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From Policy to Practice: Shipping’s Regulatory Autumn Puts Proof on Trial

From Policy to Practice: Shipping’s Regulatory Autumn Puts Proof on Trial photo

The IMO has selected "From Policy to Practice: Powering Maritime Excellence" as the theme for World Maritime Day in 2026 and 2027. This choice couldn't come at a better time.

The last two weeks have highlighted an important issue: the challenge in the maritime industry isn't about having enough rules. It's about the gap between what is agreed upon in places like London and Brussels and what is actually happening in real-life situations on ships, such as in the engine room or regarding emissions data.

To start, let's look at the audit results. The IMO has finished its first cycle of the mandatory Member State Audit Scheme, auditing 168 Member States since 2016. This represents 94% of its members, making it one of the most extensive evaluations of maritime governance ever conducted.

The IMO reports that the findings, plans for corrective actions, and consolidated reports have revealed common areas that need attention, along with their underlying causes. However, they have not published a league table, and it seems unlikely they will. The second audit cycle will begin in July 2027, adopting a more risk-based and data-driven continuous monitoring approach.

This cautious approach makes sense but is less helpful for shipowners, managers, and charterers who need to evaluate the quality of oversight based on flag and organizations acting on their behalf.

A valid certificate indicates that a survey happened, but it doesn't alone verify the ship's condition when it really counts.
Port state control continues to address this gap, especially this autumn with a focused effort. The Paris and Tokyo Memoranda of Understanding are conducting a joint Concentrated Inspection Campaign from September 1 to November 30, 2026, to ensure the safety of cargo units and their transport.

Inspectors will work using a standard questionnaire. They will check if there is an approved Cargo Securing Manual on board and if it is being followed. They will also verify if enough approved portable securing devices are available and if fixed and portable devices are maintained properly.
Each vessel will undergo one CIC inspection per MoU during this campaign, with outcomes ranging from recorded deficiencies to detention. The results will be reviewed and reported back to both MoUs’ governing bodies, which could influence future regulations based on the data collected.

This is the most pressing compliance issue for operators of cargo-carrying ships today. It's also a significant test. While a Cargo Securing Manual is easy to create, proving that the lashing equipment on deck matches this manual and is well maintained is a much bigger challenge.
The same dissonance between documentation and reality is evident in carbon regulations.

On September 30, shipping companies met their second EU ETS surrender deadline, which covers 70% of verified emissions for 2025. For emissions generated in 2026, this number rises to 100%, and emissions of methane and nitrous oxide are now included alongside carbon dioxide.

The inclusion of methane is particularly important for LNG-powered vessels. Unburned methane from a dual-fuel engine now has a carbon cost. Factors like engine design, load profile, and verified slip performance have become significant commercial considerations.
At the same time, FuelEU Maritime has been fully enforced since January 1, 2025, limiting the greenhouse gas intensity of energy used on board. One regulation establishes a price for emissions, while another sets an intensity limit, using the same fuel and voyage data but rewarding and penalizing differently.

In the UK, the ETS has been in effect for domestic shipping since July 1, focusing on cargo and passenger ships over 5,000 GT on voyages between UK ports and while docked. Offshore vessels will join starting January 1, 2027. The first surrender, covering both 2026 and 2027, is due on April 30, 2028, with the tonnage threshold set for review in 2028.

Brussels has proposed further changes. On July 17, the European Commission published two proposals revising the ETS Directive and amending the MRV and FuelEU regulations, which the Council and European Parliament are evaluating this autumn.

The maritime components of these proposals are significant. Certain vessel types as small as 400 GT would be included, along with offshore vessels between 400 and 5,000 GT beginning in 2031. Up to 110 million allowances, valued at approximately €15 billion, will be set aside to support sustainable fuels, electrification, and wind propulsion.

Regulations concerning non-EU transshipment ports will become stricter, and offshore working sites in EU waters will be treated like ports of call. Reporting for the ETS, MRV, and FuelEU will be consolidated into a single submission, potentially reducing annual compliance costs by 10 to 20% according to the Commission.

Importantly, the proposal allows for a review of the ETS if the IMO adopts a global carbon pricing measure to avoid double payments by owners. An agreement is expected in 2027, with implementation planned for 2028 or 2029.

Returning to London, the IMO Net-Zero Framework was approved in principle at MEPC 83 in April 2025 but failed to be adopted in the extraordinary session in October 2025. MEPC 84 later kept it alive in April and May this year but did not finalize it.

The 22nd intersessional working group met in London from September 1 to 4, with nearly 1,200 attendees. The chair noted a genuine readiness to present a text to MEPC 85, although work on guidelines and life cycle assessment has been postponed to the next session due to time constraints.

The timeline is now very tight. ISWG-GHG 23 meets from November 23 to 27. MEPC 85 follows from November 30 to December 3, and a rescheduled extraordinary session is expected to resume on December 4, pending confirmation by MEPC 85. If not needed, that day will serve simply as an additional meeting day for MEPC 85.

Until then, there is no globally adopted carbon price for shipping. Any statement, broker note, or charter provision that treats IMO levies as settled is jumping ahead of the current reality.

For owners considering LNG, methanol, ammonia, or biofuels, the situation is challenging. Investment decisions are being made amid two moving targets: an evolving European framework and a global framework that may or may not be adopted in December.

Additionally, the engine room faces its own adjustments. Amendments to the NOx Technical Code 2008 took effect on September 1, establishing a certification process for marine diesel engines undergoing substantial modifications or requiring certification for a NOx Tier not met during initial installation.

Remarkably, this certification process had never been specified before. The new amendments now allow testing of installed parent engines where no comparable test-bed engine exists.

This is a sensible fix for a long-standing issue. It also means that fuel conversions, injection changes, and Tier III upgrades must be certified under NOx regulations from the feasibility assessment stage rather than as an afterthought during commissioning. A second set of amendments regarding multiple engine operational profiles is set to take effect on March 1, 2027.

The introduction of new fuels also reveals gaps in emergency planning. The IMO's Research and Development Forum in Singapore on September 21 and 22, supported by the Maritime and Port Authority of Singapore and China, focused on pollution preparedness for various fuels, including LNG, LPG, methanol, ammonia, hydrogen, biofuels, and e-fuels.

Participants highlighted the need for clear response procedures for each type of fuel before any major incidents occur, not just afterwards. The forum served as preparatory work rather than establishing new regulations. However, the point remains: a port capable of supplying ammonia isn't automatically prepared to handle an ammonia leak.

Lastly, the issues of security and autonomy are also crucial. The ISPS Code has been under review since MSC 111 in May, following a submission from the United States regarding illicit trade and organized crime. The European Union is preparing submissions for MSC 112 in December, including proposals for amendments to the ILO/IMO Code of practice on port security.

Regarding autonomy, the optional MASS Code has been in effect since July 1. EU drafts for MSC 112 work on the framework and a plan for the experience-building phase. The IMO's roadmap indicates efforts towards a mandatory code starting in 2028, with adoption expected by July 2030 and enforcement beginning January 1, 2032.

However, key engineering questions remain underexplored. Areas such as remote machinery monitoring, redundancy, maintenance responsibilities, and accountability in the absence of engineers on board require much more attention than the current focus on navigation algorithms.

In summary, the recent developments point in a clear direction. The volume of regulations isn't decreasing; instead, the burden of proof is changing.

Carbon regulations now require verified fuel and voyage data. Port state controls are ensuring manuals align with actual practices. Engine certifications have established clear pathways for modifications. The audit scheme is transitioning to continuous, risk-based monitoring.
For technical managers, the key takeaway is straightforward: ships that best align their documentation, equipment, and data will be the most successful.

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Published 10.10.2026