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The Ship Energy Efficiency Management Plan (SEEMP) has been introduced by the International Maritime Organisation (IMO) as a desire to develop a system approach to the problem of the increased CO2 emission level generated by the world fleet. The paper is an attempt to answer the question whether the Ship Energy Efficiency Management Plan (SEEMP) may be classified as a management system. It also comprises of a comparative analysis of the requirements included in the IMO guidelines regarding developing the SEEMP and the systems the most commonly encountered in navigation such as the System for Ship Safety Management and for Pollution Prevention, drawn up according to the ISM Code requirements, ISO 9000 and ISO 14000. The author, based on an analysis, specifies the characteristic and key elements for the management systems and indicates variances in the structure of these systems. The SEEMP weaknesses are also identified i.e. the deficiencies in ensuring the plan continuity, responsibilities for the actions mentioned in the plan, risk assessment. The analysis results show that the SEEMP does not meet the formal requirements for the management systems and therefore, in order to obtain the status of the management system, the SEEMP should be incorporated into the existing management systems or it should be completed with the missing elements mentioned in the paper. [ABSTRACT FROM AUTHOR]