IMO 11th Session on Implementation of Instruments (III 11) – Key outcomes
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The International Maritime Organization (IMO) Sub-Committee on Implementation of IMO Instruments (III 11) met in London from 21–25 July 2025, addressing major topics set to impact ship operations, port state control inspections, and global maritime safety standards. At Deep Bridge Maritime Consulting, we break down the essential outcomes and actionable steps for shipowners, Designated Persons Ashore (DPAs), and maritime professionals committed to compliance and operational excellence.
Remote Surveys: New Guidance for Modern Maritime Compliance
A major achievement of this IMO session is the release of comprehensive new guidance for remote surveys, ISM Code audits, and ISPS Code verifications—a major step forward for digitalization in maritime compliance and vessel certification. This guidance recognizes the post-pandemic shift to remote work while ensuring statutory requirements are still met.
Key Points:
- General principles for using remote technology in statutory certification
- Detailed recommendations for remote surveys under the Harmonized System of Survey and Certification (HSSC)
- Procedures for remote ISM Code and ISPS Code verifications
Remote audits cannot fully replace physical attendance for interim ISM audits or most ISPS Code verifications, except under extraordinary circumstances. For security matters, physical attendance is the standard. The IMO is expected to formally adopt this guidance in 2026.
Port State Control Inspections: Enhanced Security and Consistency
Draft amendments to the 2023 Procedures for Port State Control (PSC) were finalized, with new guidelines for Port State Control Officers (PSCOs) focusing on vessel security and documentation. These changes, entering into force January 2026, aim to make inspections more focused and consistent.
Key Points:
- Clearer steps for addressing security deficiencies
- PSCOs may not access Ship Security Plans without flag State involvement
- Flag State approval is decisive where conventions are open to interpretation
For shipowners and DPAs, this means security systems and documentation must be robust and ready for targeted inspection. Deep Bridge Maritime Consulting can assist with PSC preparation, security audits, and crew training.
Survey Guidelines: Consistency and Clarity for Shipowners
The updated Harmonized System of Survey and Certification (HSSC) guidelines incorporate all new requirements through the end of 2025. Ongoing integration of Hong Kong Convention compliance (for ship recycling) provides interim solutions for owners.
Other clarifications include:
- Standardized interpretation of means of escape from machinery spaces
- A clear, uniform approach to recording “completion date of the survey” on statutory certificates
- This brings greater predictability and fewer disputes during port state control inspections.
Marine Safety: Lessons from Casualty Investigations
A central part of the III 11 session was the approval of 36 detailed case studies analyzing recent marine casualties. These case studies focus on practical lessons learned from incidents at sea, with particular emphasis on fire safety in cargo handling spaces—especially self-unloading bulk carriers, where conveyor belts and fire detection systems have been identified as critical points of risk. Another recurring topic is the safe use of inflatable lifejackets; the investigations highlighted several incidents where improper use or unfamiliarity with these devices led to dangerous situations, such as entrapment or failed deployment during emergencies.
Shipowners, DPAs, and safety managers are strongly encouraged to incorporate the findings from these case studies into their Safety Management Systems and crew training programs. Regular drills and toolbox talks focusing on fire prevention and the correct donning and removal of inflatable lifejackets are recommended as part of a proactive approach to safety.
Fraudulent Ship Registration: Protecting the Integrity of the Fleet
The fight against fraudulent ship registration continues to be a key IMO priority. During the session, the sub-committee reviewed the latest measures aimed at identifying and eliminating fake or improperly registered vessels from the world fleet. Fraudulent registrations undermine the integrity of international shipping, expose legitimate shipowners to unfair competition, and often involve vessels that do not meet statutory safety or environmental standards.
To address these risks, the IMO is working on improved procedures for flag administrations, including better information sharing when a ship is rejected for failing to meet legal requirements. Shipowners are advised to regularly verify the status and legitimacy of their vessel registrations, and to remain vigilant for signs of fraud in the industry. The strengthening of global standards will help protect compliant operators and contribute to safer, more transparent maritime operations.
Recommended Actions for Shipowners and DPAs
At Deep Bridge Maritime Consulting, we recommend the following steps to align your operations with these new IMO requirements and stay ahead of the compliance curve:
1. Update Procedures and Management Systems
- Review and plan internal procedures to match the new remote survey and digital compliance standards.
2. Strengthen Security and Port State Control Readiness
- Audit vessel security systems, Ship Security Plans, and related training.
- Prepare crews for more focused PSC inspections in 2025 and clarify what information can be shared with PSCOs.
3. Maintain Accurate Survey and Certification Records
- Double-check that “completion date” and all certificate records follow the new guidelines.
- For vessels affected by the Hong Kong Convention, follow interim survey guidance.
4. Incorporate Safety Case Studies into Training
- Use lessons from IMO marine casualty reports to inform SMS updates and crew training.
- Address fire risks and life-saving appliance use in toolbox talks and drills.
5. Monitor Regulatory Updates
- Be proactive and track forthcoming IMO circulars and regulatory changes.
Summary:
The outcomes from the IMO’s III 11 session set a new standard for maritime safety, digitalization, and regulatory compliance. Deep Bridge Maritime Consulting stands ready to support shipowners, DPAs, and crews in navigating these changes, ensuring operational continuity and industry-leading safety standards.
Need support with remote audits, port state control readiness, or SMS improvements?
Contact Deep Bridge Maritime Consulting for tailored solutions, expert guidance, and hands-on training for your fleet.
