Beginning in 2026, site visits become a core regulatory requirement for both the EU MRV (CO₂ monitoring) and FuelEU Maritime (GHG intensity reduction) schemes. These visits, whether physical or virtual, ensure that a company’s monitoring and reporting processes are implemented correctly as described in the approved Monitoring Plan (MP).
With EU Regulations 2023/2917 (MRV) and 2024/2027 (FuelEU) fully defining the requirements, companies should already be preparing for verification activities that will directly impact compliance and operational planning.
Why Site Visits Matter
Both MRV and FuelEU require the verifier to obtain reasonable assurance that the ship’s monitoring plan is correctly implemented. Site visits, either at the company’s office or the vessel, allow the verifier to:
- Understand the monitoring and reporting procedures
- Validate data-flow and control processes
- Confirm that the MP is implemented exactly as described
- Ensure that reported fuel, voyage, and emissions data is accurate
Importantly, verification cannot be completed without a valid site visit, meaning non-compliance may lead to the withholding of compliance documents, potential fines, or PSC issues.
Physical vs Virtual Site Visits
According to both regulations, site visits may be conducted through:
Physical Site Visit:
- Performed at the vessel, company office, or another relevant location where data processing occurs
- Does not always require boarding the vessel
- Often preferred when procedures are complex or when a verifier is engaging with a ship for the first time
Virtual Site Visit:
Allowed only when at least one of the following is true:
- The verifier already has a sufficient understanding of the monitoring system
- The system is not complex, and physical verification adds no value
- All required information can be reliably reviewed remotely
- Extraordinary circumstances prevent physical access
Waiving a Site Visit:
A site visit may be waived only when the verifier already has sufficient understanding of the ship’s monitoring and reporting system, the system is not complex enough to require a physical visit, and all necessary information can be fully assessed remotely.
A waiver is not permitted:
- When the verifier is assessing a ship’s monitoring plan for the first time
- When the MP has been significantly modified during the reporting period
How Often Are Site Visits Required?
From 2024 onward, the following principles apply:
- A physical site visit is required at least once every 4 years
- A visit (physical or virtual) is required at least every 2 years if waivers are used
- A physical site visit is required if no such visit took place in the previous 3 reporting periods
- A virtual site visit does not reset the 4-year cycle for physical visits
- For FuelEU, 2025 is the first reporting year, so, no physical site visit can be waived for a vessel assessed for the first time
- If the company has no EU voyages in 2025, no site visit is required yet
Practical Recommendation
Most verifiers suggest scheduling physical site visits every three years, ensuring continuity and avoiding the need for ad-hoc virtual visits or last-minute compliance actions.
Where permitted by flag requirements, companies may combine:
- EU MRV
- FuelEU Maritime
- SEEMP audits (i.e., DCS verification under IMO)
This must be done by an EU-accredited MRV/FuelEU verifier.
What Happens During a Site Visit?
The verifier determines:
- Location(s) (office, technical department, onboard, or remote)
- Scope based on where data is stored and processed
- Activities such as interviews, system demonstrations, and document sampling
Typical areas assessed include:
- Data collection from noon reports, flow meters, sensors
- Fuel consumption measurement methods and procedures
- Voyage definitions and reporting practices
- Data transfer and IT systems (e.g., performance platforms, EMS)
- Roles, responsibilities, and control mechanisms
- Change management (especially for MP modifications)
Typical Time Needed
- Minimum: 1 day for a small fleet or a simple MRV-only scope
- Additional time for:
- Large or complex fleets
- ISM / SEEMP integration
- ISO 50001 involvement
Who Is Responsible?
| Scheme | Responsible Party |
|---|---|
| EU MRV | Registered owner, unless delegated to ISM company |
| FuelEU | Always the ISM company |
This distinction is crucial when planning audits across multi-managed fleets.
Consequences of Non-Compliance
Failure to conduct a required site visit may result in:
- Inability to issue verification statements
- Inability to submit compliant MRV or FuelEU reports
- FuelEU non-compliance penalties (potentially very significant)
- Port State Control action, including detention
- Commercial impacts (e.g., charterparty obligations, sustainability ratings)
Confirmation of Physical Site Visit
After a successful physical visit, the verifier may issue a Confirmation of Physical Site Visit, valid for three years.
If a virtual site visit is conducted, the next physical visit may be postponed by one year, but only once per four-year cycle.
Practical Guidance: How to Prepare
Before the Visit
- Review and update the Monitoring Plan (MP)
- Ensure all procedures reflect actual practice
- Validate your dataflow maps and control mechanisms
- Prepare evidence (fuel records, voyage logs, BDNs, EMS exports, etc.)
- Ensure critical personnel are available
During the Visit
- Demonstrate systems used for data collection and reporting
- Walk through real voyages and fuel transactions
- Provide access to IT systems or data sources
- Show how corrections, deviations, or anomalies are handled
After the Visit
- Implement any corrective actions promptly
- Review internal procedures and training needs
- Update monitoring systems if necessary
- Confirm the issuance of the physical site visit certificate (if applicable)
Summary
✓ Check when your last physical site visit occurred
✓ Confirm whether your Monitoring Plans need updates for 2024–2025
✓ Schedule the next physical visit in line with the 3-year best practice
✓ Plan combined audits (MRV/FuelEU/SEEMP) where beneficial
✓ Prepare documentation and personnel well ahead of verification deadlines
References
Commission Delegated Regulation (EU) 2023/2917
Commission Implementing Regulation (EU) 2024/2027