IMO DCS: Transport Work and Advanced Granularity from 2026

DCS: ordinary enhanced granularity from 2026, 2025 early-implementation or delivery branches, transport work, data gaps and access.

Operational Explanation

To prepare the DCS report, connect each datum to its applicable period and SEEMP Part II method: fuel consumption and consumers, voyage phases, cargo, distances and shore power. Reconciliation must keep distinct the data required from all DCS ships, transport work for the regulation 28 subset and the CII calculation.

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)”.

For shore power retain total kWh with invoices/evidence and consistency checks. This does not create a universal obligation to install a new meter: document the method in the SEEMP.

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.

Regulation 27 DCS covers ships of 5,000 GT and above within chapter 4: retain regulation 19 exclusions, including ships solely operating in waters under their flag State's sovereignty/jurisdiction and ships not propelled by mechanical means, platforms including FPSOs/FSUs and drilling rigs. Transport work applies only to the regulation 28 subset, also defined by ship type. Tonnage alone does not determine both duties.

What total transport work is, and how it is calculated

Total transport work is the annual sum of cargo × distance for each voyage, using Table 1 metrics in MEPC.395(82). Original paragraph 7.11 became 7.12 after MEPC.401(83) inserted paragraph 7.6. The table below gives the metrics by ship type:

Containerships and ro-ro passenger ships must retain both listed metrics. The cited Table 1 has no explicit refrigerated-cargo-carrier row, although that type appears in regulation 28: do not infer an exemption. For that category, verify the metric and SEEMP-documented method with the Administration or authorized organization.

DCS transport work is not the CII denominator

AER and cgDIST remain capacity-based indicators, using DWT and GT respectively as cargo proxies. Actual transport work does not replace that denominator. Under MEPC.401(83), paragraph 7.6, underway is the FAOP–EOSP period, but canal transit is not under way. MEPC.413(84), paragraph 7.7.2 and appendix 4, separates underway and not-underway distance: record the two distances separately and reconcile them to the total using the SEEMP method. CII uses total distance, not only underway distance, and capacity as a proxy, not actual cargo (MEPC.412(84)).

Collection timetable: ordinary implementation, early implementation and delivery

Granularity must be consistent throughout the relevant collection and reporting period. The calendar depends on flag implementation and delivery date:

MEPC.1/Circ.913 distinguishes the ordinary branch (existing ships: enhanced granularity from 1 January 2026, with Part II revised and verified beforehand), early implementation (from 1 January 2025 where adopted by the Administration, with revision/verification before that date or at delivery for ships delivered from 1 January 2025), and ships delivered on or after 1 August 2025, collecting enhanced data from delivery. Retain the Part II Confirmation of Compliance before the applicable period: it is not the annual DCS/CII Statement or the IAPP.

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

Distinguish four levels: the public aggregated annual report, institutional database access, non-anonymized reports for company-owned ships made public at that company's request (regulation 27.15, MEPC.385(81)), and future public-account access to the anonymized database from 1 September 2027 (new 27.14, MEPC.407(84)). Confidential sharing with consultants/researchers is a separate channel, not public access.

Under the 2026 regime, Parties' anonymized access and access to their own flag data are not unrestricted public access. The annual report is available through the IMO DCS page.

From 1 September 2027 MEPC.407(84) also changes Parties' access to non-anonymized data for all ships, allowing a flag Administration to require express approval for inclusion of its ships. Do not anticipate this regime in 2026. The same resolution updates appendix IX, reporting periods and the Fired Boiler(s) entry.

Regulatory Reference

MEPC.407(84): the adopted text in the official MEPC 84/16/Add.1 report, annex 3 is available. Its IMO Knowledge Centre entry remains marked “awaiting certification”: availability of the adopted text and certification of the copy are distinct. Regulation 27 paragraphs 11–17 on DCS access and the 1 September 2027 commencement were read; do not bring that regime forward to 2026.

Ordinary reporting: submit annual aggregated data to the Administration or authorized organization within three months after year end (regulation 27.3); applicable CII reporting follows 28.2. The ordinary deadline for 2026 is 31 March 2027. Transfers of flag, company or both follow the specific 27.4–27.6 branches.

Scope of Application

Regulation 27 DCS covers ships of 5,000 GT and above within chapter 4: retain regulation 19 exclusions, including ships solely operating in waters under their flag State's sovereignty/jurisdiction and ships not propelled by mechanical means, platforms including FPSOs/FSUs and drilling rigs. Transport work applies only to the regulation 28 subset, also defined by ship type. Tonnage alone does not determine both duties.

Regulation 28 references the relevant regulation 2.2 ship types: bulk carrier, combination carrier, containership, cruise passenger ship, gas carrier, general cargo ship, LNG carrier, refrigerated cargo carrier, ro-ro cargo ship, ro-ro cargo ship (vehicle carrier), ro-ro passenger ship and tanker. The metrics table does not replace this regulatory filter.

Procedure / How to Complete It

1. Check regulations 19, 27 and 28 for the ship and period. Identify ordinary implementation from 2026, any flag early implementation from 2025, or collection from delivery for ships delivered on or after 1 August 2025; use the revised/verified SEEMP Part II and its Confirmation before the relevant period.
2. Collect consumption by fuel type and the four groups: main engines, auxiliaries/generators, fired boilers and specified other consumers. Keep not-underway consumption and evidence of the method identifiable.
3. For regulation 28 ships, apply the table metric to each voyage. Containerships and ro-ro passenger ships require both of their respective metrics; absence of a refrigerated-cargo-carrier row is not an exemption: verify the method with the Administration/authorized organization.
4. Record FAOP/EOSP and classify canals as not under way. Reconcile underway and not-underway distances to total distance; for CII retain capacity and total distance instead of substituting actual transport work.
5. Reconcile total shore power in kWh with supplier documents and SEEMP-method evidence; do not presume a universal new-meter requirement.
6. Identify missing periods and fields, retain originals and recover BDNs, engine logs and voyage/cargo data. Apply the SEEMP and submit treatment, estimates, uncertainty and residual gaps to the verifier: no invented zeroes or automatic deferral of the year.
7. Aggregate and submit data to the Administration/authorized organization in the applicable format. The ordinary 2026 reporting deadline is 31 March 2027; manage flag/company transfers separately under 27.4–27.6 and retain the annual Statement separately from the Part II Confirmation.

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

What the PSCO Checks

Operational Tips

• Check evidence continuity monthly as a management measure, without inventing a statutory monthly deadline.
• Keep a gap list identifying period, field, recovered-data source and treatment submitted to the verifier; retain traceability of residual uncertainty.
• Before sharing data, identify the channel: public aggregated report, institutional access, own-ship reports made public at company request, or future anonymized access from 2027. Confidential sharing with researchers/consultancies remains distinct.

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.

• Regulations 19/27/28 applicability and ship type checked
• Circ.913 branch, verified Part II and Confirmation identified
• Four consumer groups, fuel types and operating conditions reconciled
• Voyage metrics complete, including both for containers/ro-ro passenger
• Canals, both distances and total consistent; CII distinct from transport work
• Shore power and supplier evidence available
• Gaps/treatment and annual documents ready for the verifier

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Certified substantive revision: 17 October 2026 · page fingerprint 57403e0f1c49