IMO CII Compliance | VURDHAAN
IMO CII • Carbon Intensity Indicator

Manage IMO CII ratings before they manage your fleet.

The IMO Carbon Intensity Indicator (CII) rates ships annually from A to E based on operational carbon intensity. Poor ratings are no longer theoretical: they trigger corrective action plans, reputational risk, and commercial pressure. VURDHAAN helps operators actively manage CII—year after year.

MARPOL Annex VI
Annual A–E ratings
SEEMP Part III
Charterer scrutiny
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Annual Ship-level rating
A–E Performance bands
2023+ Tightening every year

What CII actually measures

CII evaluates how efficiently a ship transports cargo or passengers, using CO₂ emissions per transport work, based on:

  • Fuel consumption (from IMO DCS)
  • Distance travelled
  • Deadweight / GT (by ship type)

Key insight: CII is an operational performance metric—optimising it requires voyage planning, speed management, and fuel decisions throughout the year.

CII is an operational performance regime—not a reporting exercise.

Unlike annual reporting frameworks, CII ratings are calculated after the year ends—when operational decisions can no longer be changed. The time to manage CII is during the year, not after.

Problem

CII is calculated after the year ends—when operational decisions can no longer be changed.

Impact

D or E ratings require corrective action plans and attract scrutiny from charterers, financiers, and regulators.

Solution

Continuous monitoring, forecasting, and operational levers built into voyage and speed decisions.

IMO CII rating bands explained

Each ship receives an annual rating from A (best) to E (worst). The thresholds tighten each year, meaning yesterday's C rating might become a D rating tomorrow.

Rating Performance level Regulatory consequence Commercial impact
A Major superior performance None required Positive signal to charterers & stakeholders
B Minor superior performance None required Generally acceptable, good positioning
C Moderate performance None required Baseline compliance, neutral commercial impact
D Minor inferior performance Corrective action plan required (SEEMP) Increased scrutiny from charterers and banks
E Inferior performance Urgent corrective measures + flag state oversight Serious reputational and commercial risk

Ships receiving three consecutive D ratings (or D + E, or three E ratings) may face additional enforcement measures. This is not theoretical—it's a compliance trigger built into the regulation.

Operational levers that influence CII

CII can be managed through strategic decisions made throughout the year. The key is knowing which levers have the greatest impact on your specific ship types and trade routes.

Speed optimisation

Reducing speed in ballast or adjusting voyage speeds based on cargo deadlines can significantly improve CII ratings.

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Hull & propeller maintenance

Clean hulls and efficient propellers directly reduce fuel consumption per nautical mile, improving both CII and operational costs.

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Voyage planning & routing

Weather routing, current optimization, and port call efficiency all impact total fuel consumption and transport work ratios.

Port time management

Minimizing time at anchor or waiting at berth reduces fuel burn without corresponding transport work—a CII drain.

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Energy efficiency technologies

Wind-assisted propulsion, air lubrication, waste heat recovery—proven technologies that directly improve CII performance.

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Ballast voyage optimization

Ballast legs contribute fuel consumption but no cargo work—optimizing or reducing ballast time is critical for CII.

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Alternative fuels (future)

Biofuels, LNG, methanol, and ammonia can reduce CO₂ emissions intensity—some with immediate CII benefits, others positioning for future compliance.

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Cargo load optimization

Higher capacity utilization means more transport work per fuel consumed—a direct improvement to CII calculations.

The CII optimization challenge

CII isn't just about fuel efficiency—it's about the relationship between fuel consumed and transport work delivered. A ship can be very fuel-efficient but still receive a poor CII rating if it's operating with low cargo utilization or excessive ballast voyages.

This is why CII management requires cross-functional coordination: technical (fuel/speed), commercial (cargo booking), and operational (voyage planning) decisions all impact the final rating.

CII management maturity: where does your organization sit?

Most ship operators are somewhere between reactive (Level 1-2) and proactive (Level 4-5). Move the slider to see what each level looks like in practice.

1. Blind 2. Reactive 3. Monitored 4. Managed 5. Strategic

Level 2 — Reactive

CII calculated after year-end with limited ability to intervene. Corrective action plans are developed retrospectively when D or E ratings appear, but operational decisions for that year are already locked in.

How VURDHAAN helps you manage CII proactively

We help ship operators move from reactive year-end reporting to proactive in-year management—so CII becomes a managed KPI, not an annual surprise.

Baseline & forecast

Establish your fleet's CII baseline, forecast year-end ratings based on current operations, and identify vessels at risk of D or E ratings before it's too late.

Operational scenario modeling

Model the CII impact of speed changes, route adjustments, fuel switches, and cargo decisions—so you can make informed trade-offs during the year.

SEEMP Part III alignment

Develop corrective action plans that satisfy flag state requirements while actually improving operational performance (not just checking a compliance box).

Integration with IMO DCS

Use your existing DCS fuel consumption data as the foundation for CII tracking—no duplicate data collection, just smarter use of what you already report.

Charterer & stakeholder communication

Prepare clear narratives and data for charterers, banks, and ESG stakeholders who increasingly ask about CII performance as part of commercial negotiations.

Fleet-level strategy

Identify which vessels are CII-vulnerable, which operational changes deliver the biggest rating improvements, and where capital investments (retrofits, technologies) make commercial sense.

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Let's discuss your fleet's CII profile and build a practical management approach for 2024 and beyond.

CII timeline & key deadlines

Understanding the annual CII cycle helps you plan interventions at the right time.

January 1 – December 31

Operational year: Collect fuel consumption data (IMO DCS), track distance travelled, and monitor transport work. This is when operational decisions (speed, routing, cargo utilization) actually influence your CII rating.

Q1 (Year +1): January – March 31

IMO DCS submission deadline (March 31): Verified fuel consumption report submitted. This data feeds directly into CII calculation, so errors or delays here impact your rating.

Q2 (Year +1): CII Rating Issued

Official rating published: Ships receive their A–E rating from the flag state. D and E ratings trigger mandatory corrective action plan requirements (SEEMP Part III).

Throughout the year: Proactive monitoring

The key to CII success: Don't wait for the official rating. Track your projected CII monthly or quarterly, and make operational adjustments during the year when you can still influence the outcome.

The best time to manage CII is before the rating is fixed.

Let's move CII from a year-end surprise to a managed operational metric. Contact us to discuss your fleet's CII profile and build a practical management approach.

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No lengthy forms—just a direct conversation with our team.

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IMO CII