass) × distance) and, in addition, sum of (number of TEU × distance) |
| Cruise passenger ship | sum over voyages of (number of passengers × distance) |
| Ro-ro passenger ship | sum of (number of passengers × distance) and, in addition, sum of (cargo mass × distance) |
Two ship types carry two metrics rather than one: the containership and the ro-ro passenger ship. It is the easiest configuration mistake to make when adapting the onboard system, because the software will happily accept a single one.
DCS transport work is not the CII denominator
The new datum measures the cargo actually carried. The regulatory CII does not use it. Resolution MEPC.352(78) defines at §2.4 a CII “in which calculation the capacity of a ship is taken as proxy of the actual mass or volume of the shipment carried on board” and calls it supply-based; at §2.5 it specifies that “the supply-based CII which uses DWT as the capacity is referred to as AER, and the supply-based CII which uses GT as the capacity is referred to as cgDIST”. AER and cgDIST therefore remain measures founded on the ship's capacity as a proxy for cargo, not on actual cargo. Total transport work is a demand-based measure: it sits alongside the CII on the same reporting form, but it is not its denominator. Confusing the two produces an internally recalculated rating that will never match the Administration's.
When it actually starts: calendar year 2026, and 2025 on one condition
Circular MEPC.1/Circ.913 of 21 October 2024 governs the transition, and it starts from a principle: there must be “uniform data granularity throughout the collection and reporting process over a calendar year”. Granularity is not changed mid-year. Hence the three scenarios:
- Ordinary. The SEEMP is revised “before 1 January 2026”; in the meantime “data will be collected with the existing level of granularity throughout the entire year of 2025”, and the new granularity applies “from 1 January 2026 and beyond”.
- Early application. MEPC.385(81) “ALSO INVITES the Parties to consider the early application of the amendments to appendix IX … from 1 January 2025”. For that to hold, however, the SEEMP “should undergo revision and verification by the Administration … before 1 January 2025”: the Company's willingness was not enough, the Administration's verification was required, and that deadline has passed.
- Ships delivered after 1 August 2025. They collect at advanced granularity “from the date of delivery”, without waiting for the turn of the calendar year.
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
The regime in force is the one in Regulation 27. The IMO DCS User Guidance, revision 5 of 17 April 2025, sums it up: “the Secretary-General of the Organization shall maintain an anonymized Database such that identification of a specific ship will not be possible and Parties to MARPOL Annex VI shall have access to the anonymized data strictly for their analysis and consideration”. Each Administration sees its own ships in the clear, those flying its flag; everything else it sees anonymised. Recognized organizations have no access even to the anonymised dataset.
That revision of the User Guidance is dated 17 April 2025, however, and describes the picture before MEPC.385(81) entered into force. The very resolution that replaced Appendix IX also added two access paragraphs to Regulation 27, in force since 1 August 2025. Paragraph 15 grants the general public the consumption reports in non-anonymised form, on the request of the company and for the ships it owns: “The Secretary-General of the Organization, on the request of a company, shall grant access to the fuel oil consumption reports of the company's owned ship(s) in a non-anonymized form to the general public.” Paragraph 14 provides for case-by-case sharing with third parties: “On an ad hoc basis, the Secretary-General of the Organization may share data with analytical consultancies and research entities, under strict confidentiality rules.” This public access on the company's request is therefore already available today.
What, then, does resolution MEPC.407(84), entering into force on 1 September 2027, actually add? The text adopted on 1 May 2026 rewrites paragraphs from 11 to 17 of Regulation 27 and introduces a paragraph 12 for the Parties: “Parties shall have access to a non-anonymized database containing data for all ships to which this regulation applies strictly for their analysis and consideration.” Paragraph 13, however, leaves each Administration free to notify the Secretary-General that its express approval is necessary before the data of ships entitled to fly its flag are included in the non-anonymised database, and paragraph 17 carries over the general public's access to the consumption reports in non-anonymised form on the company's request. The same resolution also amends Appendix IX again: the reporting period is split between Regulation 27 and Regulation 28, and the item “Oil-fired Boiler(s)” becomes “Fired Boiler(s)”.
Regulatory Reference
MARPOL Annex VI, Appendix IX, as replaced by Res. MEPC.385(81) (adopted 22 March 2024, in force since 1 August 2025). To be read with Res. MEPC.395(82), §7.11 and Table 1, for the definition of total transport work, and with circular MEPC.1/Circ.913 of 21 October 2024 for the start date. Total transport work is due only from ships to which Regulation 28 applies; advanced fuel granularity from all ships subject to Regulation 27.
Scope of Application
Two distinct perimeters, and they must be kept apart. Advanced consumption granularity concerns every ship of 5,000 GT and above subject to the DCS under Regulation 27 of Annex VI. Total transport work concerns only ships to which Regulation 28 applies, that is, ships of 5,000 GT and above falling within the ship types referred to by that Regulation and which therefore calculate a CII. Table 1 of MEPC.395(82), as amended, assigns a transport work metric to bulk carriers, tankers, combination carriers, gas carriers, LNG carriers, general cargo ships, ro-ro cargo ships (including vehicle carriers), containerships, cruise passenger ships and ro-ro passenger ships. Responsibility for adapting onboard data-collection systems remains with the Company.
Declared limit: we could not read the consolidated text of Regulations 27 and 28 on an IMO PDF — the documents containing the revised Annex VI open but are truncated before the Chapter 4 regulations; the Regulation 27 verbatim quotes above are read on the amending resolutions MEPC.385(81) and MEPC.407(84). The ship-type list above is the one in Table 1 of the SEEMP guidelines, which does not claim to coincide entry by entry with the list in Regulation 28. The existence of the distinction between the two perimeters is, by contrast, read directly on the heading of Appendix IX in the text of the resolution.
Procedure / How to Complete It
- First establish whether the ship falls under Regulation 28 as well as Regulation 27: whether total transport work must be collected at all depends on the answer.
- If it does, identify on Table 1 of MEPC.395(82), as amended, the metric for the ship's type, and check whether two are needed (containerships and ro-ro passenger ships).
- Record the cargo carried and the distance sailed for each voyage, and sum the product over the calendar year: transport work is a sum of voyages, not a year-end total.
- Adapt onboard systems to fuel granularity: consumption recorded separately for the main engine, auxiliary engines/generators, oil-fired boilers and other consumers to be specified (“Others (specify)”), and by underway/not-underway condition.
- Keep granularity unchanged for the whole calendar year, as MEPC.1/Circ.913 requires, and have the SEEMP revised before the start of the year in which the new collection begins.
- Do not carry transport work into the CII calculation: the denominator of AER and cgDIST remains the ship's capacity, not actual cargo.
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
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Adaptation of data-collection systems postponed by relying solely on the mandatory 2026 deadline, without considering implementation lead times | Systems not ready in time, risk of non-compliance with the 1 January 2026 deadline | Start adapting monitoring systems well ahead of the mandatory deadline |
| Fuel consumption data continued to be collected in aggregate form, without breakdown by consumer or operating condition | Non-compliance with the new IMO DCS granularity requirements | Always adapt onboard systems to the required breakdown by consumer (main engine, auxiliaries/generators, oil-fired boilers, other consumers to be specified) and operating condition |
| Containerships and ro-ro passenger ships configured with a single transport work metric | Incomplete reporting: Table 1 assigns two metrics to both of these ship types | Check on Table 1 of MEPC.395(82), as amended, how many metrics apply to the ship's type before configuring the system |
| Total transport work collected by ships outside Regulation 28, or not collected by ships that fall within it | Wasted work in the first case, an incomplete Appendix IX form in the second | Establish first whether the ship calculates a CII: transport work follows Regulation 28, not Regulation 27 |
| Transport work used as the denominator in an internal CII recalculation instead of the ship's capacity | Operational rating diverging from the Administration's, with management decisions taken on the wrong figure | Keep the two apart: AER and cgDIST remain supply-based, transport work is a datum in its own right |
What the PSCO Checks
Operational Tips
- The first question is not “how do I collect transport work” but “does my ship fall under Regulation 28”: the perimeter comes before the method.
- Always verify that the onboard system separates consumption by main engine, auxiliaries/generators, oil-fired boilers and other consumers to be specified, and by underway/not-underway condition.
- Record cargo and distance per voyage: the annual total cannot be derived from averages, and a year closed badly cannot be recovered.
- The commercial office should be told that public access to non-anonymised data already exists, since 1 August 2025 (Regulation 27.15), but it runs through a request from the company and covers only the ships the company owns. What is awaited from 1 September 2027 with MEPC.407(84) is the Parties' access to the non-anonymised database for all ships: on that one, the adopted text leaves each Administration free to require its express approval before its own flag's ships are included.
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.
- Applicability of Regulation 28 to the ship established, not only that of Regulation 27
- Transport work metric or metrics identified on Table 1 of MEPC.395(82), as amended
- Cargo and distance recorded per voyage, not as an annual total
- Onboard system adapted to break down consumption by the four consumer groups on the form, “Others (specify)” included, and by underway/not-underway condition
- Granularity kept uniform for the whole calendar year, and SEEMP revised before the start of the year
- Transport work kept distinct from the denominator of AER and cgDIST
FAQ
Related Topics
Last substantive revision of this page: 19 August 2026 · page fingerprint b11772bcf69a