IMO MSC 111 Key Notes

Executive Summary

MSC 111 at a glance: from technical feasibility to regulatory implementation

This session marks a significant update to maritime safety regulation in response to new fuels, new communications, new survey technologies and autonomous ships. For owners, yards, class societies and equipment makers, the key is not only when requirements enter into force, but building a verifiable compliance pathway early in newbuild design, crew training, equipment selection and management systems.

5Major topic groups

2028Cluster of amendments

2032Mandatory MASS code target

NowGuidelines already apply

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Practical notes for industry

Immediate action: Crew training guidelines for hydrogen, ammonia and methanol are already in effect. Review training matrices and SMS documentation early.
Newbuild projects: IP Code, Load Line, SRtP, IGC/IGF and related updates hinge on contract, keel and delivery dates. Confirm applicability at the design stage.
Long-term watchlist: Mandatory MASS regulation targets 2032 but may slip in practice. Keep tracking MSC 112 and subsequent EBP discussions.

Key Effective Dates

Important effective dates at a glance

From a project-management perspective, map these dates into newbuild specifications, design review and compliance tracking sheets.

Immediate effect

Hydrogen fuel ship safety guidelines, Electronic Navigational Publications (ENP) guidelines, navigation and communication software maintenance guidelines, and methanol/ethanol and ammonia crew training guidelines.

2026.07.01

Non-mandatory MASS code enters into force; ammonia cargo as fuel guidelines take effect.

2028.01.01

VDES introduction, 2011 ESP Code amendments, GMDSS-related SOLAS amendments and other requirements begin to apply.

2028.07.01

IGC Code amendments, IGF Code and SOLAS II-1 amendments expected to enter into force.

2031–2032

Free-fall lifeboat amendments apply from 2031; IP Code delivery applicability and mandatory MASS code target fall in 2032.

Maritime Autonomous Surface Ships

Maritime Autonomous Surface Ships (MASS)

MSC 111 moves MASS from conceptual debate toward a global regulatory framework, with ROC, master responsibility and ISPS applicability among the key discussion points.

Adopted

Non-mandatory MASS code formally adopted

Establishes a foundational regulatory framework for autonomous ships, filling gaps in how SOLAS and related conventions apply to MASS. The session confirmed that a Remote Operation Centre (ROC) may be treated as a location directly associated with the navigation bridge; when crew are on board, the master must be physically present. ROCs should also fall under the ISPS Code.

Effective: 1 July 2026

Ongoing

Mandatory MASS code development launched

The Experience-Building Phase (EBP) framework draft will continue at MSC 112. The target entry-into-force date remains 1 January 2032, but the Committee acknowledged that 2036 may be more practicable. MASS and ROC certificate templates are examples only; each Administration must develop its own formats.

Target effective date: 1 January 2032

Alternative Fuels & New Technologies

Alternative fuels and new technology safety requirements

This session clarified regulatory boundaries for hydrogen, ammonia, LPG, ethane, CO₂ cargo and low-flashpoint fuels.

Approved

IGC Code amendments: gas carriers

Amendments cover ammonia, LPG and ethane as fuel, CO₂ cargo transport and related topics. To address industry concerns on retroactive application, a three-date system applies: contract date, keel-laying date and delivery date. The IGC Code is also confirmed not to apply to non-gas carriers, reinforcing a one-ship-one-code approach.

Expected effective: 1 July 2028 (after adoption at MSC 112)

Approved

IGF Code and SOLAS II-1 amendments

Amendments confirm that the IGF Code does not apply to gas carriers, and harmonise definitions of "gaseous fuel" and "low-flashpoint fuel" across SOLAS and the IGF Code, removing past inconsistencies that created design and approval uncertainty.

Expected effective: 1 July 2028

Approved / Immediate effect

Hydrogen, ammonia and methanol/ethanol fuel guidelines

Interim guidelines on hydrogen as marine fuel take immediate effect, covering liquid and compressed hydrogen under a goal-based framework. Interim guidelines on ammonia cargo as fuel were approved, supporting IGC Code regulation 16.9. Crew training guidelines for methanol/ethanol and ammonia fuels were also approved, using LNG training standards as a development baseline.

Hydrogen and training guidelines: immediate effect

Ship Design & Construction

Ship design and construction (SDC)

These updates have practical impact on newbuild design, stability calculations, structural survey and passenger-ship safe return to port analysis.

Adopted

IP Code: industrial personnel weight standard raised

The stability calculation basis increases from 75 kg to 90 kg for new ships contracted on or after 1 January 2028.

Applies to contracts from 2028.01.01

Adopted

1988 Load Line Protocol amendment

Open-deck guardrails must be at least 1 m high to reduce crew fall-overboard risk in heavy weather. Applies to new ships of 24 m or more with keels laid on or after 1 January 2028.

Applies to keels laid from 2028.01.01

Adopted

2011 ESP Code: Remote Inspection Techniques (RIT)

Allows remote inspection techniques as an alternative to close-up structural survey. RIT service-provider certification is valid for three years and must meet Annex 4 performance requirements.

Effective: 1 January 2028

Approved

Passenger ship SRtP explanatory notes revision

Expands scope to include alternative fuels and the full lifecycle. Adds system categories 1A, 1B, 2 and 3, and recommends early Administration involvement at the design stage.

Applies to passenger ships of 120 m or more, or with three or more main vertical zones

Navigation, Communications, Search & Rescue

Navigation and communications (NCSR)

NCSR-related outcomes reflect the growing importance of digital navigation communications, diversified satellite positioning and software maintenance governance.

Adopted

VDES (VHF Data Exchange System) formally introduced

Amends SOLAS V/18, V/19 and the 1994/2000 HSC Code to allow ships to carry VDES equipment, enhancing ship communications and data exchange capability.

Effective: 1 January 2028

Adopted

BeiDou (BDS) performance standards and GNSS augmentation recognition

BDS performance standards are updated to support dual-frequency operation and improved positioning accuracy. Formal IMO recognition procedures are established for GNSS augmentation systems such as SBAS and RAIM.

Applies to equipment installed on or after 31 July 2028

Approved

Electronic Navigational Publications (ENP) and software maintenance guidelines

ENP usage guidelines take immediate effect, providing a unified direction for digital publications outside ECDIS. Navigation and communication equipment software maintenance guidelines cover cyber security, remote maintenance and electronic service reporting.

Immediate effect

Ship Systems, Equipment & Other Matters

Lifesaving equipment (SSE) and other key matters

Beyond lifesaving equipment, the session also advanced cyber risk management, FRP fire safety and the institutionalisation of remote audit and survey.

Adopted

Free-fall lifeboat LSA Code amendment

Adds design requirements for release-system test arrangements that do not require launching the boat. Minimum safety factor is 6, with corrosion-resistant materials that do not require coating or galvanising.

Applies to lifeboats installed on or after 1 January 2031

Approved

Cyber security and the ISPS Code

Revision 4 of the Guidelines on maritime cyber risk management was approved, incorporating IAPH guidance on cyber resilience for emerging technologies. A non-mandatory maritime cyber regulation roadmap was approved, targeting completion in 2028, with an intersessional working group expected in 2027.

Approved

FRP structure guidelines and remote survey guidelines

Revised interim guidelines on FRP fire safety were approved, adding test methods for load-bearing and non-load-bearing components, including temperature-based and deflection-based options. Guidelines on remote survey, ISM audit and ISPS verification were also finalised, giving clearer regulatory support to remote practices developed after the pandemic.

Recommended follow-up checklist

Use these items in project meetings, regulatory tracking sheets or newbuild specification review checklists.

01 | Design phase Confirm how contract, keel and delivery dates affect applicability of IP Code, Load Line, IGC/IGF, SRtP and ESP Code requirements.

02 | Operations Update SMS, crew training matrices and alternative-fuel operating procedures, especially for hydrogen, ammonia and methanol/ethanol requirements.

03 | Equipment & suppliers Track certification requirements for VDES, BDS, ENP, software maintenance, remote inspection techniques and lifeboat release systems.

For shipowners: The priority is turning effective dates into practical checkpoints for fleet management and newbuild projects.

For class societies and surveyors: The priority is clarifying review bases, certificate formats, remote survey boundaries and Administration acceptance early.