DNV has issued new guidance on site visit procedures and compliance responsibilities for all vessels falling under the EU Regulations 2023/2917 (EU MRV) and 2024/2027 (FuelEU Maritime), ahead of the first FuelEU verification year in 2026.
Purpose and Types of Site Visits
The core purpose of the site visit is for the verifier to gain a sufficient understanding of the company’s and vessel’s monitoring and reporting systems and procedures outlined in the Monitoring Plan (MP).
- Format and Scope: Site visits can be either physical or virtual, but they must cover the same scope and purpose. A physical visit is mandatory at least once every 4 years.
- Location: The verifier chooses the location based on where relevant data is stored and where dataflow and control activities occur. A physical site visit does not necessarily require boarding the ship; it can be held at the ISM company’s main office or another relevant location.
Frequency of Site Visits
The requirements for the frequency of site visits for both EU MRV and FuelEU reports are as follows:
- Physical Visit Minimum: A physical site visit is required at least once every 4 years, starting in 2024.
- Waiver Limits: A site visit can be waived for a maximum of 2 consecutive years within the 4 years, after which a physical or virtual visit must be carried out in the third year.
- Initial Verification: Site visits cannot be waived if the verifier has never verified the report for a vessel before. This means a site visit is mandatory for the 2025 FuelEU reports.
- Virtual vs. Physical: Conducting a virtual site visit does not replace or waive the requirement for a physical site visit within the 4-year cycle.
| DNV Recommended Approach | Rationale |
| Schedule a physical company-level site visit every three years. | This minimizes customer effort and avoids the need for a mandatory virtual site visit that would be triggered if the minimum four-year physical requirement were chosen. |
| Combine EU MRV/FuelEU site visits with ISM company audits (recommended every third year) and/or SEEMP company audits. | This optimizes resources and time. |
Compliance and Consequences
- Compliance Responsibility:
- EU MRV: Responsibility lies with either the registered owner or the ISM company (if mandated).
- FuelEU Maritime: Responsibility lies solely with the ISM company.
- Non-Compliance: The site visit is a prerequisite for a successful FuelEU report verification. Failure to complete site visits may result in final compliance documents not being issued, fines, and Port State Control (PSC) detentions.
DNV recommends scheduling a site visit early on, ideally before the March 31, 2026 verification deadline, or even sooner in 2025, and combining it with other planned audits to optimize resources.
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Source: Safety4sea
