Introduction:

As fleet transitions accelerate across the industry, vessel takeovers demand meticulous attention to regulatory continuity. Missing or delayed compliance documentation can cascade into certification risks, operational disruptions, and exposure to penalties—especially under IMO DCS and EU frameworks. This guide outlines the essential records and plans to secure from previous owners/managers and to prepare with your Recognized Organization (RO) prior to takeover, ensuring uninterrupted compliance into 2025 and beyond.
Why this matters now
* Certification timelines are tightening: Verified fuel consumption and statements of compliance underpin 2025 certifications under IMO DCS.
* EU oversight is expanding: EU MRV and FuelEU Maritime requirements apply for voyages touching EU ports and waters, with partial-year statements critical at change-of-management.
* Data integrity is key: Raw voyage data and supporting evidence (BDN, cargo docs) are increasingly scrutinized.

Preparation of plans

Once the takeover is confirmed, the following two plans to be prepared and to be approved by the Recognized Organization (RO)

1. SEEMP Part II

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2. SEEMP Part III

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Ensure that these plans are well within the frame work of the company SEEMP Part 1. In addition both the plans to be in line with the 2024 guidelines.

Post-takeover , evaluate the trading pattern of the vessel and prepare and get approvals for

3) EU MRV Monitoring Plan, if the vessel is planned for EU voyages.


4) Fuel-EU Maritime plan, if the vessel is planned for EU voyages.

Historical compliance documents

The core documents to obtain from the previous vessel operator under each reporting regime are as follows:

IMO DCS :
1. Previous years Statement of Compliance (SoC) and verified Fuel Oil Consumption Reports ( FOCR)

2. Statement of Compliance and verified Fuel Oil Consumption Report till the date of takeover.

Both are essential to ensure timely certification of the vessels in  and to avoid gaps in annual reporting continuity.
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EU MRV and Fuel-EU Maritime (applicable if the vessel has EU voyages in previous and current reporting year)


a) EU MRV Document of Compliance for 2024 (if applicable).


b) Verified partial EU MRV statement up to the takeover date for 2025.

c) Verified partial compliance statement for Fuel-EU Maritime up to the takeover date for 2025.


d) EU MRV raw voyage data, including Bunker Delivery Notes (BDN) and cargo supporting documents.

e) In case vessel has not had any voyages under MRV/Fuel-EU scope till date of take over, a no EU Voyage declaration to be obtained.

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These items provide traceable evidence of monitoring, reporting, and verification across the management handover, and ensure accurate aggregation of annual emissions and energy metrics.

Verification of equipment and associated documents

With revisions in the SEEMP2 bringing in additional granularity and added focus to the reporting of fuel consumption from individual consumers , it is recommended to check :

* The details of the fuel measuring instruments such as flow meters and other tank level gauging systems.

* Sight and ensure availability of type approvals for the measuring instruments.

* Establish maintenance routines for these instruments in line with maker recommendations.

* Ensure calibrations are done and certificates available as per maker recommended intervals.

Practical steps to ensure smooth transition

* Define a cut-off date : Agree in writing, say as part of the MOA for the take over, for obatining all required certification from previous operators.

Request auditor confirmations: Where possible, obtain verification body sign-off for partial-year statements to avoid rework.

* Standardize data formats: Ensure MRV raw data (voyage logs, BDNs, cargo documentation) arrive in machine-readable formats consistent with your reporting systems.

* Cross-check identifiers: Confirm IMO number, company IDs, reporting period references, and voyage boundaries match between DCS, MRV, and FuelEU datasets.

* Maintain an audit trail: File correspondence and versioned documents centrally for future Port State Control or verifier queries.
Conclusion

Conclusion:

A disciplined approach to document collection and plan approvals at takeover safeguards certification timelines and operational flexibility. By securing verified partial-year statements, raw evidence, and RO-approved plans ahead of the handover, owners and managers can maintain compliance continuity and minimize regulatory risk.
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