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SEEMP Part III and the CII corrective action plan

The ship operational carbon intensity plan, in the IMO model form, with every figure worked through and sourced. Ready to edit in one working day.

Updated 2026-10-20

Example. A 63,500 dwt bulk carrier burning 4,000 t of heavy fuel oil and 450 t of gas oil over 33,000 nautical miles in 2026, with 75% of its fuel used on EU-related voyages, is rated E on the CII (attained 6.63 against a required 4.35), owes €659,979 in EU allowances at €85 each, and faces a FuelEU penalty of €146,456, or about €25,220 if the deficit is pooled.

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Fuel burned in the year (tonnes)
Nothing you enter is stored.

What SEEMP Part III is

Part III of the Ship Energy Efficiency Management Plan is the ship operational carbon intensity plan required by regulation 26 of MARPOL Annex VI for every ship that receives a CII rating. It sets out the method of calculating the CII, the required CII for the next three years, the measures that will meet it, the procedure for self-evaluation and improvement, and how the plan is verified. Its form is the model in Appendix 3 of the 2024 SEEMP Guidelines, resolution MEPC.395(82).

The corrective action plan

A ship rated D for three consecutive years, or E in a single year, must revise Part III with a plan of corrective actions: the causes of the rating, the measures to reach at least C in the following year, the person responsible and the timetable. It is submitted with, and no later than one month after, the attained CII is reported, and the Administration or recognised organisation verifies it.

What is in the plan we prepare

SectionContents
1 to 2Ship particulars and the calculation method: four steps with the IMO equations, symbols, carbon factors, and where each figure comes from
3Attained and required CII for the past and the next three years, with the rating
4Implementation plan: speed, routing, just-in-time arrival, hull and propeller, trim, auxiliary load and energy-saving devices, with the effect of each
5 to 6Self-evaluation, improvement and the corrective action plan where one is needed
AnnexesThe data used and its source, the information the company supplied, the worked calculation, and how the measures were combined

Parts I and II, and the 2025 change to the data collection plan

Resolution MEPC.385(81), in force since 1 August 2025, adds fuel consumption by consumer type, transport work and onshore power to the IMO DCS data. Part II, the fuel oil consumption data collection plan, has to describe how those data are measured, so most ships need a revised Part II. We prepare Parts I and II in the forms of Appendices 1 and 2.

Prices

DocumentReady to editPrepared with you
Part IIIUS$450US$1,450
Parts I and IIUS$350US$750
Parts I, II and IIIUS$650US$1,650

Ready to edit: built on your inputs within one working day, as Word and PDF. Prepared with you: on your verified data and noon reports, with one revision after the Administration's or recognised organisation's comments. Ten ships or more: 20% less.

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Questions

When is a SEEMP Part III corrective action plan required?

When a ship is rated D for three consecutive years or E in one year. It must be submitted with, and no later than one month after, the attained CII is reported.

Who verifies SEEMP Part III?

The Administration or the recognised organisation acting for it. CarbonKeel prepares the plan; it does not verify it.

What changed in SEEMP Part II in 2025?

Resolution MEPC.385(81), in force since 1 August 2025, adds fuel consumption by consumer type, transport work and onshore power to the IMO DCS data, so Part II has to describe how they are measured.

How long does it take?

A ready-to-edit plan is delivered within one working day of your inputs. A plan prepared with you depends on your data and the Administration's comments.

What does it cost?

US$450 ready to edit or US$1,450 prepared with you for Part III; US$650 or US$1,650 for Parts I, II and III together.

Check every ship in your fleet

EU ETS, FuelEU, CII and UK ETS for each ship, from the public register or your own data, with the reports for owners, charterers and lenders.

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