Abstract. Photogrammetry is a valuable tool for 3D documentation, mapping, and monitoring of underwater environments. However, the ground control surveys necessary for georeferencing and validation of the reconstructed bathymetry are difficult and time consuming to perform underwater, and thus impractical to scale to larger areas. Underwater direct georeferencing, using a differential GNSS receiver synchronized with an underwater camera system, offers an attractive alternative to surveying underwater ground control points in conditions when the seafloor is clearly visible from the surface. In this paper, the design of an underwater direct georeferencing system using mostly commercial off the shelf components is presented. The accuracy of the system is evaluated against geodetic survey based on trilateration and leveling, as well as by RTK (real time kinematic) positioning using a tilt-compensated GNSS receiver mounted on an extended pole to allow measurements of points in up to 7 m in water depth. Tests were conducted in a controlled outdoor pool setting with depths from 1–3 m, as well as in a 10 m × 10 m test plot established on the seafloor in a near-shore environment by Catalina Island, California at depths from 4–10 m. Comparing the geometry of the photogrammetric reconstruction with the geodetic survey yielded sub centimeter consistency, and 1 mm accuracy in length measurement was achieved when compared with calibrated 0.5 m scale bars. Through repeated surveys of the same area, repeatability of georeferencing is demonstrated within expectations for differential GNSS positioning, with horizontal errors at sub centimeter level, and vertical errors of up to 3 cm in the worst cases. These tests demonstrate the benefits of the underwater direct georeferencing approach in shallow waters, which can be scaled up much more easily than measuring underwater ground control points with traditional approaches, making this an ideal option for collecting accurate bathymetry of the seafloor over large coastal areas with clear waters.