A SEEMP Part III Company Audit is a periodic audit required under MARPOL Annex VI Regulation 26.3.3 to verify that a company is effectively implementing and maintaining the Ship Energy Efficiency Management Plan (SEEMP) Part III, which supports compliance with the Carbon Intensity Indicator (CII) framework.

The requirement applies to ships:
-    5,000 GT and above
-    Engaged in international voyages
-    Subject to operational CII requirements under MARPOL Annex VI Regulation 28

Examples include tankers, bulk carriers, container ships, gas carriers, general cargo ships, ro-ro ships, cruise ships, and refrigerated cargo ships. 

A SEEMP Part III Company Audit must be conducted at least once every three years i.e. at least once for each 3-year implementation plan. 
The audit is to be conducted within 06 months from the issuance of the Statement of Compliance (SoC) for IMO DCS- CII data for the previous year i.e. between 01 June to 30 November. 

For example: For the audit to be conducted in 2026, the ships in the fleet must have received the SoCs for the reporting year 2025. The deadline for obtaining the SoCs was 31 May 2026. Hence, the period when the audit can be conducted is 01 June 2026 to 30 November 2026. 

The audit may be carried out by:

• The Flag Administration; or
• A Recognised Organization (RO) authorized by the Flag Administration. Hence, prior to conducting the audit, the RO should confirm the authorization or seek authorization from the Flag Administrations of the respective vessels of the company fleet, which fall within the audit scope.  

The Flag Administration remains ultimately responsible for compliance oversight. 

The SEEMP Part III came into force from 01 January 2023 with the 3-year implementation plan therein ending on 31 December 2025. The IMO DCS-CII data for these three years namely, for 2023, 2024 and 2025 was verified in 2024, 2025 and 2026 respectively. Hence, the first SEEMP Part III Company Audit could be conducted between 01 June 2024 to 30 November 2024 or between 01 June 2025 to 30 November 2025 or the last window available is between 01 June 2026 to 30 November 2026. 

Yes. As per Section 7.1 of MEPC.347 (78) indicates that the SEEMP Part III Company Audit may be combined with the ISM audit. However, the ISM audit should be falling within the window of the SEEMP Part III Company Audit i.e between 01 June to 30 November.

If the ISM audit is outside this window, concurrence of the respective Flag Administrations of the company fleet may be obtained to combine the audit. 

The scope of the SEEMP Part III Company Audit is defined in para 5.9 of MEPC.347(78), which consists of: 

• verify that the SEEMP for which the Confirmation of Compliance has previously been issued complies with regulation 26.3.1 and, in the case of non-compliance, require remedial action; 
• confirm that the ship is being operated in accordance with SEEMP part III, regardless of its rating; 
• verify the progress made in the (corrective) actions to be taken in the execution of the three-year implementation plan and the plan of corrective actions; 
• verify self-assessment and improvement of actions taken; and 
• verify the assignment of responsibilities related to the implementation and monitoring of measures. 

Yes. The scope of SEEMP Part III Company Audit is distinct from the ISM audit. Hence, verifying the SEEMP Part III and the COCs during the ISM audit does not imply that the SEEMP Part III Company Audit is completed. SEEMP Part III Company Audit has to be conducted to cover the applicable scope. 

However, the SEEMP Part III Company Audit may be combined with ISM audit as explained under Q.6. above. 

Companies should maintain evidence such as:
-    Approved SEEMP Part III.
-    Confirmation of Compliance (CoC) for each vessel under the audit scope.
-    Statement of Compliance (SOC) for the preceding year for the IMO DCS- CII data for each vessel under the audit scope. 
-    Annual attained and required CII calculations.
-    Voyage performance monitoring records.
-    Fuel consumption and operational data.
-    Internal reviews and management review reports.
-    Corrective action plans and implementation status.
-    Training and awareness records. 

Yes. Company audits are required regardless of the ship's CII rating. The audit focuses on implementation and management of the SEEMP Part III rather than solely on the rating achieved. 

The Master is likely to be required to show:

• a Shipboard Energy Efficiency Management Plan, (with a plan of corrective actions included – for a ship rated D for 3 consecutive years or rated E) and the associated Confirmation of Compliance; and
• a Statement of Compliance related to fuel oil consumption reporting and operational carbon intensity rating covering at least the last five years, as applicable.

Auditors may verify:
-    Root cause analysis of poor CII performance.
-    Defined corrective measures.
-    Realistic implementation timeline.
-    Assigned responsibilities.
-    Progress monitoring.
-    Evidence of effectiveness reviews. 

No. The primary focus is the company's management system and implementation framework. Shipboard verification may be undertaken when company audits are not satisfactory or if required by the Administration. 

Typical findings include:
-    Lack of evidence of monitoring CII performance.
-    Responsibilities not clearly assigned.
-    Failure to demonstrate effectiveness of implemented measures.
-    Incomplete implementation plans.
-    Missing corrective action follow-up.
-    Inadequate crew and shore staff awareness.
-    Insufficient management review records.

These are common industry observations derived from SEEMP audit practices

Best practices include:
-    Keep SEEMP Part III updated.
-    Monitor attained vs required CII regularly.
-    Document implementation of all energy efficiency measures.
-    Conduct periodical internal reviews / audits.
-    Ensure vessel and shore personnel understand their responsibilities.
-    Track corrective actions and improvement initiatives.
-    Maintain objective evidence supporting decisions and performance trends. 

No. A separate contract for this service must be signed by the client with LR

No. Whether the SEEMP Part III Company / shipboard Audit can be conducted physically or remotely depends upon the Flag instructions. If the Flag authorizes LR to conduct the SEEMP Part III Company / Shipboard Audit remotely, then there is no necessity for a physical audit. 

However, if the Flag does not allow the audit to be conducted remotely, a physical audit is the only option. 

Yes. However, this is subject to Flag authorisation to LR for conducting the same.