3.

The three-year implementation plan should be monitored and adjusted when necessary, and the
data to be monitored, identified.

PLAN OF CORRECTIVE ACTIONS

A plan of corrective actions is not required to be included in the SEEMP unless a ship has been rated D
for three consecutive years or E for one year.

For a ship that is required to develop a plan of corrective actions in accordance with regulation 28.7 of
MARPOL Annex VI, a revised SEEMP including the corrective actions for CII reduction shall be submitted
to the Administration or any organization duly authorized by it for verification in accordance regulation
28.8 of MARPOL Annex VI. The revised SEEMP should be submitted together with, but in no case later
than one month after reporting the attained annual operational CII in accordance with regulation 28.2.

Regulation 28.9 of MARPOL Annex VI further provides that "A ship rated as D for three consecutive
years or rated as E shall duly undertake the planned corrective actions in accordance with the revised
SEEMP."

DEVELOPING THE PLAN OF CORRECTIVE ACTIONS

The purpose of the plan of corrective actions is to set out what actions a ship that was rated D for three
consecutive years or E for one year should take to achieve at least a C rating for the calendar year
following the adoption of the plan of corrective actions and ultimately the required annual operational
CII.

The plan of corrective actions is ship-specific.

The plan for corrective action should describe the actions that the ship plans to take, the timeline in which
those actions will be applied, and the expected impact their application will have on the ship's CII rating.

It should be demonstrated how the corrective actions will contribute to achieving the required annual
operational CII, so as to ascertain the effectiveness of the corrective actions. Experience gained from
previously taken corrective actions and their degree of effectiveness should be taken into account when
selecting the proper corrective actions.

The plan of corrective actions should be SMART (Specific, Measurable, Achievable, Realistic, and Time-
bound). It should include:
▪ an analysis of the cause of the inferior CII rating;

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▪ an analysis of the performance of implemented measures;
▪ a list of additional measures and revised measures to be added to the implementation plan with time
and method of implementation necessary for achieving the required operational CII;
▪ designation of a company person to be responsible for the added and revised measures in the
implementation plan, monitoring and recording performance throughout and reviewing of the
effectiveness of the corrective actions; and
▪ identification of possible impediments to the effectiveness of the measures for improving the energy
efficiency and reducing the carbon intensity of the ship, including possible additional contingency
measures put in place to overcome and how these impediments will be overcome.

The implementation of the plan of corrective actions should be monitored and adjusted when necessary.
Additional measures should be taken to strengthen corrective actions in case of insufficient intermediate
results.

The company should ensure that it is in a position to perform the actions set out in the plan of corrective
actions and confirm that it is able to do so when submitting its updated SEEMP.

THE CII AND SEEMP III TIMELINE IN SHORT

YEAR DATE ACTION
2022 31/DEC Initial Verification: Issuance of the Confirmation of Compliance (CoC)
Start of CII Year 2023 (Updated SEEMP in place; Confirmation of Compliance (CoC)
01/JAN
in place)
2023 30/NOV Deadline for Company audits, if conducted
31/DEC End of CII Year 2023

01/JAN Start of CII Year 2024

31/MAR Deadline for submission of 2023 CII for verification

For ships rated E in 2023, only
30/APR Deadline for submission of Corrective Action Plan to be implemented in 2024 and
2025
Additional verification, if applicable
2024 31/MAY
Deadline for issuance of SoC for 2023 (valid until 31 May 2025)
30/JUN Deadline for transfer of 2023 data to DCS

30/NOV Deadline for Company audits, if conducted

31/DEC End of CII Year 2024

01/JAN Start of CII Year 2025

31/MAR Deadline for submission of 2024 CII for verification

For ships rated E in 2024, only

2025
Deadline for submission of Corrective Action Plan to be implemented in 2025 and
30/APR
2026 (at the discretion of the Administration to require a new Corrective Action
Plan or previous one can be continuously implemented)

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 Deadline for issuance of Statement of Compliance for 2024 (valid until 31 May
31/MAY
2026)
30/JUN Deadline for transfer of 2024 data to DCS

30/NOV Deadline for Company audits, if conducted

Periodical verification: Issuance of the Confirmation of Compliance (CoC) for

31/DEC updated SEEMP related to upcoming three-year period.
End of CII Year 2025
Start of CII Year 2026 (Updated SEEMP in place; Confirmation of Compliance (CoC)
01/JAN
in place)
31/MAR Deadline for submission of 2025 CII for verification

For ships rated D in 2023-2025 or E in 2025, only

Deadline for submission of Corrective Action Plan to be implemented in 2026 and
30/APR 2027 (at the discretion of the Administration whether a new Corrective Action Plan
is required or the previous one can be continuously
implemented)
2026
31/MAY Deadline for issuance of SoC for 2025 (valid until 31 May 2027)

30/JUN Deadline for transfer of 2025 data to DCS

30/NOV Deadline for Company audits, if conducted

Periodical verification: Issuance of the Confirmation of Compliance (CoC) for

31/DEC updated SEEMP related to upcoming three-year period
End of CII Year 2026

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