SURVEYOR'S READING METHOD
More than a catalogue of future regulations
When I read a Future Legislation report as a surveyor, the priority is not memorizing every item number. It is identifying each requirement’s regulatory status, confirming its trigger dates and scope, and translating the text into documents, equipment, tests and operational evidence that can be verified on board.
This article uses the Containerships edition available from the official Lloyd’s Register Future IMO & ILO Legislation Summer 2026 page as its main reference. Search, status filters, a timeline and a newbuilding/survey checklist make the material usable for project briefings, design meetings, survey preparation and fleet regulatory tracking.
Search and filter regulations
Enter the Item, regulation name, date or keyword, such as "PFOS", "BWMS", "2028" and "pilot transfer".
VISUAL ROADMAP
Priority years to track
The following project-planning view is based on the source report. Items marked as expected remain subject to IMO or ILO negotiations.
Lifting appliances, PFOS, IGF 2026, Canadian Arctic/Norwegian Sea ECA, engine recertification process.
NOx multi-mode, DCS amendments, Northeast Atlantic ECA, MLC repatriation/shore leave/grievances and anti-harassment.
Emergency towing, VDES, pilot transfer arrangements, IGF 2028, IMDG 43-26; Net-Zero and BWM amendments may be implemented.
The results of the second phase of CII/EEXI and the regulatory framework for onboard carbon capture are expected to take effect.
MARPOL Annex IV sewage management and comprehensive revision of STCW may enter the implementation period.
Container ship fire, MASS, battery main power supply, non-traditional steering/propulsion, LSA/FTP/FSS series amendments.
Updates to regulations for nuclear-powered ships, and some 2032 projects may be delayed until then.
HOW TO READ THE REPORT
1. Report structure and usage
LR groups the regulatory status into four main parts:
Part 1 | Requirements that have taken effect but are still in the transition period for full application
These requirements are already in force, but may apply later to individual ships depending on ship type, tonnage, construction date, equipment installation date or the date of the first periodical survey.Part 2 | Requirements that have been adopted and will take effect in the future
The IMO or ILO has adopted these requirements and confirmed their entry-into-force dates.Part 3 | Requirements under development
These requirements have not yet been formally adopted. The report provides expected dates, but both dates and technical text may change.Part 4 | Proposed new requirements
These items remain at the work-programme or early proposal stage; their scope and technical requirements are not yet settled.
The source report presents separate timelines for adopted and potential amendments. Its Figure 1 compares the greenhouse-gas fuel-intensity reduction paths for the IMO Net-Zero Framework’s Base Target and Direct Compliance Target.
EXECUTIVE TAKEAWAYS
2. Three-minute summary
2.1 Requirements most directly affecting container ships in 2026–2028
- From 2026, shipboard lifting appliances and loose gear are governed by the new SOLAS II-1/3-13. Existing appliances must also undergo load testing and thorough examination and receive SWL markings and documentation by the specified renewal survey.
- Fire-extinguishing foam containing PFOS is prohibited from 2026. Both new and existing ships must demonstrate removal by the first relevant statutory survey.
- The Canadian Arctic and Norwegian Sea ECAs have been established. NOx Tier III applies to new ships meeting the construction-date criteria, while the 0.10% SOx limit applies from 2027.
- From 2027, the NOx Technical Code adds recertification procedures for engines undergoing major conversion and requirements for multiple operational profiles and rational emission control strategies.
- From 2028, new ships other than tankers of 20,000 GT and above must be fitted with emergency towing arrangements.
- From 2028, pilot transfer arrangements are subject to comprehensive mandatory performance standards, including a phased upgrade schedule for existing arrangements.
- IMDG Code Amendment 43-26 introduces provisions for lithium-metal batteries, sodium-ion batteries, vehicles and cargo transport units, with particular implications for container-ship cargo acceptance and dangerous-goods documentation.
2.2 Priority issues for advance planning in 2028–2032
- IMO Net-Zero Framework There is no consensus yet, but if adopted by the end of 2026, it may enter into force in mid-2028 and would affect fuel selection, capital expenditure, operating costs and compliance costs.
- The comprehensive review of the BWM Convention shifts the focus from equipment being installed and certified to its continued effective operation. Maintenance records, failure reports, repair plans, crew familiarization and annual sampling of active substances will become central to surveys.
- The Phase 2 review of CII/EEXI has set tighter CII Z factors for 2027–2030. SEEMP may evolve from annual-rating management toward continual improvement and stronger tracking of company accountability.
- Fire detection and control in container-ship cargo holds and on deck is expected to generate new SOLAS and FSS Code requirements around 2032, potentially covering infrared thermal imagers, fixed detection, remote-controlled water monitors, water-mist lances and hatch-cover protection.
- Batteries as the main source of electrical power, non-conventional propulsion and steering systems, MASS, autonomous ships and firefighting for alternative fuels are all giving rise to new regulatory frameworks.
REGULATORY TIMELINE
3. Principal entry-into-force timeline
| Date | Important requirements |
|---|---|
| 2026-01-01 | Lifting appliances and anchor handling winches; maintenance related to ventilation of totally enclosed lifeboats; PFOS fire-extinguishing foam ban; IGF Code 2026 amendments; Polar Code expansion to some non-SOLAS ships |
| 2026-03-01 | MARPOL Annex VI amendments to the Canadian Arctic ECA and Norwegian Sea ECA come into effect |
| 2026-09-01 | Diesel-engine recertification procedures following major conversion or an upgrade to a higher NOx Tier |
| 2027-03-01 | Amendments on multiple engine operational profiles and rational emission control strategies enter into force |
| 2027-09-01 | IMO DCS reporting field revisions; Northeast Atlantic ECA; DCS data access reforms |
| 2027-12-23 | MLC 2006: repatriation, shore leave, marine casualty investigations and fair treatment of seafarers, on-board complaint procedures, and prevention of violence and harassment on board |
| 2028-01-01 | Emergency towing arrangements for ships other than tankers; VDES; pilot transfer arrangements; IGF Code 2028; IMDG 43-26; GMDSS MSI transmission amendment, etc. |
| Estimated 2028 | IMO Net-Zero Framework, integrated bilge water treatment, non-carbon fuel NOx certification, BWM Convention overhaul |
| Estimated 2030 | CII/EEXI review results; on-board carbon capture and storage OCCS regulatory framework |
| Estimated 2031 | MARPOL Annex IV Sewage Management; comprehensive revision of STCW |
| Estimated 2032 | mandatory MASS Code, container ship fire, LSA/FTP/FSS Code, various propulsion and steering, battery main power supply, etc. |
PART 1 · REGULATION STATUS
4. Part 1 | In force but still subject to transitional application
These requirements are already in force, but their application must still be determined ship by ship according to vessel type, tonnage, construction or installation date, and the date of the first relevant statutory survey.
ITEM 370 Item 370 | MARPOL Annex VI In-use Fuel Oil Sampling Points
- Adopted: MEPC.324(75)
- Entry into force: 2022-04-01
- Ships of 400 GT and above must be fitted with, or designate, sampling points from which representative samples of fuel oil in use can be obtained.
- For new ships, the relevant threshold is a keel-laying date of 2022-04-01; existing ships must comply by the first IAPP renewal survey after 2023-04-01.
- The sampling configuration should be shown on the piping diagram or relevant documents for verification during survey.
- Low flash point fuels may be excluded from sampling point requirements under the new definition.
ITEM 377 Item 377 | Prohibition on the Use and Carriage of Heavy Fuel Oil in Arctic Waters
- Adopted: MEPC.329(76)
- Entry into force: 2022-11-01
- From 2024-07-01, ships without protected fuel oil tanks are generally prohibited from using or carrying the specified HFO for use as fuel in Arctic waters.
- Ships complying with the fuel oil tank protection requirements of MARPOL Annex I/12A or the Polar Code, and ships granted waivers by the flag States of Arctic coastal States, may defer compliance until 2029-06-30.
- Full ban as of 2029-07-01.
- Exceptions apply to ships engaged in search and rescue, securing the safety of ships, or oil-spill preparedness and response.
ITEM 368 Item 368 | Controls on Cybutryne under the AFS Convention
- Adopted: MEPC.331(76)
- Entry into force: 2023-01-01
- From 2023-01-01, no ship may apply or reapply an anti-fouling system containing cybutryne.
- Ships with an existing cybutryne-containing coating must remove it or apply a barrier coating at the first scheduled renewal of the anti-fouling system, but no later than 60 months after the original coating was applied.
- Shipowners and managers should arrange the survey needed for an IAFS Certificate in the revised format by 2025-01-01.
ITEM 350 Item 350 | 2024 Amendments to the IGF Code
- Adopted: MSC.458(101)
- Entry into force: 2024-01-01
- The amendments cover secondary enclosures for gas fuel piping, containment of liquefied-fuel leakage, explosion relief for exhaust systems, and separation of Type C fuel tanks from spaces of high fire risk.
- Exhaust systems on new natural-gas-fuelled ships must have explosion-relief devices unless they can withstand the most severe overpressure resulting from ignition.
- In principle, fuel containment spaces must be separated from Category A machinery spaces and other spaces of high fire risk by a 900 mm cofferdam with A-60 fire protection; A-60 insulation alone, without a cofferdam, is not accepted.
- Mainly applicable to ships contracted on or after 2024-01-01, keels laid on or after 2024-07-01, or delivered on or after 2028-01-01.
ITEM 365 Item 365 | Towing and Mooring Equipment under SOLAS II-1/3-8
- Adopted: MSC.474(102)
- Entry into force: 2024-01-01
- Shipowners and managers must establish procedures for mooring operations and for the inspection, maintenance, identification, tracking and replacement of equipment and mooring lines.
- The original design concept, equipment arrangement, specifications, mooring-line MBLSD and related information must be retained on board.
- For ships built before 2007 and lacking original mooring design data, the design basis can be established based on equipment SWL, structural capacity or recalculation.
- New ships of 3,000 GT and above must also meet the requirements for safe mooring arrangements and selection of mooring lines.
- Regardless of ship age, mooring equipment and lines must remain fit for purpose and in good condition.
ITEM 366 Item 366 | SOLAS Chapter II-1 Watertight Integrity
- Adopted: MSC.474(102)
- Entry into force: 2024-01-01
- The amendments address damage stability, forepeak-tank piping, watertight doors, shell openings, internal watertight boundaries and watertight closing appliances.
- For cargo ships constructed from 2024, side cargo ports, gangway ports and bunkering ports must have watertight and structural integrity equivalent to the surrounding shell and should generally open outwards.
- Pipes, scuppers, cables and other penetrations through watertight boundaries within the damage extent must preserve watertight integrity.
- Mainly applicable to new ships contracted on or after 2024-01-01, keels laid on or after 2024-07-01, or delivered on or after 2028-01-01.
ITEM 374 Item 374 | Water Level Detectors on Multiple-hold Cargo Ships
- Adopted: MSC.482(103)
- Entry into force: 2024-01-01
- SOLAS II-1/25-1 has been added so that multi-hold cargo ships that are not bulk carriers or oil tankers must also be equipped with water level detectors.
- A general high bilge level alarm is not necessarily a sufficient replacement for the water level detection required by the new regulations.
- Applicable to new cargo ships contracted on or after 2024-01-01, keel laid on or after 2024-07-01, or delivered on or after 2028-01-01.
ITEM 403 Item 403 | Fixed Fire-extinguishing Systems in Fuel Preparation Rooms under the IGF Code
- Adopted: MSC.475(102)
- Entry into force: 2024-01-01
- Fuel preparation rooms containing pumps, compressors or other ignition sources shall be equipped with fixed fire-extinguishing systems.
- The design concentration or discharge rate of the extinguishing medium must be suitable for gas fires.
- Applies to cargo ships of 500 GT and above and all passenger ships constructed from 2024 that are subject to the IGF Code; it does not apply to gas carriers subject to the IGC Code.
ITEM 155 Item 155 | Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships
- Adopted: SR/CONF/45
- Entry into force: 2025-06-26
- From 2025-06-26, new ships must carry an approved and certified IHM (Inventory of Hazardous Materials) upon delivery.
- Existing ships must hold an approved and certified IHM Part I before 2030-06-26.
- Ships entering recycling must use a ship recycling facility holding a DASR and must have IHM Parts I–III, a ship-specific Ship Recycling Plan and a Ready for Recycling Certificate.
- Shipyards and equipment suppliers need to establish Material Declaration and Supplier Declaration of Conformity to support the preparation of IHM for new ships.
- Applies to ships of 500 GT and above engaged on international voyages, excluding warships and government ships used only on non-commercial service.
ITEM 383 Item 383 | Lifting Appliances and Anchor Handling Winches under SOLAS II-1/3-13
- Adopted: MSC.532(107)
- Entry into force: 2026-01-01
- Lifting appliances installed on or after 2026-01-01 must be designed, constructed and installed in accordance with requirements of a classification society recognized by the Administration.
- Proof-load testing and thorough examination are required before first use and after repairs or significant modifications.
- Equipment must be permanently marked SWL and have appropriate documentation.
- Existing appliances installed before 2026 must be examined, tested, marked with their SWL and documented by the first relevant renewal survey after 2026-01-01.
- All lifting appliances and loose gear must be tested, thoroughly examined, inspected, operated and maintained in accordance with MSC.1/Circ.1662 and MSC.1/Circ.1663.
- The mandatory scope generally covers appliances with an SWL of 1,000 kg and above; exclusions include life-saving appliance launching arrangements and machinery integrated into hatch covers.
ITEM 395 Item 395 | Ventilation of Totally Enclosed Lifeboats
- Adopted: MSC.535(107)
- Entry into force: 2026-01-01
- A totally enclosed lifeboat must provide at least 5 m³/h of ventilation per person for at least 24 hours.
- The requirement applies to lifeboats installed on or after 2029-01-01.
ITEM 413 Item 413 | Prohibition of Fire-extinguishing Foams Containing PFOS
- Adopted: MSC.532(107), MSC.536(107), MSC.537(107)
- Entry into force: 2026-01-01
- PFOS-containing foam is prohibited in both fixed and portable fire-extinguishing systems.
- Existing PFOS-containing extinguishing media on board must be delivered to a suitable shore reception facility.
- Both new ships and existing ships must comply at the first initial, annual, periodic or renewal survey after 2026-01-01, whichever occurs earliest.
ITEM 431 Item 431 | 2026 Amendments to the IGF Code
- Adopted: MSC.551(108)
- Entry into force: 2026-01-01
- The amendments address LNG fuel-tank relief capacity, tank pressure and temperature control, fuel-pipe thickness, leakage at bunkering connections, fuel-supply redundancy, automatic ventilation between double-block-and-bleed valves, and hazardous-area classification.
- Fuel preparation rooms are treated as Category A machinery spaces; existing ships must also provide a 5 kg dry-powder extinguisher in each fuel preparation room by the first survey.
- Interbarrier spaces are classified as Zone 0 on new ships.
- A new item for written confirmation before bunkering is "compatibility of the maximum possible supply pressure at the shore and the design pressure of the ship-side bunkering pipe".
- Generally applicable to low flash point fuel ships contracted on or after 2026-01-01, keel laid on or after 2026-07-01, or delivered on or after 2030-01-01.
ITEM 487 Item 487 | Extension of the Polar Code to Certain Non-SOLAS Ships
- Adopted: MSC.532(107), MSC.538(107)
- Entry into force: 2026-01-01
- Polar Code adds new navigation safety and voyage planning requirements for non-SOLAS ships.
- Applicable to fishing vessels of 24 m and above, non-commercial pleasure yachts of 300 GT and above, and cargo ships of 300 GT and above but less than 500 GT.
- Ships constructed before 2026 must comply by 2027-01-01; ships constructed from 2026 are subject to the requirements from 2026-01-01.
ITEM 661 Item 661 | MSC.402(96): Lifeboat Ventilation System Inspections
- Adopted: MSC.559(108)
- Entry into force: 2026-01-01
- Authorized service providers must confirm the condition and functionality of installed ventilation systems during inspections of lifeboats, rescue boats and fast rescue boats.
- Because the new ventilation requirement applies to totally enclosed lifeboats installed from 2029, the corresponding inspection item applies when that equipment becomes mandatory.
ITEM 770 Item 770 | Canadian Arctic ECA
- Adopted: MEPC.392(82)
- Entry into force: 2026-03-01
- NOx: Ships with keels laid on or after 2025-01-01, fitted with marine diesel engines of 130 kW and above and operating in the ECA, must meet Tier III.
- SOx: From 2027-03-01, ships sailing in this ECA must use fuel oil with a sulfur content not exceeding 0.10% m/m, or adopt an approved equivalent method, such as EGCS.
ITEM 771 Item 771 | Norwegian Sea ECA
- Adopted: MEPC.392(82)
- Entry into force: 2026-03-01
- NOx: Marine diesel engines of 130 kW and above on ships contracted on or after 2026-03-01, or in the absence of a contract with keels laid on or after 2026-09-01, or delivered on or after 2030-03-01, must meet Tier III when operating in the ECA.
- SOx: From 2027-03-01, the sulfur content of fuel oil must not exceed 0.10% m/m, or equivalent emission reduction methods must be used.
ITEM 188/264 Item 188/264 | EEDI Phase 2
- Adopted: MEPC.203(62) and subsequent amendments
- EEDI measures the design efficiency of new ships in grams of CO₂ per tonne-nautical mile.
- For container ships, the Phase 2 reduction factor is graduated by DWT; the principal band is 20%, with linear interpolation for smaller ships.
- Compliance measures may include lightweight design, hull and propeller optimization, slow steaming, waste-heat recovery, shaft generators and low-carbon fuels.
- If a major modification substantially changes the ship’s dimensions, capacity, main engine power, type, intended service life or energy efficiency, the ship may be treated as a new ship and may therefore trigger reapplication of EEDI/EEXI, as applicable.
ITEM 373 Item 373 | EEDI Phase 3
- Adopted: MEPC.324(75)
- Entry into force: 2022-04-01; the second phase starts from 2025-01-01
- For container ships, Phase 3 was brought forward to 2022-04-01, with substantially higher reduction factors than for most other ship types.
- Container ship design reduction from 2022:
| Container ship DWT | Phase 3 Tranche 1 |
|---|---|
| 200,000 and above | 50% |
| 120,000–200,000 | 45% |
| 80,000–120,000 | 40% |
| 40,000–80,000 | 35% |
| 15,000–40,000 | 30% |
| 10,000–15,000 | 15–30% linear interpolation |
- The report also lists Tranche 2 requirements for different ship types from 2025; applicability must still be checked against the building-contract, keel-laying and delivery dates.
PART 2 · REGULATION STATUS
5. Part 2 | Adopted with future entry into force
IMO or ILO has formally adopted these requirements and set clear entry-into-force dates, so they can be incorporated directly into newbuilding specifications, fleet modification plans and certification schedules.
ITEM 731 Item 731 | Engine Recertification after Major Conversion or Upgrade to a Higher NOx Tier
- Adopted: MEPC.398(83)
- Entry into force: 2026-09-01
- Existing marine diesel engines of 130 kW and above must be recertified under the new procedure when a major conversion affects NOx-critical parameters or when certification to a higher Tier than originally held is sought.
- The applicant must prepare an Engine Emission Test Plan and obtain agreement from the flag State or RO before testing.
ITEM 467 Item 467 | Multiple Engine Operational Profiles and Rational Emission Control Strategies
- Adopted: MEPC.397(83), MEPC.408(84)
- Entry into force: 2027-03-01
- The amendments prevent auxiliary control devices or “defeat devices” from being used to circumvent the NOx Technical Code.
- They permit and regulate certification of engines with multiple operational profiles and require rational emission control strategies across the full load and speed range.
- New parent and individual engines are covered by reference to EIAPP certification dates from 2028-01-01; existing engines are principally triggered by a major conversion on or after 2028-01-01.
ITEM 813 Item 813 | MARPOL Annex VI Appendix IX Reporting-period Field
- Adopted: MEPC.407(84)
- Entry into force: 2027-09-01
- The IMO DCS/CII data table adds a field identifying the portion of the calendar year covered by the report.
- The term “oil-fired boiler” is replaced by “fired boiler”.
- Applies to ships of 5,000 GT and above; the practical impact is primarily a change to the reporting format.
ITEM 888 Item 888 | North-East Atlantic NOx/SOx ECA
- Adopted: MEPC.407(84)
- Entry into force: 2027-09-01
- It covers Greenland, Iceland, the Faroe Islands, Ireland, the west coast of the United Kingdom, and extends southward to Spain and Portugal.
- NOx Tier III: Applies to ships contracted on or after 2027-01-01, or in the absence of a contract with keels laid on or after 2027-07-01, or delivered on or after 2031-01-01.
- SOx 0.10%: Applicable to ships entering this ECA from 2028-09-01.
ITEM 896 Item 896 | IMO DCS data access reform
- Adopted: MEPC.407(84)
- Entry into force: 2027-09-01
- Flag States and ROs acting on their behalf have access to complete historical data on specific ships.
- MARPOL Annex VI Parties may obtain complete information for analysis with the consent of the flag state.
- Public accounts will generally have access only to anonymized data; companies may request publication of non-anonymized data for their own fleets.
ILO16 ILO16 | MLC Repatriation
- Adopted: 2025 MLC Amendment
- Entry into force: 2027-12-23
- Member States shall not discriminate and shall facilitate the repatriation of seafarers.
- The shipowner must at least cover transportation back home, accommodation, meals, luggage up to 30 kg, and necessary medical treatment until fit to travel.
- The guidance encourages recognition of seafarers as key workers to facilitate shore leave, repatriation, crew changes and access to medical care ashore.
ILO17 ILO17 | MLC Shore Leave
- Entry into force: 2027-12-23
- Port States must permit shore leave once the necessary formalities are completed, unless refusal is justified on public-health, public-safety or public-order grounds.
- Any refusal must be explained to the master, with written reasons provided at the request of the master or seafarer.
- In principle, seafarers should not be required to hold a separate visa or permit for shore leave.
- Shipowners should permit off-duty seafarers to take shore leave unless it is unsafe, restricted by the port State or operationally impracticable.
ILO20 ILO20 | Marine Casualty Investigation and Fair Treatment of Seafarers
- Entry into force: 2027-12-23
- When conducting marine casualty investigations, Member States should take account of the IMO Casualty Investigation Code and the ILO/IMO Guidelines on Fair Treatment of Seafarers.
- States concerned are required to cooperate to the extent possible to avoid unfair treatment or undue criminalization of seafarers.
ILO21 ILO21 | On-board Complaint Procedures
- Entry into force: 2027-12-23
- In addition to submitting a complaint to the master or an external authority, seafarers may complain to appropriate shore-based personnel.
- The confidentiality of complaints must be protected and adverse action against complainants, victims, witnesses or whistleblowers is prohibited.
ILO23 ILO23 | Prevention of Violence, Harassment, Sexual Harassment, Bullying and Sexual Assault on Board
- Entry into force: 2027-12-23
- Member States are required to prevent and eliminate violence and harassment on board ships through domestic laws.
- Shipowners must establish preventive measures and a safe, fair and effective reporting mechanism, and seafarers must also comply with relevant measures.
- Recruitment and placement services, and occupational safety and health management, must address risks of violence and harassment.
ITEM 442 Item 442 | Emergency Towing Arrangements for Ships Other than Tankers of 20,000 GT and Above
- Adopted: MSC.549(108)
- Entry into force: 2028-01-01
- New ships other than tankers of 20,000 GT and above must be fitted with emergency towing arrangements.
- The arrangements must be capable of rapid deployment following loss of main power, with strength based on ship size and the loads expected in adverse weather.
- Design, construction and prototype testing are subject to approval by the Administration or RO.
- For this requirement, “constructed” is determined by keel laying or a similar stage of construction.
ITEM 566 Item 566 | IP Code: Mass of Personnel in Stability Calculations
- Adopted: MSC.588(111)
- Entry into force: 2028-01-01
- For ships carrying 12 or more industrial personnel, the mass used per person in stability calculations increases from 75 kg to 90 kg.
- Applicable to new IP Code ships contracted on or after 2028-01-01, keel laid on or after 2028-07-01, or delivered on or after 2032-01-01.
ITEM 606 Item 606 | VDES as an AIS alternative
- Entry into force: 2028-01-01
- VDES integrates terrestrial and satellite VHF data exchange, ASM and AIS functions.
- SOLAS Chapter V will permit VDES as an alternative to AIS, although VDES has not yet been incorporated into the SOLAS Chapter IV requirements for radio equipment.
- The expected application mirrors AIS: ships of 300 GT and above on international voyages, cargo ships of 500 GT and above on non-international voyages, and all passenger ships.
ITEM 607 Item 607 | Arrangements for Testing Free-fall Lifeboat Release Systems Without Launching
- Entry into force: 2028-01-01
- A new LSA Code 4.7.7 has been added, regulating means for testing release systems under load without actually launching the lifeboat.
- The design safety factor must be at least 6, accounting for the full complement, equipment, and static and dynamic loads.
- Components exposed to marine environments must be corrosion-resistant and should not rely on painting or galvanizing.
- The requirement applies to free-fall lifeboats installed on or after 2031-01-01.
ITEM 642 Item 642 | Safety of Pilot Transfer Arrangements
- Adopted: MSC.572–574(110), MSC.577(110)
- Entry into force: 2028-01-01
- The performance standards under SOLAS V/23 will become mandatory and cover design, manufacture, inspection, maintenance, replacement, rigging and training.
- Pilot transfer arrangements on all new and existing ships must be inspected, stowed, maintained and replaced in accordance with the performance standards, with appropriate familiarization training.
- Accommodation ladders used in combination arrangements must comply with the means-of-embarkation and disembarkation requirements of SOLAS II-1/3-9.
- Arrangements installed on SOLAS ships before 2028 must comply with Parts A–C no later than the first relevant safety equipment survey after 2029-01-01.
ITEM 708 Item 708 | 2028 Amendments to the IGF Code
- Adopted: MSC.567(109)
- Entry into force: 2028-01-01
- The amendments address fuel-tank suction wells, separation of fuel tanks from cargo, safety-valve discharge, non-return valves, equivalent A-60 protection and hazardous-area extents.
- In principle, Zone 1 around a fuel-tank vent mast comprises a cylinder of unlimited height and 6 m radius, plus a 6 m hemisphere below; where ship geometry constrains this, dispersion analysis may justify a reduction, but not below 3 m, with an additional 1.5 m Zone 2.
- Hazardous area ventilation ducts passing through non-hazardous areas must be airtight and maintain a relative negative pressure; exceptions may be made for fully welded piping that meets material requirements.
- Principally applies to ships contracted on or after 2028-01-01, with keels laid on or after 2028-07-01, or delivered on or after 2032-01-01.
ITEM 728 Item 728 | Guard Rails under the 1988 Load Line Protocol
- Entry into force: 2028-01-01
- For new ships engaged on international voyages of 24 m or above, guardrails or bulwarks must be provided around all open decks and sea openings accessible to crew members.
- In principle, the height should be at least 1 m; if it hinders normal operations, it can be lowered with the consent of the Administration.
- Detachable chains can be used when the job requires them, but they must be tightened as much as possible.
ITEM 807 Item 807 | IMDG Code Amendment 43-26
- Adopted: MSC.587(111)
- Entry into force: 2028-01-01; voluntary early adoption is available starting from 2027-01-01
- The amendment adds or revises provisions for batteries, vehicles, the Dangerous Goods List, special provisions, packaging, marking and transport procedures.
- New:
- UN 3563: Lithium metal batteries contained in cargo transport units
- UN 3564: Sodium-ion batteries contained in cargo transport units
- SP980 requires shippers to assess vehicle safety status; damaged lithium batteries must be removed.
- SP961 and SP962 are amended to clarify exemptions for electric and hybrid vehicles and placarding requirements for CTUs.
- For container ships, the main practical effects concern cargo acceptance, dangerous-goods declarations, CTU marking and on-board emergency-response information.
ITEM 906 Item 906 | GMDSS Maritime Safety Information via RMSS
- Adopted: MSC.583(111)
- Entry into force: 2028-01-01
- The amendments to SOLAS IV/5, V/4 and V/5 require coastal States to use all operational recognized mobile satellite services to transmit MSI and SAR information.
- The principal obligation rests with Contracting Governments; ship operators receive the information they transmit.
PART 3 · REGULATION STATUS
6. Part 3 | Requirements under development
These requirements remain under discussion or await formal adoption, so both their dates and technical text may change. They are useful for design foresight and risk allowances, but must not be treated as current mandatory requirements.
ITEM 613 Item 613 | IMO Net-Zero Framework
- Expected entry into force: 2028-04-03
- The 2023 IMO GHG Strategy sets checkpoints of a 20% reduction by 2030, striving for 30%; a 70% reduction by 2040, striving for 80%; and net-zero GHG emissions by or around 2050.
- MEPC 83 had approved a draft of the new Chapter 5 of MARPOL Annex VI, but the 2025 special session was postponed by one year and the future of the framework remains uncertain.
- MEPC 84 confirmed that countries still lack consensus on the intensity of targets and economic measures; a decision may be made at MEPC 85 or a resumed session in December 2026.
- If adopted in 2026, it could take effect in mid-2028.
- It may apply to ships of 5,000 GT and above; ships solely on domestic voyages, ships without mechanical propulsion, platforms, FPSOs, FSUs, drilling rigs and semi-submersible units may be excluded.
- Shipowners should model fleet fuel scenarios, costs and compliance pathways well in advance.
ITEM 378 Item 378 | Integrated Bilge Water Treatment Systems (IBTS)
- Expected entry into force: 2028-04-03
- A new MARPOL Annex I Regulation 12B is proposed to establish uniform international requirements for IBTS.
- The requirements become mandatory only where an IBTS is installed.
- The IOPP Supplement and Oil Record Book will add records of alternative treatment methods and clarify practices such as forced evaporation.
- They are expected to apply to ships of 400 GT and above fitted with IBTS after entry into force; existing systems would comply to the extent reasonably practicable.
ITEM 889 Item 889 | NOx Certification for Engines Using Non-carbon-containing Fuels
- Expected entry into force: 2028-04-03
- The NOx Technical Code 2008 is based on carbon-containing fuels such as diesel and LNG and does not adequately address exhaust-flow calculations and measurement methods for ammonia, hydrogen or mixed fuels.
- The draft amendments address definitions, test fuels, exhaust-gas-flow calculations, measurements, analyser specifications and the parent-engine test report.
- More complete fuel element analysis, emissions measurements and onboard data recording may be required.
- Expected to apply to engines of 130 kW and above.
ITEM 750 Item 750 | Comprehensive Review of the BWM Convention
- Expected entry into force: 2028-06-03
- The compliance focus will shift from type approval and installation to continued proper operation and achievement of the D-2 standard.
- The BWMP must identify the BWMS approval basis, maintenance procedures, safe ballast-water exchange, contingency measures and arrangements for temporarily holding grey water or treated sewage; mandatory content must be approved and subject to version control.
- Auditable BWMS maintenance records will be required; if an equivalent system is not available, there must be a Maintenance Log in the Ballast Water Record Book.
- The crew must be able to demonstrate familiarity with the ship's BWMS.
- Systems using active substances will be subject to mandatory discharge-concentration limits and annual sampling for residual active substances.
- Annual surveys will verify maintenance records and sampling; failures must be reported immediately, with a time-bound repair plan agreed by the flag State and the port State of destination.
- For shipowners, crews and surveyors, a BWMS failure will become a formal compliance matter spanning flag- and port-State requirements, not merely a technical defect.
ITEM 834 Item 834 | Application of the IGF Code to Gaseous Fuels under SOLAS
- Expected entry into force: 2028-07-01
- A definition of “gaseous fuel” is proposed to resolve uncertainty where fuels such as ammonia and hydrogen have no flashpoint measurable by a closed-cup test.
- Proposed definition is: fuel with an absolute vapor pressure exceeding 0.28 MPa at 37.8°C, or completely gaseous at 20°C, 101.3 kPa.
- It will be clearly confirmed that the IGF Code applies to both gaseous fuels and low flash point fuels, but does not apply to gas carriers in accordance with the "one ship, one code" principle.
ITEM 917 Item 917 | Consequential IGF Code Amendments for Gaseous Fuels
- Expected entry into force: 2028-07-01
- In line with the revision of the definition of gaseous fuels in SOLAS II-1, the terminology and applicability of the IGF Code will be unified.
- LR considers the substantive impact limited; the change primarily clarifies established industry understanding.
ITEM 828 Item 828 | Review of short-term measures for CII and EEXI
- Expected entry into force: 2030-01-01
- Phase 2 work includes strengthening SEEMP, considering alternative CII metrics, adjustment factors and reference lines, and integrating the measures with the IMO Net-Zero Framework.
- Potential SEEMP enhancements include regular internal reviews, continual improvement, an Energy Efficiency Implementation Log, clearer company accountability, and stronger audit and verification requirements.
- The following CII Z factors have been agreed:
| Year | Reduction factor relative to the 2019 baseline |
|---|---|
| 2027 | 13.625% |
| 2028 | 16.25% |
| 2029 | 18.875% |
| 2030 | 21.5% |
- Applicable to container ships of 5,000 GT and above and other designated ship types.
- Guidelines may take effect soon after approval; amendments to MARPOL Annex VI itself are expected no earlier than 2030.
ITEM 885 Item 885 | Onboard carbon capture and storage OCCS
- Expected entry into force: 2030-01-01
- The IMO is establishing an OCCS regulatory framework with the goal of allowing the capture, transport, transfer, permanent storage or reuse of CO₂ without causing additional environmental risks.
- It will address emissions to air, discharges to the sea, CO₂ traceability, reception facilities, data recording and GHG-reduction accounting methods.
- Major work is expected to be completed in 2028, with final scope of application yet to be determined.
ITEM 637 Item 637 | MARPOL Annex IV Sewage Management
- Expected entry into force: 2031-06-01
- Information cited by LR indicates that a high proportion of tested ships failed to meet discharge standards despite carrying approved STPs, largely because of maintenance and performance failures.
- A Sewage Management Plan and Sewage Record Book are proposed.
- New ships of 400 GT and above, and ships below 400 GT certified to carry more than 15 persons, would need an SMP from construction.
- Existing ships would need an SMP by the renewal survey, followed by annual surveys.
- All MARPOL Annex IV ships are required to maintain an electronic or paper SRB approved by the Administration.
ITEM 572 Item 572 | Comprehensive Review of the STCW Convention and Code
- Expected entry into force: 2031-07-01
- The gap analysis identified more than 500 issues requiring further consideration, and the work has now entered the formal revision stage.
- Adoption is expected in 2029 or 2030, with possible entry into force in 2031 or 2032.
- The revision may change existing requirements for seafarer training, certification of competency and revalidation.
ITEM 497 Item 497 | MASS Code
- Expected mandatory entry into force: 2032-01-01; the report also notes that 2036 is more realistic
- The non-mandatory, goal-based MASS Code has been adopted and is scheduled to take effect on 2026-07-01 as a bridge to the future mandatory Code.
- The initial mandatory Code is expected to focus on cargo ships, with passenger ships excluded for the time being.
- It will cover both ships and Remote Operations Centres and establish a framework for MASS/ROC certificates and records.
- The original four degrees of autonomy were used only for the Regulatory Scoping Exercise; future classification may instead address the autonomous capability of specific systems or functions.
ITEM 586 Item 586 | Comprehensive Revision of SOLAS Chapter III and the LSA Code
- Expected entry into force: 2032-01-01 or later
- The complete life-saving sequence—alerting, muster, embarkation, abandonment, survival while awaiting rescue, man overboard, recovery and transfer—will be reorganized on a goal-based basis.
- The broad application is expected to remain cargo ships of 500 GT and above and all passenger ships.
ITEM 589 Item 589 | Amendments to MSC.402(96)
- Expected entry into force: 2032-01-01
- The amendments will address authorized service providers, manufacturer certification programmes, personnel certification, access to tools, documentation and training, and inconsistent terminology.
- The make, type, model, and series definitions have been initially established.
- Expected to apply to all passenger ships and cargo ships of 500 GT and above engaged on international voyages.
ITEM 590 Item 590 | Fire Detection and Control in Container Ship Cargo Holds and on Deck
- Expected entry into force: 2032-01-01
- IMO is developing SOLAS II-2/FSS Code amendments for early detection and effective fire suppression of container cargo in holds and on deck.
- Key risk control options:
- Fixed fire detection in cargo holds
- Fixed fire detection for containers on deck
- Portable infrared thermal imaging cameras
- Water-mist lances and extended water-mist applicators
- Remote-controlled mobile or fixed water monitors
- Fixed CO₂ systems
- Active or passive hatch-cover protection
- Further work will address video fire detection, the quantity of firefighters’ outfits, shore-side supply-chain training, reliability of shipper declarations, port container scanning and crew training.
- It is expected to apply to container ships of 500 GT and above constructed on or after 2032-01-01.
ITEM 608 Item 608 | Automatically Self-righting or Canopied Reversible Liferafts
- Expected entry into force: No earlier than 2032-01-01
- New cargo and passenger ships would generally be required to carry automatically self-righting or canopied reversible liferafts; liferafts with a capacity of 12 persons or fewer would be excluded.
- New requirements would address stability, self-draining, self-righting, canopies on both sides and accessibility of equipment.
- The transition periods under discussion: 3 years for passenger ships and 5 years for cargo ships.
ITEM 610 Item 610 | Revision of the 2010 FTP Code
- Expected entry into force: 2032-01-01
- The revision will accommodate new fire-protection systems and materials, incorporate existing unified interpretations and update ISO fire-test standards.
- Includes H-class division testing, multi-purpose penetration/transit, horizontal A-class hatch, and references to plastic pipe usage guidelines.
- The changes will affect shipyards, designers, manufacturers and test laboratories.
ITEM 721 Item 721 | Conventional and Non-conventional Propulsion/Steering Systems
- Expected entry into force: 2032-01-01
- Current SOLAS requirements do not fully address integrated propulsion and steering systems such as azimuth thrusters, pods, waterjets and Voith Schneider propellers.
- Planned additions:
- SOLAS II-1/28-1: Astern propulsion and stopping capability
- SOLAS II-1/29-1: Steering performance, failure tolerance, control systems and power supplies
- In waters where navigation requires special caution, ships equipped with multiple steering systems may be required to activate more than one system at the same time.
- Navigation and maintenance personnel must be familiar with the ship’s manoeuvring characteristics.
- It is expected to be applicable to new ships contracted on or after 2032-01-01, keels laid on or after 2032-07-01, or delivered on or after 2036-01-01.
ITEM 850 Item 850 | Ventilation of Partially Enclosed Lifeboats
- Expected entry into force: 2032-01-01
- The goal is to prevent prolonged CO₂ concentrations above 5,000 ppm.
- Compliance may be achieved by mechanical ventilation providing at least 5 m³/h per person for 24 hours, natural ventilation openings of sufficient area and appropriately opposed arrangement, or another equivalent solution.
- The specific ventilation opening area is still under discussion.
ITEM 859 Item 859 | Consolidation of SOLAS II-2/9 Fire Containment Requirements
- Expected entry into force: 2032-01-01
- Existing unified interpretations and diagrams would be incorporated into SOLAS to clarify fire insulation of duct sleeves and the fire integrity of bulkheads and decks bounding adjacent spaces.
- LR expects limited substantive impact on clients; the work mainly consolidates and clarifies existing requirements.
ITEM 955 Item 955 | Enclosed Spaces Containing Nitrogen Receivers or Buffer Tanks
- Expected entry into force: 2032-01-01
- Proposed amendments to FSS Code Chapter 15 address enclosed spaces containing nitrogen receivers or buffer tanks associated with nitrogen-generator systems.
- The preliminary direction supports an interlock for mechanical ventilation and clarification of oxygen-detector locations.
- There is no formal draft yet, and the scope of application and technical requirements have not yet been determined.
ITEM 958 Item 958 | Batteries as the Main Source of Electrical Power and Lighting
- Expected entry into force: 2032-01-01
- Proposed amendments to SOLAS II-1/41 would allow lithium-ion batteries to replace the conventional two generating sets as the main source of electrical power and lighting.
- It is expected to apply to all passenger ships and cargo ships of 500 GT and above.
ITEM 979 Item 979 | Gasket Materials in Fixed Gas Fire-extinguishing Systems under the FSS Code
- Expected entry into force: 2032-01-01
- Proposed amendments to FSS Code Chapter 5 would exclude gaskets from the requirement for materials to have a melting point above 925°C.
- It is expected to be applicable to both new and existing ships.
ITEM 1014 Item 1014 | LRIT financial model
- Expected entry into force: 2032-01-01
- The proposal would allow coastal States to obtain standard six-hourly LRIT position reports free of charge.
- The rate model under discussion is US$0.25 × 0/1/2/6, and different multiples correspond to routine reports, location requests, polling, and transmission interval changes.
- This may expand coastal-State use of LRIT, while reducing revenue for some data centres and service providers and changing the allocation of costs.
ITEM 953 Item 953 | Update of Regulations for Nuclear-powered Ships
- Expected entry into force: 2036-01-01
- IMO is reviewing SOLAS Chapter VIII and the Nuclear Code to reflect decades of technical and operational developments.
- The revision is expected to use goal-based standards and apply to nuclear-powered passenger ships on international voyages and nuclear-powered cargo ships of 500 GT and above.
ITEM 975 Item 975 | Legally Binding Biofouling Framework
- Entry into force: Not yet estimated
- IMO has agreed to develop a standalone mandatory framework for biofouling management to reduce the transfer of invasive aquatic species.
- Provisions, rules, appendices and supporting guidelines will be established based on the 2023 Biofouling Guidelines, in-water cleaning guidance, etc.
- Future shipowners may be required to demonstrate continued management of biofouling with hull maintenance, cleaning and protective measures.
PART 4 · REGULATION STATUS
7. Part 4 | Proposed new requirements
These items are at the work-programme or early-proposal stage; their scope and technical requirements have not yet been settled. They should be used to understand the likely regulatory direction rather than as a compliance basis.
ITEM 737 Item 737 | Environmental Risks of Plastic Pellets Transported by Sea
- Following the 2021 casualty involving MV X-Press Pearl, which released large quantities of plastic pellets, IMO is developing mandatory requirements.
- A new Code may be developed under MARPOL Annex III, SOLAS, or a combined framework under both instruments.
- It is expected to apply to all ships transporting plastic pellets and may involve classification, packaging, container loading and declaration requirements.
ITEM 971 Item 971 | NOx control for low-load engine operation
- The current E2/E3 test cycle does not adequately cover actual operations below 25% load, and AIS studies show that modern ships spend 20–45% of the time in this range.
- In the future, low-load NOx emission reduction methods, verification methods for continued compliance with certified configurations on board, and emission reduction strategy failure determination and contingency procedures may be added.
- The existing NOx Technical Code threshold of 130 kW and above is expected to be retained.
ITEM 981 Item 981 | Prohibition of Other Fluorinated Fire-extinguishing Foams, Including PFAS
- Beyond PFOS, IMO is considering a broader prohibition on fluorinated substances in the PFAS family.
- The proposal is expected to cover both fixed and portable extinguishing media; existing foam would need to be delivered to suitable shore reception facilities.
- It may apply to both new and existing ships, with compliance required by the first relevant statutory survey after entry into force.
ITEM 983 Item 983 | Fire-extinguishing Systems for Methanol/Ethanol Fuel Fires
- IMO will develop certification standards for water-based and gaseous-agent fire-extinguishing systems for alcohol-fuel fires.
- Shipowners, shipyards and equipment manufacturers should monitor the fire-safety requirements developed alongside MSC.1/Circ.1621.
- The report anticipates possible application from 2032-01-01 to ships using methanol or ethanol as fuel.
ITEM 984 Item 984 | Safety of Fischer–Tropsch Diesel
- Expected entry into force: 2032-01-01
- The auto-ignition temperature of Fischer–Tropsch diesel is approximately 208°C, below certain maximum permissible surface temperatures under SOLAS; dedicated fire-safety requirements are therefore needed.
- Possible amendments to SOLAS II-2 Part B and MSC.1/Circ.1321.
- The scope of application has not yet been determined, but is generally expected to cover all passenger ships and cargo ships of 500 GT and above.
SURVEYOR PRACTICE
8. Container Ship Newbuilding and Survey Checklist
This section is a practical reading order based on the original document. It is a practical summary rather than a separate list of regulations from the original text.
8.1 Design and plan-approval stage
- Check the building-contract, keel-laying and delivery dates so that a delivery delay does not unexpectedly trigger newer requirements.
- Confirm the applicable EEDI Phase 3 design reduction and the subsequent EEXI/CII operational strategy.
- For LNG and other low-flashpoint-fuel ships, verify the 2026 and 2028 IGF Code requirements for:
- fuel containment and A-60/cofferdam
- pressure relief
- bunkering interface
- ventilation
- hazardous area classification
- fuel supply redundancy
- For new container ships of 20,000 GT and above from 2028, confirm the emergency towing arrangements.
- Allow for the 2028 standards in pilot ladders, accommodation ladders and combination pilot transfer arrangements.
- Track new requirements for container fires in 2032 to avoid adding fixed detection, water cannon or hatch protection to new ships late in the design.
8.2 Construction and equipment installation phase
- Lifting appliances and loose gear: SWL, load tests, certificates, permanent markings and registration.
- Fire-extinguishing foam: Confirm PFOS-free and take inventory of PFAS risks ahead of time.
- IHM: MD/SDoC integrity, supplier information, shipyard preparation and delivery certification.
- Water-level detectors: do not treat conventional bilge alarms as a substitute on multiple-hold container ships.
- LNG fuel systems: bunkering-pressure compatibility, ventilation between DBB valves, gas detection, PRV discharge and hazardous areas.
- Use the latest formats for shipboard IMO documentation, including DCS, SEEMP, BWMP and BWRB records.
8.3 Sea trials, delivery and initial survey
- Complete test evidence should be retained for emergency towing, steering, reversing and stopping performance.
- For pilot transfer arrangements, lifting appliances, life-saving appliances and fire-safety systems, verify consistency among the physical arrangement, operating procedures, certificates and maintenance intervals.
- For BWMS, verify not only the commissioning test but also the maintenance regime, alarms, bypasses, failure reporting and contingency procedures.
- Confirm that the IHM, IAPP, IEEC and Cargo Ship Safety Equipment/Construction certificate supplements match the equipment actually installed.
8.4 Operational ship management
- PFOS foam removal and shore disposal records.
- Retain the original mooring design concept, MBLSD, line identification and replacement records.
- Maintain annual/periodical inspection, thorough-examination and load-test records, together with the loose-gear register.
- ECA route planning: NOx/SOx applicable dates in the Canadian Arctic, Norwegian Sea, and Northeast Atlantic.
- Assess how tighter 2027–2030 CII Z factors affect speed, routing, utilization and retrofit investment.
- Before the 2028 BWM amendments, establish auditable records for maintenance, failures, repairs and crew familiarization.
REFERENCE
9. Abbreviations
| Abbreviation | English | Plain-language meaning |
|---|---|---|
| AFS | Anti-Fouling Systems | Anti-fouling systems |
| BWMP | Ballast Water Management Plan | Ballast Water Management Plan |
| BWMS | Ballast Water Management System | ballast water management system |
| CII | Carbon Intensity Indicator | carbon intensity index |
| DASR | Document of Authorization to conduct Ship Recycling | Authorization document for a ship recycling facility |
| DCS | Data Collection System | Fuel consumption data collection system |
| ECA | Emission Control Area | emission control area |
| EEDI | Energy Efficiency Design Index | Design-efficiency index for new ships |
| EEXI | Energy Efficiency Existing Ship Index | Energy-efficiency index for existing ships |
| EIAPP | Engine International Air Pollution Prevention Certificate | Engine International Air Pollution Prevention Certificate |
| FSS Code | International Code for Fire Safety Systems | Code for fire safety systems |
| HFO | Heavy Fuel Oil | Heavy fuel oil |
| IAFSC | International Anti-Fouling System Certificate | International Antifouling System Certificate |
| IBTS | Integrated Bilge Water Treatment System | Integrated bilge water treatment system |
| IGF Code | International Code of Safety for Ships Using Gases or Other Low-flashpoint Fuels | Safety Code for ships using gases or other low-flashpoint fuels |
| IHM | Inventory of Hazardous Materials | List of Hazardous Materials |
| IMDG Code | International Maritime Dangerous Goods Code | International Maritime Dangerous Goods Code |
| LSA Code | International Life-Saving Appliance Code | Code for life-saving appliances |
| MASS | Maritime Autonomous Surface Ship | Maritime autonomous surface ships |
| MBLSD | Ship Design Minimum Breaking Load | Ship-design minimum breaking load |
| MLC | Maritime Labour Convention | Maritime Labour Convention |
| OCCS | Onboard Carbon Capture and Storage | Onboard carbon capture and storage |
| PFAS | Per- and polyfluoroalkyl substances | Per- and polyfluoroalkyl substances |
| PFOS | Perfluorooctane sulfonic acid | PFOS |
| RMSS | Recognised Mobile Satellite Service | Recognized mobile satellite service |
| ROC | Remote Operations Centre | remote operations center |
| SEEMP | Ship Energy Efficiency Management Plan | Ship Energy Efficiency Management Plan |
| SMP | Sewage Management Plan | sewage management plan |
| SRB | Sewage Record Book | sewage record book |
| STP | Sewage Treatment Plant | Shipboard sewage treatment plant |
| SWL | Safe Working Load | Safe load for working operations |
| VDES | VHF Data Exchange System | VHF data exchange system |
IMPORTANT NOTES
10. Important notes
- The LR report notes that SOLAS amendments generally follow a four-year cycle, with the next principal entry-into-force date on 2028-01-01; exceptional items may still be advanced.
- New-ship requirements often use three concurrent thresholds—building contract, keel laying and delivery. A delivery delay can unexpectedly bring an original design within a newer regulatory regime.
- “All ships” means all ships within the scope of the relevant Convention, Annex or chapter—not every type of marine craft.
- Trading area, fuel type, ship service and equipment choices can all change actual applicability.
- Parts 3 and 4 summarize LR’s view of ongoing IMO/ILO work. Formal plan approval, survey and compliance decisions must use the latest resolutions, circulars, flag State instructions and classification rules.
Main reference: Lloyd’s Register, Future IMO & ILO Legislation Summer 2026, Containerships edition.