IMO III 11: Finalized guidance on remote surveys, audits and verifications

The 11th session of the IMO Sub-Committee on Implementation of IMO Instruments (III 11) took place from 21 to 25 July 2025. The Sub-Committee completed guidance on remote surveys, ISM audits and ISPS verifications and added Industrial Personnel (IP) Code items to the harmonized survey guidelines. It also considered marine safety investigation reports, identifying parametric rolling, fire safety in self-unloading bulk carriers and inflatable lifejackets for consideration.

Relevant for ship owners and managers, Port State Control and flag states. 

Meeting highlightsIMO III 11: Finalized guidance on remote surveys, audits and verifications

  • Finalized guidance on remote surveys, ISM Code audits and ISPS verifications
  • Reviewed lessons learned from accident reports
  • Finalized amendments to the survey guidelines under the Harmonized System of Survey and Certification (HSSC)
  • Finalized amendments to procedures for Port State Control (PSC)

Remote surveys, ISM audits and ISPS verifications

Guidance on remote surveys, ISM audits and ISPS verifications were finalized, and the circular is expected to be approved by future sessions of the Maritime Safety Committee (MSC) and the Marine Environmental Protection Committee (MEPC).

Remote surveys

Portions of surveys may be carried out remotely, based on a risk assessment and the eligibility of the item for using remote methods. However, remote surveys cannot be performed for two consecutive years for the same survey items. In all cases, the survey plan needs to be approved by the flag administration.

Remote surveys are not accepted for SOLAS safety certificates and the International Load Lines Certificate for passenger ships.

International Safety Management (ISM) Code audits

ISM Code shipboard audits cannot be fully replaced by remote audits, and physical attendance will always be needed under normal circumstances.

Initial, renewal and interim company audits need physical attendance. Remote methods may be considered for annual audits and for interim audits when adding a new ship type to an existing Document of Compliance (DOC).

The performance of remote audits will need approval from the flag administration, and the audit plan needs to be sent well in advance to the flag administration for review and approval.

International Ship and Port Facility Security (ISPS) Code verifications

ISPS Code verifications can only under exceptional circumstances be carried out remotely, and only selected items are eligible for remote verification even in the exceptional circumstances.

Lessons learned and safety issues identified from the analysis of marine safety investigation reports

III 11 reviewed and approved a circular containing 36 lessons learned from marine casualties. These will be published on the IMO website.

A total of 39 individual casualty reports were analysed, and the following major contributing factors were identified: management (22), risk assessment (19), safety culture (20) and training (12). III 11 considered that these factors can be addressed by the ongoing comprehensive revision of the guidelines on the implementation of the ISM Code.

III 11 considered the following lessons learned and follow-up items:

  • Parametric rolling – forwarded to relevant Sub-Committees for consideration
  • Fire safety in self-unloading bulk carriers – a Correspondence Group will develop a proposal for new output
  • Inflatable lifejackets risks identified – a Correspondence Group will develop a proposal for new output
  • Accidents related to falls, enclosed spaces, and rescue and survival craft – ongoing work noted  

Measures to harmonize Port State Control (PSC) activities and procedures

III 11 finalized amendments to the “Procedures for Port State Control”. The revised consolidated PSC procedures, including amendments agreed at III 10 in 2024, are expected to be adopted at Assembly 34 in December 2025 and enter into force on 1 January 2026.

Guidelines for Port State Control Officers (PSCOs) on security aspects were added as a new Appendix 20. It clarifies roles and responsibilities between PSCOs and Duly Authorized Officers (DAOs) and adds new guidance to help PSCOs identify potential security concerns and escalate appropriately.

III 11 discussed the general issue of differing interpretations of mandatory provisions between flag states and port states. Regarding the specific matter of inspecting escape arrangements from machinery spaces, it was noted that
MSC 110 had encouraged PSC authorities to adopt a pragmatic approach, as outlined in MSC.1/Circ.1689, while the Committee continued to consider potential clarifications to the relevant technical regulations. III 11 reminded flag states and Recognized Organizations (ROs) of their obligation to issue certificates in accordance with paragraph 1.2.6 of the PSC procedures and emphasized to port states the importance of adhering to paragraph 1.2.5 when conducting PSC inspections.

III 11 also discussed inconsistent application of ISM Code-related deficiencies across PSC regimes, and the development of objective criteria to assess manning levels. No changes were made to the PSC procedures. III encourages regional PSC regimes to conduct internal reviews and training to improve consistency. It also emphasizes that flag states, not PSCOs, are responsible for determining minimum safe manning.

III 11 updated Model Course 3.09 on Port State Control.

Updated survey guidelines under the Harmonized System of Survey and Certification (HSSC)

III 11 finalized updates to the “Survey Guidelines under the Harmonized System of Survey and Certification (HSSC)”, and the “Non-Exhaustive List of Obligations under Instruments Relevant to the IMO Instruments Implementation Code (III Code)”. Both documents are expected to be adopted at Assembly 34 in December 2025 and enter into force on 1 January 2026.

The updated HSSC guideline includes provisions for the IP Code. Provisions related to the Anti-fouling System (AFS) Certificate were deleted, as the AFS Convention does not provide for a harmonized survey and certification system.

The Correspondence Group for the survey guidelines under the HSSC and the non-exhaustive list of obligations was re-established. The Correspondence Group will also consider matters related to unlawful practices associated with fraudulent registration and fraudulent registries of ships, and consider if circulars MSC/Circ.1140 and MEPC/Circ.424 on “Transfer of Ships between States” could be amended with measures to prevent such practices.

Unified Interpretations (UIs)

III 11 prepared a revision of MSC-MEPC.5/Circ.3 on UIs of the date of completion of the survey and verification on which the certificates are based. The revised UI clarifies that the “based on date” shall be the date of the initial or renewal survey. The amended circular will be sent to MSC and MEPC for approval.

Recommendations

DNV recommends that customers note the completed guidance on remote surveys, audits and verifications, the lessons learned from accident investigation reports, and updates on PSC matters.

As III is a Sub-Committee, all decisions concerning rules, regulations and dates are subject to further consideration and approval by the Maritime Safety Committee (MSC), Marine Environment Protection Committee (MEPC) or by the Assembly.

Contact

  • For customers:
    DATE - Direct Access to Technical Experts via My Services on Veracity.
  • Otherwise:
    Use our office locator to find the nearest DNV office.