Maritime compliance: SOLAS amendments and relevant codes update


( A set of amendments to the International Convention for the Safety of Life at Sea (SOLAS) and the associated Codes are lined up below to assist Owners and Managers on compliance.

Fuel sampling

MSC 108, having noted that MEPC 81 further modified the guidelines prepared by MSC 107, approved MSC-MEPC.2/Circ.18 on Guidelines for the sampling of fuel oil for determination of compliance with MARPOL Annex VI and SOLAS chapter II-2.

The circular provides a single unified sampling method for both SOLAS (flashpoint) and MARPOL (sulphur contents) and increases the amount of sample from 400ml to 600ml, and revokes resolution MEPC.182(59) on 2009 Guidelines for the sampling of fuel oil for determination of compliance with the revised MARPOL Annex VI.

Adoption of mandatory instruments

MSC 108 adopted various instruments introduced below.  Expected entry into force (EIF) date is also indicated.

SOLAS Convention

Chapter II-1 on Emergency Towing Arrangements (EIF 1 January 2028) (resolution MSC.549(108))

This amendment is on SOLAS regulation II-1/3-4 in relation to new requirements for all new ships other than tankers of not less than 20,000 GT to be fitted with emergency towing arrangements.  Tankers have been required to meet the requirements, but these amendments expand the application to other ship types, while the technical requirements of the towing arrangements may differ from those for tankers.

Associated guidelines are currently being developed by the Sub-Committee on Ship Design and Construction (SDC).

Chapter II-2 on (EIF 1 January 2026) (resolution MSC.550(108))

The amendments include regulations II -2/4, 7, 9, 20 and 23 on oil fuel parameters other than flashpoint for safe operation and fire safety of ro-ro passenger ships, as well as fixed fire detection and alarm systems in control stations and cargo control rooms.  Some of the requirements apply to both new and existing ships.

Associated circular

In this regard, MSC 108 also approved MSC.1/Circ.1456/Rev.1 on Revised unified interpretations of SOLAS chapter II-2 and the FSS and FTP Codes.

Chapter V on reporting of lost container (EIF 1 January 2026) (resolution MSC.550(108))

Following the adoption of the amendments to the similar provision in the MARPOL Convention by MEPC 81 by resolution MEPC.384(81), the SOLAS part (regulation V/31 and V/32) was adopted by MSC 108.  The requirements apply to both new and existing ships.

MSC 108 noted that further clarification on possible duplication was needed for the Nairobi Shipwreck Convention, which will be addressed by the IMO’s Legal Committee.

IGF Code (EIF 1 January 2026) (resolution MSC.551(108))

The amendments include several interpretations on airlocks, relief valves, tank pressure, bunkering arrangements etc., for new ships and requiring a portable fire-extinguisher in fuel preparation room, which apply to both new and existing ships.

Associated Circular

In this regard, MSC 108 also approved MSC.1/Circ.1677 on Voluntary early implementation of the amendments to paragraphs 4.2.2 and 8.4.1 to 8.4.3 of the IGF Code.

Grain Code (EIF 1 January 2026) (resolution MSC.552(108))

The amendments introduce a new class of loading conditions for "specially suitable compartment, partly filled in way of the hatch opening, with ends untrimmed" and specify the requirements under which grain may be safely carried in such compartments.  The amendments apply to both new and existing ships.

ESP Code (EIF 1 January 2026) (resolution MSC.553(108))

The amendments modify the procedures for approval and certification of a firm engaged in thickness measurement of hull structures in the annexes of the International Code on the Enhanced Programme of Inspections during Surveys of Bulk Carriers and Oil Tankers (ESP Code) by clarifying that approval can be undertaken by the recognized organizations or flag Administration itself.  The amendments apply to both new and existing ships.

LSA Code (EIF 1 January 2026) (resolution MSC.554(108))

The amendments include chapters II, IV and VI of the LSA Code concerning the in-water performance of lifejackets; single fall and hook systems; and lowering speed (introduction of maximum lowering speed of 1.3 m/s in addition to the minimum lowering speed of 1.0 m/s) of survival craft and rescue boats.  The application criteria are:

(a) for ships for which the building contract is placed on or after 1 January 2026, or in the absence of the contract, the keels of which are laid or which are at a similar stage of construction on or after 1 January 2026, all installations of the specified type on board those ships; or

(b) for ships other than those ships specified in (a) above, all installations of the specified type, having a contractual delivery date for the equipment or, in the absence of a contractual delivery date to the ship, actually delivered to the ship on or after 1 January 2026.

Associated resolution and circular

In this regard, MSC 108 also adopted amendments to the Revised recommendation on testing of life-saving appliances (resolution MSC.81(70)) by resolution MSC.563(108) and MSC.1/Circ.1628/Rev.2 on Revised standardized life-saving appliance evaluation and test report forms.

Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear (resolution MSC.402(96)) (EIF 1 January 2026) (resolution MSC.559(108))

Paragraph 6.2.3 of resolution MSC.402(96) was amended to accommodate the new ventilation requirements for totally enclosed lifeboats introduced by the amendments to the LSA Code (resolution MSC.535(107)), to include "ventilation system, where fitted" in the items of annual thorough examination and operational test.

FSS Code (EIF 1 January 2026) (resolution MSC.555(108))

The amendments are to chapters 7 and 9 of the FSS Code concerning fire safety of ro-ro passenger ships, including specification of linear heat detection systems.  The amendments apply to new ro-ro passenger ships.

IMDG Code (EIF 1 January 2026) (resolution MSC.556(108))

MSC 108 adopted amendments (42-24).  Key changes are:

  • Inserting editorial clarification in paragraph of the IMDG Code that the required stowage arrangements are to prevent the listed phenomena;
  • Clarifying that a stowage plan can be an alternative to a special list or a manifest;
  • Carriage of various types of batteries and battery-powered vehicles;
  • Carriage of various carbons;
  • Clarifying documentation when an exemption is granted under a special provision; and
  • Clarifying competent authority in special provision SP964.

Associated Circular

In this regard, MSC 108 also approved MSC.1/Circ.1588/Rev.3 on Revised emergency response procedures for ships carrying dangerous goods (EmS Guide).

Coating related Performance standards (EIF 1 January 2026) (resolutions MSC.557(108) and MSC.558(108))

The following instruments were revised to reflect the change of name from NACE International to the Association for Materials Protection and Performance Inc. (AMPP):

  • Performance standard for protective coatings for dedicated seawater ballast tanks in all types of ships and double side skin spaces of bulk carriers (resolution MSC.215(82)); and
  • Performance standard for protective coatings for cargo oil tanks of crude oil tankers (resolution MSC.288(87)).

Associated Circulars

In this regard, MSC 108 also approved:

  • MSC.1/Circ.1330/Rev.1 on Guidelines for maintenance and repair of protective coatings; and
  • MSC.1/Circ.1399/Rev.1 on Guidelines on procedures for in-service maintenance and repair of coating systems for cargo oil tanks of crude oil tankers.

STCW Code (EIF 1 January 2026) (resolution MSC.560(108))

Table A-VI/1-4 (Specification of minimum standard of competence in personal safety and social responsibilities) was revised to address prevention of and response to violence and harassment, including sexual harassment, bullying and sexual assault bullying and harassment, including sexual assault and sexual harassment.

STCW-F Convention and New STCW F Code (EIF 1 January 2026) (resolutions MSC.561(108) and MSC.562(108))

The Convention was comprehensively reviewed with recent development of various technologies and standards.  A new STCW-F Code was introduced.

Associated Circular

In this regard, MSC 108 also approved MSC.1/Circ 1678 on Guidelines on the medical examination of fishers.


Maritime Autonomous Surface Ships (MASS)

MSC 108 reviewed the work of the correspondence group (CG), the Intersessional Working Group (ISWG) and the FAL-LEG-MSC joint working group (JWG), and submission papers.  Key development during the session is captured hereunder.

Network Governance

MSC 108 reviewed the document submitted by Liberia and co-sponsoring Member States about the need for network governance for MASS, similar to that for GMDSS.  Opinions at MSC 108 was divided whether it is time to consider network governance similar to GMDSS, or leave it to each operating company and the flag Administration.  MSC 108, noting that exact data needed has not established yet, decided to keep the issue on hold until the non-mandatory MASS Code is completed.

High-Speed Craft

MSC 108 agreed not to develop provisions for high-speed craft in the MASS Code for inclusion in the non-mandatory Code, as the current work is supplemental/complemental to the SOLAS Convention, while the HSC Code is an independent stand-alone instrument.

Government ships

MSC 108 also agreed that the MASS Code will not apply to government owned/operated MASS.

Oversight of Remote Operation Centre (ROC)

Liberia and co-sponsoring Member States submitted a proposal on the oversight mechanism for ROCs.  MSC 108 noted that the majority view at the WG was that, regardless of whether to use the Remote Operation Management (ROM) concept or solely the ISM Code, there was a need for an oversight mechanism for ROC. This mechanism should include certification by the flag Administration and the company (ship operator/owner). The ROM concept might be a solution to bridge the gap in responsibility among the ship, ROC, and company, ensuring effective oversight by the flag State.  Additionally, it may provide a solution for situations where one ROC manages ships for multiple (ISM) Companies.

MSC 108 further noted that the Group had agreed that responsibility for the safe operation of MASS remained with the ISM Company but that the ROM concept should be retained as a complementary alternative ISM Code scheme of certification for the safe operation management of the ROC.

While MSC 108 agreed that connectivity between MASS and ROC should be independent of the radio communication requirements, there was no clear agreement on how to handle situations when the connection is lost.  The matter will be discussed further.

Safety of Navigation

MSC 108 further clarified that the MASS Code does not supplement nor modify COLREGs.

MASS trials with officer of navigational watch acting as sole lookout in periods of darkness

MSC 108 instructed the Sub-Committee on Human element, Training and Watchkeeping (HTW) to examine the proposals for allowing one watch standard on MASS.

Revised roadmap

MSC 108 agreed to revise the target as follows:

  • Completion of non-mandatory MASS Code will be MSC 110 (June 2025); and
  • Completion of mandatory MASS Code will be later than MSC 111 and will look into entry into force on 1 January 2032, which will make final adoption in spring 2030 at the latest.

GHG emissions from ships using new technologies and alternative fuels

This work was approved by MSC 107 to address a safety regulatory framework to support the reduction of GHG emissions from ships using new technologies and alternative fuels.

Seafarer training

MSC 108 endorsed the decision of the HTW Sub-Committee to proceed with the development of training provisions for seafarers on ships using alternative fuels.  In addition, MSC 108 agreed that there should be ship-specific training.

Onboard Carbon Capture and Storage (OCCS)

MSC 108 considered the proposal to develop non-mandatory safety guidelines related to Onboard Carbon Capture and Storage (OCCS).  However, while recognizing the merit of this proposal, agreed that at this stage it would be prudent to first complete the work of developing a road map and agreed to recommend that this proposal be kept in abeyance.

Other technologies

Other technologies identified were:

  • Supercapacitor energy storage;
  • Nuclear power as an alternative fuel; and
  • Wind propulsion and wind assisted power.


MSC 108 further updated available fuel list.  With regard to the fuel that may be regulated by the IGF Code, MSC 108 noted that clarification was needed whether the Code should address all hazardous fuels regardless of the flashpoint.

Further work

MSC 108 confirmed that the work under this output must be fuel/technology neutral, meaning that IMO must not choose/push a solution.  Nevertheless, MSC 108 developed the List of alternative fuel) and Details on alternative fuels and technologies for further review as live documents.

The following will be discussed by the correspondence group which will be reported to MSC 110 scheduled for June 2025.

  • To develop recommendations to address each of the identified barriers and gaps in current IMO instruments that impede the safe use of an alternative fuel or new technology;
  • for instruments causing barriers, to ensure that each recommendation clearly states which IMO instrument is proposed to be amended; and
  • for gaps in the regulations, to ensure that each recommendation clearly states either which IMO instrument is proposed to be amended, or provides the scope, nature and purpose of any new instrument that is recommended for development to fill the gap.

Cyber risk management and cybersecurity

MSC 98 approved the Guidelines on maritime cyber risk management (MSC-FAL.1/Circ.3) and subsequently, MSC 104 approved Rev.2 of MSC-FAL.1/Circ.3.  By resolution MSC.428(98), MSC also affirmed that an approved safety management system should take into account cyber risk management in accordance with the objectives and functional requirements of the ISM Code.

MSC 108 approved the draft revised Guidelines on maritime cyber risk management (MSC-FAL.1/Circ.3/Rev.3).  The key future of the revised guidelines are:

  • Inclusion of clear reference to Computer Based System (CBS),role of subcontractors, MASS;
  • Stressing that cyber resilient security features should be incorporated in the ship's equipment and systems at the design, manufacturing, integration, operation and maintenance stages;
  • Adding type and operational profile as well as onboard systems' complexity and connectivity in the risk assessment;
  • Additional cybersecurity measures; and
  • Additional reference includes IACS Unified Requirements UR E 26 (Cyber resilience of ships) and E 27 (Cyber resilience of onboard systems and equipment).

Maritime security

Security in the Southern Red Sea and Gulf of Aden

Following intense discussion, MSC 108 adopted MSC resolution MSC.564(108) on the Security situation in the Red Sea and Gulf of Aden resulting from Houthi attacks on commercial ships and seafarers.  The resolution, among others:

  • extends deepest condolences to the families of those seafarers who lost their lives;
  • demands the Houthis immediately cease attacking commercial ships;
  • deplores the Houthis' illegal seizure of the M/V Galaxy Leader and URGES for the immediate and unconditional release of the M/V Galaxy Leader and its crew;
  • underscores the paramount importance of preserving the safety and welfare of seafarers and urges Member States and observer organizations to provide maximum assistance to seafarers affected by the Houthis' reckless actions;
  • encourages operators and vessels to carefully assess the nature and unpredictability of recent events, as well as the potential of continued Houthi attacks, when considering their current and imminent transit plans, based on vessel profile, business need and risk tolerance; and
  • encourages all parties to provide relevant information to IMO as appropriate.

Piracy and armed robbery against ships

The IMO Secretariat reported on developments related to piracy and armed robbery against ships since MSC 107.

MSC 108 noted that the areas most affected by acts of piracy and armed robbery against ships in 2023 were the Straits of Malacca and Singapore (85), West Africa (22), South China Sea (14) and South America (Pacific) (14), followed by Indian Ocean (5), South America (Caribbean) (4), Arabian Sea (2), East Africa (2), South America (Atlantic) (1) and Mediterranean Sea (1) (paragraph 4).

Unsafe mixed migration by sea

MSC 108 recalled that MSC 106, having considered a relevant proposal, had adopted resolution MSC.528(106) on Recommended cooperation to ensure the safety of life at sea, the rescue of persons in distress at sea and the safe disembarkation of survivors.

Following the discussions at MSC 106 and MSC 107, Liberia, along with a co-sponsoring Member State, presented a draft FAL-MSC Circular to provide guidance to stakeholders on the proper handling of deceased persons among migrants rescued at sea. While there was general support for the proposal, there were further suggested editorial improvements and disagreements regarding references to the SAR Convention and the IAMSAR Manual.

MSC 108 invited Member States and international organizations to submit a revised proposal to MSC 109.

Outcome of the Sub-Committee on Navigation, Communications and Search and Rescue (NCSR)


Following the consideration of the paper by Liberia and the co-sponsor, MSC 108:

  • agreed that NAVDAT implementation should not entail replacement of shipborne NAVTEX receivers with NAVDAT receivers; and
  • instructed the NCSR Sub-Committee to consider NAVDAT implementation issues and implications of its introduction, both from the shore and ship perspectives, including coordination with existing NAVTEX services and carriage requirements.

ECDIS performance standards

MSC 108 adopted resolution MSC.530(106)/Rev.1 on Performance standards for electronic chart display and information systems (ECDIS), which accommodates the voyage plan exchange between shore-based organizations and ships.

Further, MSC 108 instructed the NCSR Sub-Committee to:

  • consider the development of appropriate operational guidance for route exchange; and
  • further consider the issues relating to S-100 Electronic Navigation Chart implementation matters and training needs of seafarers, taking into account the views expressed at this session.

Dissemination of Maritime Safety Information (MSI)

Matters relating MSI dissemination through Iridium satellite service has been on the agenda of MSC and NCSR for several sessions.  Following review of the submission papers, including the paper from Liberia urging immediate dissemination of MSI via Iridium satellite system, MSC 108:

.1   instructed the NCSR Sub-Committee to prepare draft amendments to the SOLAS Convention, including any necessary consequential amendments to related instruments, clearly stating the requirement for dissemination of MSI and SAR related information through all operational Recognized Mobile Satellite Services (RMSSs), as appropriate;

.2   agreed that MSI should be disseminated through all operational RMSSs with an implementation date not later than 31 December 2026; urged Member States responsible for the dissemination of MSI to complete the implementation of the Iridium SafetyCast service as soon as possible; and

.3   agreed also that rescue coordination centres (RCCs) should disseminate SAR related information through all operational RMSSs, as appropriate, or, alternatively, establish the necessary arrangements with other certified providers for dissemination of information within the areas for which the RCC was responsible.

VHF Digital Exchange System (VDES)

Liberia and the co-sponsor pointed out that use of VDES for SOLAS Chapter IV requires recognition of the satellite system as an RMSS.  MSC 108 agreed with the view.

Other matters decided by MSC 108

MSC 108:

  • approved SN.1/Circu.343 on recognition of ship reporting system in the Pentland Firth (PENTREP), for implementation on 1 December 2024;
  • approved MSC.1/Circ.1610/Rev.1 on Descriptions of Maritime Services in the context of e-navigation, taking into account the outcome of FAL 48 concerning Maritime Service 8 (Vessel shore reporting); and
  • approved MSC.1/Circ.1310/Rev.2 on Joint IMO/IHO/WMO Manual on Maritime Safety Information to be implemented from 1 January 2025.

Outcome of the Sub-Committee on Implementation of IMO Instruments (III)

Appropriate language applied in ship's certificates

MSC 108 agreed that the language requirements under the different IMO instruments refer to the form of certificates rather than the content of the field concerned; therefore, the names of ships, companies, and addresses should be considered as administrative information and might be in special characters of the national official language of a Member State.

Outcome of the Sub-Committee on Carriage of Cargoes and Containers (CCC)

Consideration of alternative fuel

MSC 108 approved, subject to endorsement of Council, a meeting of the Intersessional Working Group on Development of Technical Provisions for Safety of Ships using Alternative Fuels (ISWG-AF), from 9 to 13 September 2024.

MSC 108 also approved MSC.1/Circ.1679 on Interim Guidelines for use of LPG cargo as fuel.

MSC 108 also approved the next batch of the amendments to the IGF Code for final adoption by MSC 109 scheduled for summer 2025.

Ammonia cargo as fuel

MSC 108 approved draft amendments to the IGC Code, with a view to adoption at MSC 109, and entry into force on 1 July 2026, together with an MSC circular on the early implementation of the draft amendments to be issued at MSC 109. As an alternative to an MSC circular, MSC 109 could consider including an invitation for early implementation in the resolution containing the aforementioned amendments.

The amendments will lift the prohibition on using toxic cargo as fuel on board Gas Carriers.

Application of high manganese austenitic steel for cryogenic service

MSC 108 approved:

  • MSC.1/Circ.1599/Rev.3 on revised guidelines on the application of high manganese austenitic steel for cryogenic service (MSC.1/Circ.1599/Rev.2); and
  • MSC.1/Circ.1622/Rev.1 on guidelines for the acceptance of alternative metallic materials for cryogenic service in ships carrying liquefied gases in bulk and ships using gases or other low-flashpoint fuels (MSC.1/Circ.1622).

Carriage of hydrogen as cargo

MSC 108 adopted resolution MSC.565(108) on Revised Interim Recommendations for the Carriage of Liquefied Hydrogen in Bulk. While previous recommendations addressed only vacuum-insulated type C tanks, the revised recommendations address independent tanks in general. The IMO decided to continue its work to address other types of tanks.

Outcome of the Sub-Committee on Ship Design and Construction (SDC)

MSC 108:

  • approved MSC.1/Circ.1212/Rev.2 on the Revised guidelines on alternative design and arrangements for SOLAS chapters II-1 and III, containing goals, functional requirements and expected performances for SOLAS chapter II-1, parts C, D and E;
  • approved MSC.1/Circ.1572/Rev.2 on Unified interpretations of SOLAS chapters II-1 and XII, of the Technical provisions for means of access for inspections (resolution MSC.158(78)) and of the Performance standards for water level detectors on ships subject to SOLAS regulations II-1/25 and 25 1, and XII/12 (resolution MSC.188(79)/Rev.2);
  • approved MSC.1/Circ.1680 on Unified interpretation of SOLAS regulation XV/5.1 and paragraph 3.5 of part 1 of the International Code of Safety for Ships Carrying Industrial Personnel (IP Code) on the harmonization of the Industrial Personnel Safety Certificate with SOLAS safety certificates, providing specific guidance on the initial and maintenance surveys, as required in SOLAS regulations XV/3.2, 3.3 and 5.1;
  • approved MSC.1/Circ.1509/Rev.1 on Unified interpretations of the Code on Noise Levels on Board Ships (resolution MSC.337(91)), clarifying the standards against which sound level meters and their accompanying field calibrator need to be certified; and
  • approved MSC.1/Circ.1511/Rev.1 on Unified interpretations of SOLAS regulations II-2/9 and 13, outlining that steering gear spaces are to be regarded as a "safe position" under the means of escape from machinery spaces (SOLAS regulations II-2/9 and 13).




Source: IMO




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