Implementation (IM) Obligations

The adopted Audit Points for implementation obligations are based on the following template language: 

The CCM submitted a statement in AR Pt2 that:

  • confirms CCM’s implementation through adoption of a national binding measure that ensures {xxx};
  • describes how CCM is monitoring its vessels to ensure they do/do not {xxx}, and how potential infringements or instances of non-compliance with this requirement are handled.


There are typically three parts to Audit Points in this category, each of which needs to be clearly addressed in the response:

  • the nationally binding instrument
  • the monitoring regime
  • how potential infringements and detect non-compliance is handled

 

A specific legally binding instrument or type of instrument must be identified and in place or stated as intended to be in place and applicable within the Reporting Year. The intent is it must be in place before the event or activity in the obligation is allowed to occur.

 

Where an obligation is not yet implemented in law, information should be included to clarify the intended process and timeline. This situation will result in a potential compliance issue, but Capacity Assistance Needs can be requested in these circumstances to assist CCMs and streamline review at TCC and the Commission meetings.

 

The expected response does not require and may not be met by:

  • a report on whether non-compliance occurred or to describe the activity that occurred in the Reporting Year – this would be a response to the Reporting (RP) form of an obligation, not an Implementation (IM) form;
  • a response that none of the events/activities referred to in the obligation occurred– this would be a response to some types of the Reporting (RP) form of an obligation