AI performance standards for ship equipment
- PROPOSAL STAGE — NO AI-SPECIFIC IMO STANDARD
- No IMO work item on AI performance standards has been agreed.
- The IMO's invitation refers to a non-mandatory instrument.
MIW Intelligence Brief
The rules for machines that act are still being written
The IMO has noted a call for performance standards for AI in ship equipment and invited a proposal for a non-mandatory instrument, but no work on one has been agreed. Its mandatory autonomous-ship code runs on dates the Committee itself says may move. Its cyber code is still a work item. For engineers, the rules that bind a ship today are the ones already on board.
The Maritime Safety Committee's report of its 111th session and an EU Council agenda from July point the same way. Ships and the equipment on them are gaining functions that act, and the rules defining what those functions may do are unfinished. In three areas, AI equipment standards, the mandatory MASS Code and a maritime cyber code, the IMO's new work is at the stage of an invitation to propose work, a target or a code in development. None of it places a new mandatory requirement on an existing ship today. Nor does it displace what already applies: the company's safety management system under the ISM Code, where resolution MSC.428(98) encourages administrations to ensure that cyber risk is addressed; the class requirements that already apply to each ship; and, for new ships contracted on and after 1 July 2024, IACS UR E26/E27.1,2,6,8
Where each rule stands
Every line below is quoted from this brief. Follow the section links for context and sources.
Mandatory MASS Code
- Non-mandatory MASS Code ADOPTED · NON-MANDATORY
- Mandatory MASS Code EXPECTED — DATES MAY BE REVISITED
- The IMO has adopted the non-mandatory MASS Code; a mandatory version remains under development.
- It agreed to keep working towards 2030 for adoption, recognising that this target may need to be revisited.
Maritime cyber governance
- IMO maritime cyber code PLANNED — NON-MANDATORY
- IACS UR E26/E27 IN FORCE — NEW SHIPS ONLY
- The next layer is not yet written.
- IACS UR E26, … and UR E27, … apply in their revised form to new ships contracted for construction on and after 1 July 2024.
- On MIW's reading of that applicability, a ship already in service is not brought into scope by date. For those ships, the IMO instrument is resolution MSC.428(98).
1 / 3
AI in ship equipment: new work has been invited and proposed, not agreed
PROPOSALIMO RECORD
At MSC 111, which met from 13 to 22 May 2026, the Committee considered a paper from Austria and other co-sponsors, MSC 111/21/2. It set out the case for urgent development of performance standards for AI systems embedded in marine equipment: navigational, radio and other ship systems. The Committee noted the paper and invited Member States and international organizations to work with the co-sponsors on a proposal for a new output: a non-mandatory instrument on the use of AI systems in safety-critical equipment, to be submitted at a future session.1,4,5
On 17 July 2026, the EU Council's Working Party on Shipping met to examine a draft Union submission to MSC 112, which sits in London from 14 to 18 December 2026. The draft proposes a new output to develop a recommendation on performance standards for AI systems embedded in navigational and communication equipment.1,2,3
Status. No IMO work item on AI performance standards has been agreed. The IMO's invitation refers to a non-mandatory instrument. The EU draft, as its agenda item describes it, proposes work towards a recommendation. Neither is an adopted standard, and neither is a requirement on any ship. MIW has read the agenda item, not the draft text. It has not confirmed that the submission reached the IMO in that form.1,2
2 / 3
The mandatory MASS Code: the dates are targets, and the Committee says so
ADOPTED · NON-MANDATORYMANDATORY CODE: EXPECTED
The IMO has adopted the non-mandatory MASS Code; a mandatory version remains under development. The non-mandatory Code was adopted by resolution MSC.595(111) in May 2026 and came into effect on 1 July 2026 as a voluntary instrument. It applies to cargo ships covered under SOLAS Chapter I, generally ships over 500 GT on international voyages.4,5
- May 2026 (MSC 111)
Non-mandatory MASS Code adopted, MSC.595(111); in effect from 1 July 2026
ADOPTED — VOLUNTARY
- December 2026 (MSC 112, 14–18 Dec)
Framework for an Experience-Building Phase to be developed
SCHEDULED
- 2028
Road-map milestone: development of the mandatory Code, including consideration of SOLAS amendments. A development stage, not a completion date
PLANNED PROVISIONAL
- By 1 July 2030
Expected adoption of the first mandatory MASS Code. MSC 111 set 2030 as the target completion year
EXPECTED — MAY BE REVISITED PROVISIONAL
- 1 January 2032
Planned entry into force, which depends on adoption first
EXPECTED — DESCRIBED AS AMBITIOUS PROVISIONAL
Provisional planning targets, not guaranteed dates (MIW engineering analysis).
The Committee's own report qualifies those dates. When MSC 111 extended the target completion year for finalising and adopting the mandatory Code to 2030, several delegations said the 2030 adoption and 2032 entry-into-force timeline appeared unrealistic, and suggested deferring entry into force to 2036. The Committee noted the working group's view that 2032 was ambitious. It agreed to keep working towards 2030 for adoption, recognising that this target may need to be revisited.1
“Treat the 2030 and 2032 milestones as provisional planning targets, not guaranteed dates.”
3 / 3
Cyber: a class rule for new ships, a management-system expectation for existing ones, a code still in drafting
IN FORCE — NEW SHIPS (CLASS)IMO CODE: PLANNED
IACS UR E26, Cyber Resilience of Ships, and UR E27, Cyber Resilience of On-Board Systems and Equipment, apply in their revised form to new ships contracted for construction on and after 1 July 2024. The original versions, which applied to new ships from 1 January 2024, were withdrawn. According to ABS's summary of the rules, they cover passenger ships on international voyages, cargo ships and high-speed craft of 500 GT and upwards on international voyages, mobile offshore drilling units of 500 GT and upwards, and certain self-propelled mobile offshore units. They may be used for other ships only as non-mandatory guidance. In ABS's description, E26 is intended for the ship's design, construction, commissioning and operational life, and is organised under five functions: identify, protect, detect, respond and recover. It requires a cyber resilience test procedure to be developed for the vessel. E27 is aimed at third-party equipment suppliers.6,7
On MIW's reading of that applicability, a ship already in service is not brought into scope by date. For those ships, the IMO instrument is resolution MSC.428(98). It encourages administrations to ensure that cyber risks are addressed in the company's safety management system no later than the first annual Document of Compliance verification after 1 January 2021. The IMO's guidance is MSC-FAL.1/Circ.3/Rev.4.6,8
The next layer is not yet written. At MSC 111 the Committee agreed to be an associated organ to the FAL Committee's output on development of a non-mandatory maritime cyber code, with a target completion year of 2028. It approved the road map, and approved a joint FAL–MSC expert group to meet in 2027, subject to Council endorsement.1
“Until it does, the answer on each ship is the one written into its own procedures, and the test is authority, not intelligence.”
What it means on board: MIW engineering analysis
This section is MIW's engineering judgement, drawn from the developments above. It is not a rule, a class requirement or an IMO interpretation.
From function to fallback: four checks for any equipment function that recommends or acts
- AI-enabled function Check: “what it may do without a person”
- Detection / decision Check: “how it fails”
- Human authority and override Check: “who on the bridge or in the engine room has authority to override it”
- Safe fallback Check: “what the fallback arrangement is”
For Chief Engineers
- No IMO performance standard written for AI functions in ship equipment has been agreed, and work on one has not been agreed either. That gap does not remove anything that already governs the equipment. The references on board remain the maker's instructions, the company's safety management system and the class requirements. For any equipment function that recommends or acts, check that they say what it may do without a person, how it fails, who on the bridge or in the engine room has authority to override it, and what the fallback arrangement is. Raise any gap with the company under its procedures, not with a local workaround.1,2
- On an existing ship, the safety management system is where MSC.428(98) encourages cyber risk to be addressed, so that is where such a function's record belongs, in the form the company decides. A function that can act on machinery is a cyber-risk item as well as an operational one. Changes to it, including software updates and changes to its settings or its authority, belong in the company's management-of-change procedure and in any class approval it requires.8
- Treat the 2030 and 2032 milestones as provisional planning targets, not guaranteed dates. Nothing in the mandatory MASS Code binds a ship today, because it does not yet exist. The voluntary Code is a reference for any remote or autonomous trial. It does not replace class requirements, the company's procedures or the existing lines of authority on board.1,4,5
- On a newbuilding inside the E26/E27 scope, E26 requires a cyber resilience test procedure for the vessel, and it is intended for operational life as well as for build and commissioning. MIW's sources do not describe continuous testing in service, and MIW has not read the UR text. When and how the procedure is demonstrated is for class and the company to set. Expect the engine department to take part when it is, alongside the maker and the IT contractor.6,7
For maritime technology providers
- E27 already places cyber-resilience expectations on the suppliers of systems and equipment for new ships. For those ships, a security capability is a class matter, not a marketing feature.6,7
- If MSC 112 agrees a new output on AI performance standards, makers of navigational and communication equipment would be among the most directly concerned. Until any such instrument exists, the strongest evidence a supplier can offer is a documented test of what the AI function does, where its authority stops, and how it hands control back.2
AssessmentThe three developments ask one question. What is a system on board allowed to do, on whose authority, and how would anyone know? For AI equipment, for autonomous ships and for cyber resilience, the IMO has not yet answered it in mandatory form for the existing fleet. Until it does, the answer on each ship is the one written into its own procedures, and the test is authority, not intelligence. MIW's next full issue will take this further.
Follow MIW Subscribe on LinkedIn
Watch next
| Date | Item | Status |
|---|---|---|
| 14–18 Dec 2026 | MSC 112: Experience-Building Phase framework; whether a new output on AI performance standards is agreed | SCHEDULED / PROPOSAL1,2,3,4,5 |
| 2027 | Joint FAL–MSC expert group on a non-mandatory maritime cyber code | PLANNED — subject to Council endorsement1 |
| 2028 | Non-mandatory maritime cyber code: target completion year · mandatory MASS Code: development milestone | PLANNED1,4,5 |
| By 1 Jul 2030 / 1 Jan 2032 | Mandatory MASS Code: expected adoption / planned entry into force | EXPECTED — MAY BE REVISITED1,4,5 |
Not included in this brief
- The text of the EU's MSC 112 submission
- MIW has read the Council agenda item only. The draft (ST 11265/2/26) and the final IMO document were not read.
- The revised MASS road map annex (MSC 111/22/Add.1)
- Not read. The 2028 milestone is taken from the IMO's own autonomous-shipping page.
- The IACS UR E26/E27 texts
- Not retrieved. The scope above comes from the IACS press release and ABS's class-society summary.
- EU AI Act application dates for AI in marine equipment
- Held: the Official Journal text has not been read. No date is printed.
Sources and provenance
- MSC 111/22 — Report of the Maritime Safety Committee on its 111th session —
- CM 3687/1/26 REV 1 — Working Party on Shipping, notice of meeting and provisional agenda (17 July 2026) —
- IMO Maritime Safety Committee (MSC) 112th session — event listing —
- Autonomous shipping (hot topic page, incl. MASS Code timeline) —
- Meeting summary: Maritime Safety Committee, 111th session (MSC 111), 13–22 May 2026 —
- IACS UR E26 and E27 press release (revised applicability) —
- ABS Regulatory News No. 14/2023 — IACS Unified Requirements on Cyber Resilience —
- Maritime cyber risk (standing page; MSC.428(98), MSC-FAL.1/Circ.3/Rev.4) —