Joint Guidelines for Electronic CertificatesPractical Implications for Class, ROs and PSC

Executive Brief

The central point of FAL-LEG-MEPC-MSC.1/Circ.1, Joint Guidelines for the Use of Electronic Certificates, is not simply that a PDF may replace paper on board. The guidelines establish a complete electronic certificate trust chain:

Flag Administration authorization -> qualified electronic format -> tamper protection and electronic signature -> unique tracking number -> continuously available verification mechanism -> onboard SMS document control -> PSC acceptance and verification

If any link fails, such as missing flag authorization, an outdated certificate version, an unavailable verification website, missing onboard verification instructions or crew unfamiliarity, an otherwise valid e-certificate may create a compliance risk during PSC inspection.

1. Document Subject and Background

1.1 Basic Document Information

The circular consolidates the earlier FAL guidance, which focused more on ship electronic certificates, and the MSC guidance dealing specifically with seafarer electronic certificates into one joint document across FAL, LEG, MEPC and MSC.

IMO's public information also identifies this circular as the current joint guidance on electronic certificates and explains that e-certificates should be regarded as equivalent to traditional paper certificates when they comply with IMO guidance, verification website requirements and onboard verification instructions. (International Maritime Organization)

1.2 Why the Document Was Developed

The document responds to practical issues seen with traditional paper certificates and early electronic certificates:

1. PSC or other stakeholders questioned the validity of electronic certificates.
2. Masters and crew had to contact the company, flag Administration or class for additional explanation.
3. Paper certificates might not have arrived on board.
4. Paper certificates could be lost, damaged or altered.
5. Seafarer certificates are numerous, frequently updated and burdensome to manage in paper form.
6. Verification methods differed among flag States, ROs and class societies.
7. Electronic certificates involve servers, networks, electronic signatures and personal data, requiring cybersecurity and privacy controls.

The guidance is therefore not merely a statement that certificates may be digital. It attempts to define minimum common features that Administrations and stakeholders can recognize.

1.3 Legal Status of the Guidelines

This is an IMO Circular / Guidelines document. It does not directly amend the text of SOLAS, MARPOL, STCW or other conventions.

The document uses expressions such as:

• should, meaning recommended practice;
• are invited to, inviting Member States to act; and
• are urged to, urging Member States to act.

Its practical effect mainly comes from:

1. flag State domestic law and administrative procedures;
2. flag authorization given to ROs and class societies;
3. IMO convention requirements to carry and present certificates;
4. incorporation into the company's safety management system under the ISM Code; and
5. PSC regional MoUs and port State implementation procedures.

Paragraph 3 also expressly asks Member Governments to establish appropriate domestic legislation where necessary, to ensure electronic certificates can be legally used and accepted. In other words, the IMO guidelines alone do not make every PDF acceptable.

2. Document Structure

3. Core Content Analysis

3.1 Scope of Application

The guidelines apply to electronic certificates issued to demonstrate compliance with IMO requirements, including:

• ship statutory certificates;
• class-related electronic certificates;
• certificates issued by a flag Administration or its authorized RO;
• seafarer certificates of competency and other STCW-related electronic evidence; and
• printed versions of electronic certificates.

They do not apply to:

• publications carried on board;
• operating manuals;
• instruction documents; or
• logbooks and record books used for continuous recording of ship operations.

Therefore, electronic oil record books, garbage record books, ballast water record books and similar systems do not become compliant solely because of this guidance. They remain subject to their own conventions, resolutions and flag approvals.

3.2 An Electronic Certificate Is Not a Scan

An electronic certificate under the guidelines must be official electronic data issued in a format established or approved by the Administration and readable by the intended users.

The following should not be treated as qualified electronic certificates by themselves:

• a normal PDF made by scanning a paper certificate;
• a photo of a certificate taken by phone;
• an electronic file without an electronic signature;
• a Word or PDF file that can be freely edited;
• a company-made confirmation without flag authorization; or
• a file with a class logo but no online or electronic verification path.

A genuine electronic certificate must combine issuing authority, data integrity, verifiability and valid status.

3.3 Five Minimum Features

Section 4.1 sets out five requirements for electronic certificates.

1. Correct format and content

The format, fields and content must comply with the relevant international convention requirements, including:

• certificate title;
• ship name and IMO Number;
• port of registry and flag State;
• gross tonnage, ship type and other applicable particulars;
• date of issue;
• date of expiry;
• annual, intermediate or periodical survey endorsements; and
• exemptions, restrictions or additional conditions.

Digitalization must not change the content originally required by the conventions.

2. Prevent unauthorized modification

The certificate must be protected so only the issuer or personnel authorized by the Administration can:

• amend it;
• correct it;
• extend it;
• add endorsements;
• reissue it; or
• revoke or invalidate it.

A downloaded PDF whose text can be edited by the holder would generally not meet this requirement.

3. Unique tracking number

Each certificate must have a Unique Tracking Number (UTN) to distinguish electronic certificates issued by the same Administration.

The UTN supports:

• authenticity checks;
• version comparison;
• revocation checks;
• confirmation of the latest endorsement; and
• prevention of mix-ups between ships or certificate types.

4. Clearly identified issuing source

The verifier should be able to identify:

• the flag Administration;
• the issuing RO or class society;
• the issuing person;
• the issuing authority; and
• whether the certificate is issued on behalf of the flag State.

5. Electronic signature

The certificate must include an electronic signature to verify the issuer and the authenticity of the content.

A picture of a handwritten signature shown on the certificate is not necessarily a valid electronic signature. A real electronic signature normally includes cryptographic information that can be checked by a PDF reader or verification platform.

3.4 Verification Site and Cybersecurity

If an Administration uses a website to view or verify electronic certificates, the site should include:

• access control;
• protection against unauthorized queries or modification;
• fraud and forgery prevention;
• resilience against cyberattack;
• system redundancy;
• disaster recovery capability; and
• continuity of service.

The footnote refers to the ISO/IEC 27000 family of information security management standards, but this is an example. It does not mean that an ISO 27001 certificate automatically satisfies the guidelines. The Administration still needs to approve the overall issuing, storage and verification process.

3.5 What Verification Really Means

Verification does not mean a surface check of the document. It means using a reliable, secure and continuously available process to confirm that:

1. the certificate was issued by a legitimate issuer;
2. the content has not been altered;
3. the certificate is still within its validity period;
4. the certificate has not been revoked or superseded;
5. the endorsement status is current; and
6. the certificate matches the ship, equipment or seafarer concerned.

When PSC scans a QR code and sees a webpage, verification is not automatically complete. The webpage data, the electronic file and the actual ship particulars still need to be compared.

3.6 Verification Instructions on Board

Section 5.1 requires verification instructions to be available on board, including methods to confirm periodical endorsements where necessary.

At a minimum, the master or responsible crew should know:

• where electronic certificates are stored;
• how to open the files;
• how to view the electronic signature;
• where the UTN is shown;
• how to use the QR code;
• which website or application verifies the certificate;
• how to confirm the latest endorsement;
• who to contact if verification fails; and
• what alternative measures apply during network outage.

Keeping certificates only in a company cloud folder and asking shore staff when needed will usually be insufficient evidence of effective onboard control.

3.7 Special Requirements for Seafarer E-Certificates

Seafarer electronic certificates involve STCW qualifications and personal data, so additional requirements apply.

Available verification methods

Verification may use:

• an approved application;
• approved stored data;
• a UTN;
• a seafarer identification number;
• a QR code;
• a combination of these methods; or
• another method approved by the Administration.

Minimum data held by the seafarer

If complete data is stored on a remote server, the seafarer still needs enough information to initiate verification, such as:

• name;
• certificate number;
• seafarer identification number;
• QR code;
• UTN; or
• query data specified by the Administration.

Legal effect of the original certificate

If the seafarer holds a genuine and valid electronic certificate and the relevant conditions are met, it should be treated as holding the original certificate on board.

This is a significant practical step: seafarers do not necessarily need to carry the traditional paper original.

3.8 Notification and GISIS

An Administration that decides to use electronic certificates should provide information through the GISIS Survey and Certification Module, including:

• information on the use of electronic certificates;
• types of electronic certificates;
• verification websites; and
• relevant verification information.

IMO's public information explains that GISIS can provide flag State electronic certificate information and authenticity verification links. (International Maritime Organization)

GISIS mainly shows that a flag State or certificate category uses electronic certificates. It does not necessarily prove that a specific individual certificate is currently valid.

The status of an individual certificate should still be confirmed through the verification system of the flag State or issuing RO.

3.9 Acceptance Is Conditional

Section 7 requires stakeholders, including PSCOs, to accept electronic certificates that have the features required by section 4.

PSC should therefore not reject a certificate merely because it has:

• no wet signature;
• no watermarked paper;
• no embossed seal;
• no paper original; or
• only a qualified electronic file.

Acceptance is subject to the following conditions:

• the flag State permits that certificate to be electronic;
• the electronic certificate has the required features;
• verification can be completed;
• the content and dates are correct; and
• verification instructions are available on board.

The IMO 2025 PSC Procedures now define a valid certificate as one that may be issued by a Party or its RO in electronic or paper format, provided the dates, contents and actual ship condition match.

3.10 Incorporation into the ISM Safety Management System

Section 8.2 requires shipowners, operators and seafarers to manage electronic certificates under ISM Code section 11, documentation control.

The core requirements of ISM Code section 11 are:

• valid documents are available at all relevant locations;
• changes to documents are reviewed and approved by authorized personnel; and
• obsolete documents are promptly removed.

For e-certificate management, this means:

3.11 Security, Anti-Fraud and Operational Continuity

Section 9 requires the Administration to approve:

• the issuing process;
• the storage process;
• the verification process;
• the data exchange process; and
• measures to prevent fraud and cybersecurity incidents.

The control scope is therefore not limited to the PDF itself. It includes:

• account permissions;
• signature keys;
• certificate management;
• servers;
• APIs;
• email notifications;
• download links;
• verification websites;
• system logs;
• backup and disaster recovery; and
• revocation and reissue procedures.

3.12 Seafarer Data and Storage Location

The physical storage location of seafarer electronic certificate data should be decided by the Administration.

The guidelines recommend storing the main data on:

• a server controlled by the Administration; or
• a server approved by the Administration.

At the same time, flag State personal data and privacy laws must be complied with. Third parties such as companies, agents, charterers or vetting companies may access necessary data only if privacy requirements are not breached.

The verification system must balance two objectives:

• making verification easy for PSC, companies and other lawful verifiers; and
• avoiding unlimited public exposure of seafarer personal data.

4. Key Terms and Definitions

5. Practical Implications for Class Societies and ROs

5.1 Separate Class Certificates from Statutory Certificates

A class society usually acts in two different capacities.

Class capacity

Under classification rules, the society deals with:

• classification;
• hull and machinery surveys;
• class notation;
• class conditions; and
• class certificates.

RO capacity

When authorized by the flag State, the society may perform:

• SOLAS certificates;
• MARPOL certificates;
• Load Line certificates;
• ISM / ISPS certificates;
• BWM, AFS and other statutory certificates; and
• statutory endorsements.

IACS explains that the basic role of class is to establish and apply technical requirements for the design, construction, maintenance and survey of ships. Tokyo MOU defines an RO as an organization that performs statutory surveys and issues or endorses statutory certificates on behalf of the flag State. (Safer and Cleaner Shipping - IACS)

The same electronic system may manage both class and statutory certificates, but the legal source, issuing authority and PSC consequences are different.

5.2 Flag Authorization Matrix

A class society cannot issue electronic versions for all flags and all certificates simply because it has its own e-certificate platform.

A clear matrix should be maintained:

Flag State x certificate type x certificate status x issuing authority

For example:

ABS also places flag acceptance of electronic certificates as the first implementation check in its e-certificate guidance. (Eagle)

5.3 Minimum Platform Requirements

An RO / class society platform should at least provide:

1. UTN or an equivalent unique identifier;
2. digital signature;
3. tamper-protected PDF;
4. a public or reasonably accessible verification interface;
5. real-time validity status;
6. endorsement history;
7. revocation and replacement status;
8. cross-search by ship name, IMO Number and certificate number;
9. system availability monitoring;
10. backup and disaster recovery;
11. audit trail; and
12. 24-hour emergency support contact.

Current DNV, LR, ABS and ClassNK platforms use UTN, digital signature, online database, QR code or ship identifying data to support third-party verification. (DNV)

5.4 Surveyor Issuance Process

After completing a survey, the surveyor or issuing office should not close the case merely by uploading the certificate to the company system. They should confirm that:

• the certificate has been officially issued;
• the electronic signature is valid;
• the UTN has been generated;
• validity dates are correct;
• endorsement is correct;
• the verification platform has synchronized;
• old versions have been invalidated;
• the ship has received or can access the latest version;
• interim or short-term certificate status is clear; and
• flag authorization or a declaration letter is attached where needed.

After an annual or intermediate survey, a mismatch may occur if the platform has been updated but the ship still keeps an old PDF.

5.5 RO Liability Risks

Digitalization does not reduce the RO's responsibility for statutory certificates.

RO liability may be involved where:

• an electronic statutory certificate is issued without flag authorization;
• certificate validity is wrongly extended;
• endorsement dates are incorrect;
• ship particulars are assigned to the wrong ship;
• a revoked certificate still appears valid;
• two conflicting valid versions exist in the system;
• issuance or extension breaches convention limits; or
• a serious failure occurs in certificate control for which the RO is responsible.

Tokyo MOU's principles for assessing RO responsibility specifically cover statutory certificates issued or endorsed by an RO and improper issuance or extension contrary to convention limits. Actual attribution still depends on the case, the last surveyor and the nature of the deficiency.

5.6 Class / ISM Audit Focus

In an ISM audit, electronic certificates are normally part of document and data control. The audit may check:

• whether the company has an e-certificate procedure;
• who is responsible for downloading and updating certificates;
• whether ship and shore data are consistent;
• whether expiry dates are periodically checked;
• whether old versions are removed;
• whether crew have been familiarized;
• contingency actions when the verification platform is unavailable;
• whether electronic files are periodically backed up;
• whether email or portal access changes are controlled;
• whether electronic signatures and UTNs are sampled; and
• whether there is a reporting procedure for phishing, fake QR codes or fake certificates.

6. Practical Implications for PSC

6.1 E-Certificates as Part of Initial PSC Inspection

Paris MoU explains that PSC usually first examines onboard certificates and documents, then decides whether a more detailed inspection is needed based on the ship, equipment and crew condition. (parismou.org)

For electronic certificates, a PSCO's basic workflow will normally include the following steps.

Step 1: Confirm the certificate should be on board

The PSCO first confirms:

• ship type;
• gross tonnage;
• trading area;
• flag State;
• applicable conventions; and
• certificate types required to be carried.

Step 2: Confirm issuing authority

The check includes:

• whether the flag State uses electronic certificates;
• whether the issuer is the flag Administration or its RO;
• whether that RO is authorized to issue that certificate type; and
• whether GISIS or flag notices provide relevant information.

Step 3: Check face information in the electronic file

This includes:

• ship name;
• IMO Number;
• Official Number;
• certificate number;
• date of issue;
• date of expiry;
• endorsement;
• electronic signature;
• UTN;
• QR code; and
• issuing source.

Step 4: Perform online or electronic verification

Using the onboard instructions, the PSCO may:

• scan the QR code;
• enter the UTN;
• enter the IMO Number;
• check the PDF electronic signature;
• compare platform data; and
• confirm that the certificate has not been revoked or superseded.

Step 5: Compare with actual ship condition

Even if the e-certificate is authentic, the PSCO will still confirm that:

• ship condition matches the certificate;
• equipment exists and is operational;
• crew number and qualifications are compliant;
• endorsement reflects the latest survey; and
• limitations or conditions are observed.

6.2 No Deficiency Solely for Lack of Paper

In principle, the PSCO should accept the certificate if it:

• complies with the guidelines;
• is issued by a lawful Administration or RO;
• can be verified;
• has onboard verification instructions; and
• has valid dates and content.

The IMO 2025 PSC Procedures expressly recognize that a valid certificate may be issued in electronic or paper form.

The following situations should not, by themselves, constitute a deficiency:

• there is no paper original;
• the master presents the official certificate on a computer or tablet;
• the e-certificate has no handwritten signature; or
• a digital signature replaces an embossed seal.

6.3 Situations That May Trigger PSC Deficiencies

High-risk situations

Tokyo MOU's 2025 Annual Report noted an increase in cases involving fraudulent registration and certificates and agreed to study more effective measures. This suggests that PSCO attention to e-certificate authenticity is likely to increase.

6.4 Failed Verification Is Not Automatically Detention

Three situations should be distinguished.

Case 1: Temporary technical problem

Examples include:

• poor port network connection;
• temporary maintenance of the verification website; or
• QR code reader unavailable.

If the ship still has:

• an electronic file with a valid digital signature;
• UTN;
• flag / RO contact details;
• another verification portal; and
• sufficient evidence that the certificate is valid,

alternative verification should normally be attempted first.

Case 2: Document control deficiency

Examples include:

• old versions kept on board;
• latest endorsement not downloaded;
• crew unfamiliar with the procedure; or
• verification instructions missing.

This may form a documentation or ISM-related deficiency, but it does not necessarily reach the level of detention by itself.

Case 3: No valid certificate or clearly invalid certificate

Examples include:

• expired;
• revoked;
• forged;
• wrong ship;
• issued without authorization;
• improperly extended; or
• validity of a key statutory certificate cannot be demonstrated at all.

The IMO PSC Procedures state that if a ship does not carry valid certificates, or the certificate does not match actual ship condition, this may provide grounds for a more detailed inspection. Missing valid certificates required by conventions may also support detention, but the final decision depends on certificate type, severity and port State judgment. (wwwcdn.imo.org)

6.5 A Valid E-Certificate Does Not Prevent Detailed Inspection

A valid certificate proves only the formal and validity status of the certificate itself.

If the PSCO finds:

• fire-fighting equipment inoperative;
• life-saving appliances inconsistent with the Record of Equipment;
• crew unfamiliar with operation;
• hull or machinery condition obviously poor;
• pollution-prevention equipment not functioning properly; or
• certificate content inconsistent with the ship condition,

there may still be clear grounds for a more detailed inspection.

An electronic certificate is not an absolute guarantee of ship condition and does not restrict PSC from inspecting actual compliance. (wwwcdn.imo.org)

7. Recommended Onboard E-Certificate PSC Kit

At a minimum, the ship should maintain the following information:

8. Recommended Onboard PSC Workflow

Before Boarding

1. Check expiry dates of all statutory certificates.
2. Confirm annual / intermediate endorsements are completed.
3. Sample-check each certificate UTN.
4. Test QR codes and verification websites.
5. Confirm ship and company versions are consistent.
6. Remove expired or superseded versions.
7. Prepare flag and RO e-certificate instructions.
8. Assign one crew member to operate the system.

When the PSCO Requests Certificates

1. Provide the certificate list first.
2. Open the official PDF on the ship's computer.
3. Show the electronic signature, UTN and endorsement.
4. Open the official website according to the verification instructions.
5. Compare website data with certificate data.
6. Provide a paper printout for reading convenience if needed.
7. Do not provide only phone photos, email screenshots or unknown web links.

When the Verification Site Is Unavailable

1. Keep the error screen or time record.
2. Try another network or device.
3. Check the PDF digital signature.
4. Use an alternative verification portal.
5. Contact the company DPA, flag Administration or RO.
6. Provide the flag Marine Notice or RO declaration.
7. Record the actions taken.

9. Common Misunderstandings and Watch Points

9.1 E-Certificates Differ from Scanned Paper

A paper scan usually proves only that someone once possessed a paper document. It does not prove that the certificate is:

• currently valid;
• not revoked;
• not modified; or
• the latest version.

9.2 Electronic Signature vs Signature Image

An image of a signature is easy to copy and paste.

A valid electronic signature should be able to:

• verify the issuer;
• show the signature validity status; and
• detect whether the document has been modified after signing.

9.3 A QR Code Is Not the Certificate

A QR code is only a verification entry point. Even if it opens a webpage, the verifier still needs to confirm:

• whether the domain is official;
• whether the HTTPS certificate is valid;
• whether webpage data matches certificate data; and
• whether the certificate status is valid.

9.4 Printed Versions Should Not Stand Alone as Originals

A printout can help quick reading, but paper normally cannot retain the complete digital signature information.

Unless the flag State clearly provides otherwise, the ship should preferably keep:

• the original electronic file;
• verifiable UTN; and
• verification instructions.

ABS guidance also states that the official valid certificate is in electronic form, while paper printouts mainly serve as references. (Eagle)

9.5 GISIS Is Not a Complete Certificate Database

GISIS can confirm flag e-certificate policy and related verification links, but the status of an individual certificate, such as whether it is:

• valid;
• renewed;
• revoked; or
• replaced by a newer version,

must still be checked in the actual issuing system.

9.6 A Class Platform Does Not Equal Flag Authorization

The following must be confirmed separately:

• whether class certificates may be electronic;
• whether statutory certificates have flag authorization;
• whether the certificate category is within the authorization scope; and
• whether endorsements, extensions and interim certificates have separate requirements.

9.7 Continuously Verifiable Does Not Mean One Website Only

If the only verification website fails and there is no:

• backup site;
• digital signature;
• contact verification;
• offline verification; or
• disaster recovery arrangement,

the system may not meet the concept of reliable and continuously available verification.

10. Summary and Review Points

1. The guidelines consolidate requirements for ship electronic certificates and seafarer electronic certificates.
2. An electronic certificate is not an ordinary PDF or a scanned paper certificate.
3. A qualified electronic certificate needs at least: correct format, tamper protection, UTN, clear issuing source and electronic signature.
4. PSC should accept compliant electronic certificates and should not reject them solely because there is no paper original.
5. Acceptance is not unconditional: flag authorization, certificate validity and verifiability still need to be confirmed.
6. Electronic certificates must be incorporated into ISM Code section 11 document control.
7. When a class society acts as an RO, it must issue statutory e-certificates according to flag authorization.
8. Verification platforms must provide cybersecurity, redundancy, fraud prevention and continuity of service.
9. The ship should retain official electronic files, verification instructions, UTNs, latest endorsements and backup information.
10. A valid electronic certificate does not prevent PSC from conducting a more detailed inspection due to ship condition or operational deficiencies.

Practical note: This circular and related IMO, flag, class and PSC requirements may continue to change. Actual issuance, verification, extension, acceptance or deficiency decisions should be based on the latest IMO official documents, flag Marine Notices, RO authorization and applicable PSC MoU procedures. This note is for learning and preliminary compliance planning only and does not replace flag decisions, formal class review, PSCO professional judgment or legal advice.