IMO DCS Appendix IX amendments and shipboard data collection

The reporting form for the IMO Ship Fuel Oil Consumption Data Collection System (DCS) has changed. Resolution MEPC.385(81) replaced Appendix IX of MARPOL Annex VI in full. The wording in the resolution is “12 Appendix IX is replaced by the following”.

The dates are in the preamble. Adopted 22 March 2024, deemed accepted 1 February 2025 under MARPOL article 16(2)(f)(iii), entered into force 1 August 2025 (paragraph 3). Paragraph 4 adds one line.

4 ALSO INVITES the Parties to consider the early application of the amendments to appendix IX with regard to information to be submitted to the IMO Ship Fuel Oil Consumption Database from 1 January 2025;

So the first full calendar year on the new form is 2026, and it is 2025 if your flag State has adopted early application. Check the guidance from your flag State and recognised organisation to find out which applies to you.

Totals by fuel type no longer fill the form

These are the fuel consumption fields in the replaced Appendix IX. The ones in bold are new.

Field	Content
Total consumption by fuel oil type	Existing
Total consumption by fuel oil type and consumer	Main Engine(s) / Auxiliary Engine(s)·Generator(s) / Oil-fired Boiler(s) / Others (specify)
Consumption by type and consumer, not under way	Split again across the same four consumers
Total distance travelled (nm)	Existing
Laden distance travelled (nm)	New, voluntary submission
Hours under way	Existing
Total shore power received (kWh)	New

The particulars section also gained Net tonnage (NT), Attained EEXI and Ice class.

Ships to which regulation 28 (CII) applies report Total transport work, the applicable CII type (AER or cgDIST), the required annual operational CII, the attained CII before and after correction, whether innovative technology is installed, and the operational carbon intensity rating in the same form. That is why the resolution title calls this amendment “inclusion of data on transport work and enhanced granularity”.

Consumption per consumer cannot be produced in December

This amendment changes how you collect, not how you calculate. The difference matters.

If a formula had changed you could recalculate at year end from the data you already hold. But the figure split across main engine, auxiliary engines and boilers cannot be produced in December unless you received it split all year. There is no way to work it back from a total. The same is true of consumption while not under way. If you did not record under way and in port separately, there is nothing to divide at year end.

Checking when the reporting deadline approaches is too late. Regulation 27.3 requires the aggregated values to be reported electronically to the Administration or recognised organisation within three months of the end of the calendar year. A gap you discover in March cannot be filled for that year.

The raw data behind the aggregate must be kept for 12 months

You submit aggregated values, but regulation 27.8 asks separately for what sits underneath.

8 … the disaggregated data that underlies the reported data noted in appendix IX to this Annex for the previous calendar year shall be readily accessible for a period of not less than 12 months from the end of that calendar year and be made available to the Administration upon request.

It must be readily accessible for at least 12 months after the end of the calendar year and produced on request. Now that Appendix IX is split by consumer and by not under way, the raw data has to survive at the same level of detail to satisfy this. Clearing out the original noon reports once the aggregate is done does not meet the requirement.

A change to Appendix IX is a change to SEEMP Part I

Regulation 26.2 requires the SEEMP of a ship of 5,000 gross tonnage and above to include a description of the methodology for collecting the data required by regulation 27.1 and the processes for reporting it to the Administration.

The fields you collect have changed, so the methodology written in the SEEMP has to change with them. If you have started filling in the new fields while the SEEMP still describes the old ones, the document and the practice are saying different things.

Regulation 26.3 applies on top for ship types subject to CII. Sub-paragraph .3 makes the SEEMP “subject to verification and company audits”. A document that disagrees with the practice is therefore something an audit finds.

The threshold is 5,000 gross tonnage

The wording of regulation 27.1:

1 From calendar year 2019, each ship of 5,000 gross tonnage and above shall collect the data specified in appendix IX to this Annex, for that and each subsequent calendar year or portion thereof, as appropriate according to the methodology included in the SEEMP.

“or portion thereof” is there because of regulations 27.4 and 27.5. When the Administration changes, the portion belonging to the previous Administration is reported at that date. When the company changes, the portion belonging to that company is reported at that date. If both happen at once, regulation 27.6 applies the Administration change rule. If a transfer of management is planned, organise the data so it can be cut at the transfer date.

What happens after reporting is also in the regulations. Regulation 27.9 requires the Administration to transfer the reported data to the IMO Ship Fuel Oil Consumption Database within one month of issuing the Statement of Compliance (SoC).

New paragraphs on data disclosure

The same resolution added paragraphs 14 and 15 to regulation 27.

14 On an ad hoc basis, the Secretary-General of the Organization may share data with analytical consultancies and research entities, under strict confidentiality rules.

15 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 lets the Secretary-General share data with analytical and research entities under strict confidentiality rules. Paragraph 15 makes the reports of a company’s owned ships available to the general public in non-anonymized form on the request of that company, so it only moves when the company asks.

What to check now

1. Whether the noon report or daily consumption record is split into main engine, auxiliary engines, boilers and others
2. Whether under way and in port consumption can be told apart (whether voyage start and end times are recorded)
3. Whether shore power received (kWh) is recorded, for ships that take it
4. Whether the data collection methodology in SEEMP Part I reflects the new Appendix IX fields
5. Whether your flag State or recognised organisation has asked for early application for 2025

Sources

• MEPC.385(81) (adopted 2024-03-22, in force 2025-08-01). Appendix IX replacement, new paragraphs 14 and 15 in regulation 27. Checked against MEPC.385(81).pdf, PDF pages 4-6 (document pages 3-5).
• MEPC.328(76) 2021 revised MARPOL Annex VI. Regulation 26 (SEEMP), regulation 27 (collection and reporting). Checked against MEPC.328(76).pdf, pp.45-46.
• The form and the date it applies from depend on the revision and on whether your flag State adopted early application. Submit on the basis of the current guidance from your flag State and recognised organisation.