The IMO Sub-committee on Implementation of IMO Instruments (III) met in London from 21 – 25 July 2025 for its 11th session where various issues were discussed.
The sub-committee on the Implementation of IMO Instruments (III) plays a key role in port State control data and updates HSSC survey guidelines biennially, as well as addresses implementation issues by coordinating with flag, port and coastal States.
Key outcomes of the 11th session:
Development of Guidance on Assessments and Applications of Remote Surveys, ISM Code Audits and ISPS Code Verifications
III 11 agreed the following:
- The draft Guidance related to ISPS remote verifications. Given the highly sensitive nature of the information involved in ISPS verifications, the use of remote verifications in place of in-person attendance has been limited to extraordinary circumstances, and only for interim, intermediate and additional shipboard verifications.
- The technical objectives in the draft guidance for remote methods to achieve a level equivalent to in person attendance. These objectives cover communication, interviews, and safety and are outlined in the revised Section 7 of Part A, now titled “Required Technical Objectives”.
- The draft guidance on the use of remote survey or audit outside the scope of a scheduled periodical survey or audit. Such surveys/audits may stem from unscheduled examinations either by a port State or flag State or their Recognised Organisation (RO). The guidance is outlined in the revised Section 10 of Part A.
The draft Guidance and the associated draft MSC-MEPC circular is expected to be submitted to MEPC 84 in April 2026 and MSC 111 in May 2026 for approval.
Additionally, III 11 agreed to keep the finalised guidance under review, based on the experience gained in conducting remote surveys, audits and verifications.
Scope of verifications carried out to issue interim certification under the ISM Code
While discussing the scope of audits for issuing interim Safety Management Certificates (SMCs) and Documents of Compliance (DoCs) under the ISM Code, III 11 confirmed that interim audit should not be fully replaced by remote audits, as previously endorsed by III 10.
An ambiguity was identified between section 4.8 of the 2023 Guidelines on implementation of the International Safety Management (ISM) Code by Administrations (resolution A.1188(33)) and the draft remote survey guidance. To resolve this, it has been recommended that the finalised guidance should be considered during the comprehensive revision of the guidelines on the implementation of the ISM Code by Administrations and companies, scheduled for 2026–2027, with completion targeted for 2028.
Method for developing and assigning a coding system to update the Survey Guidelines under the HSSC
While discussing methods for determining remote survey eligibility within the Survey Guidelines under the HSSC, a new column was added to indicate whether each survey qualifies for remote survey.
Harmonisation of Port State Control (PSC) activities
The draft amendments to the procedures were finalised and are expected to be adopted at Assembly 34 (December 2025) and to enter into force on 1 January 2026. III 11 agreed:
- The draft Guidelines for Port State Control Officers (PSCO) on Security Aspects as a new appendix 20 to the PSC procedures. The draft guidelines focus solely on the PSCO’s role and exclude elements specific to Duly Authorised Officers (DAO). They incorporate relevant parts of the Interim Guidance on Control and Compliance Measures to Enhance Maritime Security (MSC.159(78)), clarifying procedures when security deficiencies are found. The non-mandatory nature of Part B of the ISPS Code was reaffirmed, and it was noted that PSCOs may not access the Ship Security Plan without flag Administration consultation, and also DAO involvement is necessary when it is found that there are clear grounds that the security system is not working as required and that additional security measures need to be adopted.
- Updated appendix 21 – List of instruments relevant to port State control procedures – of the PSC procedures to include relevant new requirements such as 2024 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) (MEPC.395(82)) and Voluntary early implementation of the amendments to paragraphs 4.2.2 and 8.4.1 to 8.4.3 of the IGF code (MSC.551(108)).
Means of escape from spaces below the bulkhead deck and related implementation matters
While discussing the implementation matters related to means of escape from spaces below the bulkhead deck, III reminded flag States, port States and recognised organisations (ROs) that certificates, including equivalents, should comply with relevant convention provisions and should be interpreted in accordance with PSC Procedures.
Furthermore on the topic of marine casualties’ investigations, III 11 approved a draft circular with 36 case studies highlighting lessons from marine casualties. A new output proposal will address safety issues with conveyor belts and fire systems on such vessels. Furthermore, concerns about inflatable lifejackets were raised, focusing on entrapment risks and proper use during emergencies.
Survey guidelines under the Harmonized System of Survey and Certification (HSSC)
III 11 agreed on draft amendments to the 2023 HSSC Guidelines, aligning survey items with mandatory conventions, incorporating IP Code requirements, adding checks for non-harmonised conventions, and removing Anti-fouling System Certificate items due to lack of harmonisation.
The revised guidelines are expected to be adopted at Assembly 34 (December 2025) and are expected to enter into force on 1 January 2026.
Furthermore, III 11 supported developing survey guidelines for the Hong Kong Convention to be included in the HSSC Guidelines, though time constraints prevented inclusion in the 2025 edition. Until formal inclusion in 2027, the 2012 Guidelines (MEPC.222(64)) will serve as interim guidance, with MEPC 84 (April 2026) expected to endorse this approach.
In addition, III 11 also discussed measures to address fraudulent ship registration and registries, as invited by MSC 110. Due to limited time and lack of concrete proposals, the issue was referred to a correspondence group.
The group will review MSC/Circ.1140 – MEPC/Circ.424 and consider provisions for information sharing between flag Administrations.