Maritime AI enters its accountability phase — from pilot to protocol. Plus: five things everybody missed from MSC 111.
The MASS Code cleared MSC 111 last week. If you followed the regulatory thread, you already know the headline. But here is what I keep thinking about: the framework does not care about your vessel type, your flag state, or which automation supplier your owner favours. It cares about whether the human in the loop — the officer of the watch, the duty engineer, the shore operator — can explain, override, and take responsibility for what the machine decided.
That is a different standard from what most of us trained for. STCW was built on the assumption that a competent officer is physically present and situationally aware. MASS changes the geometry — not necessarily the responsibility. The obligation to understand the system, intervene when it fails, and document why, lands squarely on the marine professional.
"MASS does not redistribute responsibility. It redistributes where you have to prove you exercised it."
The Maritime Autonomous Surface Ships (MASS) Code was formally adopted at MSC 111 (13–22 May 2026) as a non-mandatory instrument, effective 1 July 2026. A voluntary phase of at least two years follows; mandatory implementation is expected in a later phase under IMO transition planning, subject to future adoption timelines. It is goal-based — it sets outcomes rather than prescribing design solutions. For marine professionals, that distinction matters enormously. It puts the burden of demonstrating compliance on the operator and the crew, not just the shipbuilder or the software vendor.
Most commercial vessels will remain at Level 1 for the foreseeable future. But MASS introduces operational expectations that are likely to shape future design, procedures, and audit frameworks: any automated or AI-assisted function that influences navigation, power management, or safety should have a defined minimum risk condition — a state the system reverts to when it cannot complete its task safely.
For the maritime officer on watch, this means you should be able to answer three questions for any automated system in your machinery spaces:
1. What does this system do automatically, and what triggers its action?
2. What is its fallback — what state does it revert to on failure?
3. Is that fallback documented in your SMS and equipment manual, and have you drilled it?
MASS does not make these questions new. It formalises these expectations in a way that makes them more visible in future audit and assurance frameworks. PSC inspectors and class surveyors may increasingly expect documented answers as assurance frameworks mature.
MASS changes watchkeeping obligations for Level 2–3 vessels. STCW competency requirements for remote operation are under parallel review; expect amendment proposals by 2027.
AI-assisted machinery control must have documented override procedures and a minimum-risk fallback. IACS UR E26/E27 sets the cyber baseline for connected systems on new-builds contracted after 1 January 2024.
Remote operating centres become regulated spaces under Level 3–4. When crew are aboard, the master must be physically present. Remote operating centre competency and equivalence requirements are under development — STCW amendment proposals are expected by 2027.
Four outputs from MEPC 84 (27 Apr – 1 May 2026) have direct onboard implications. Two are immediate. Two are trajectory signals.
BWM from installed to operational. MEPC 84 amendments shift focus from a certified system to proof that it works. Surveyors will want a BWMS logbook showing pre- and post-treatment sampling records against the D-2 biological standard, consumable replacement dates, and alarm-response entries. If your BWMS logbook is a single sheet with three entries, it will not pass the new standard. Treat the BWMS the same way you treat the ORB: a live record, not a filing exercise.
SEEMP becomes a continuous improvement tool. The revised 2024 SEEMP Guidelines move SEEMP from a plan filed at class renewal to a document showing active management. Deviations from your CII reduction plan must be logged with the corrective action taken. Engine-load decisions, slow-steaming periods, and commercial speed-override requests all need a paper trail.
Biofuel NOx certification is use-case-specific. If your vessel is biofuel-capable or your owner is planning trials, NOx compliance must now be demonstrated per fuel type under MARPOL Annex VI Regulation 13 / NOx Technical Code. The NOx Technical File scope has been extended. This will become a survey finding if your NOx Technical File does not reflect the actual fuels in use.
MEPC 84 formally designated the North-East Atlantic as an ECA for SOx, PM, and NOx.
— ECA enters into force: 1 September 2027
— 0.10% sulphur and PM cap: 1 September 2028
— NOx Tier III: ships contracted on/after 1 January 2027; keel laid on/after 1 July 2027; delivered on/after 1 January 2031
For vessels on North Atlantic routes: verify now whether your engine meets Tier III NOx or whether an approved abatement pathway (SCR/EGR) is already in the NOx Technical File.
At the first safety equipment survey after 1 January 2026, fire-extinguishing foams must be verified PFOS-free — widely enforced through class and statutory survey pathways. The failure mode is not having the wrong foam; it is being unable to prove you have the right one.
Three accepted documentation pathways: (1) manufacturer PFOS-free declaration, (2) accredited lab test report confirming PFOS below 10 mg/kg, (3) Type Approval/MED certificate stating PFOS-free. Match one of these to the batch actually installed. If you cannot, raise the deficiency before the surveyor does.
New installations require certification before service under SOLAS Reg. II-1/3-13 (as inserted by MSC.474(102), in force 1 January 2024). Existing units require testing, examination, and maintenance records aligned with IMO guidance. Key failure modes: brake-holding failure, hydraulic leakage, degraded wire condition. Document overload test results, brake test dates, and wire condition inspections as a unified set.
VLSFO and ULSFO have different properties from HFO; lubricant BN selection must match the actual sulphur content of the fuel aboard. Poor matching accelerates deposits, injector fouling, and combustion instability. This appears as a PSC deficiency when cylinder condition records do not align with the BN of the cylinder oil in use. Confirm maker-approved lubricants and keep fuel changeover procedures tightly controlled.
1. Fleet-scale AI predictive maintenance. Remaining-useful-life (RUL) models fusing vibration, lube oil condition, pressure, and temperature with historical failure logs are now running at commercial scale. The alert an engineer receives is no longer "high vibration on bearing X" — it is "bearing X estimated to reach failure threshold in 14–21 days under current operating profile." The engineer still decides. The AI provides the evidence window. Sensor calibration and consistent oil-sampling are not optional — RUL accuracy degrades with dirty data.
2. AI voyage optimisation — G2 Ocean/DeepSea Pythia Augment on bulkers. Transfer-learning models using AIS and noon-report data generate route and speed recommendations in live commercial service. A risk specific to engineers: AI may recommend engine-load bands that coincide with torsional resonance zones. The AI does not know your engine's Campbell diagram. The engineer does. Cross-check AI-generated speed recommendations against your maker-approved safe operating envelope.
3. AI port gate — computer vision at container terminals. Computer vision systems for container and vehicle verification are in commercial use at multiple terminals. Practical value for a duty officer: fewer delays at the gate for spares clearance, faster crew change processing.
Level 3–4 autonomous operation. The GENBU (Japan, ClassNK certified) is the first commercial example of what is broadly equivalent to MASS Level 4 on a coastal route (pre-MASS Code classification — ClassNK's own notation predates the Code's adoption at MSC 111). The commercial container fleet is Level 1. The pathway to Level 2+ requires a STCW framework that does not yet exist.
AI-generated compliance decisions. DNV's RuleAgent can interpret class rules in natural language — it is a research aid, not a decision tool. AI-generated compliance outputs must still be signed off by a qualified person against formally approved documentation.
AI features deploy inside the MariApps smart PAL suite — FaultSenseAI (predictive engine health), smartAware (onboard surveillance), Intellicrew (crew management). Singapore-headquartered with significant India development presence; part of the international Schulte Group. Competitive advantage: AI embedded in an ERP many technical managers already use.
mariapps.comEdge sensors with cloud analytics for marine engine predictive maintenance. Commercial deployments with published case studies. Platforms of this type can provide advance maintenance warning windows depending on deployment quality and available data.
intangles.inShore-side AI for vessel tracking, cargo management, and voyage decision-support. Early-stage product — watch for pilot announcements with ship managers in H2 2026.
MSC 111 produced over 20 substantive regulatory outputs. Five items that affect ships trading today — or within two years — received almost no coverage.
The IMO is developing Engine Control Room Alert Management (ECRAM) performance standards, targeting finalisation at SDC 14 in 2028 and adoption at MSC 114. The work was triggered by the Viking Sky incident (March 2019), where low lube-oil levels in heavy seas caused dynamic oil sloshing, triggering a cascading trip of all online diesel generators. The ECR alarm system simultaneously flooded watchstanders with unprioritised alerts, critically delaying the correct response. Alarm flooding was not the root cause — but it was the human factors multiplier that turned a recoverable situation into an emergency.
The SDC Sub-Committee has already defined seven quality attributes that every ECR alert must meet:
ECR alarm management is moving toward formal performance-standard treatment under IMO development work. Existing vessels may find this framing increasingly referenced in ISM audits and class surveys as the standard matures.
If your ECR has persistent nuisance alarms or poorly prioritised alert stacks, treat ECRAM as the incoming regulatory framing for a problem you probably already know exists. Document your alarm management procedures in your SMS.
MSC 111 formally adopted VDES — the VHF Data Exchange System — as a permitted alternative to AIS under SOLAS regulations V/18 and V/19. Entry into force: 1 January 2028. VDES integrates four components: AIS, Application-Specific Messages (ASM), terrestrial VHF data exchange (VDE-TER), and satellite VHF data exchange (VDE-SAT). It gives highest transmission priority to AIS position reporting — safety of navigation is not compromised.
Cybersecurity is built in: VDES must comply with IEC 61162-460 and IEC 63154, with digital signature verification capability. Annual testing by an approved surveyor is required — the same standard applied to AIS today. From 2028, your Safety Certificate (Form E for cargo ships) will list "AIS or VDES." The IMO Maritime Digitalisation Strategy was also formally adopted at this session and submitted to MEPC 85 — the first time IMO has adopted a formal strategy on digitalisation.
The 2011 Enhanced Survey Programme (ESP) Code has been formally amended to allow Remote Inspection Techniques (RIT) — including drones and unmanned systems — as an alternative to traditional close-up survey for bulk carriers and oil tankers. Entry into force: 1 January 2028.
Key rules: RIT must be conducted by a certified firm under continuous direction and control of the attending surveyor. RIT cannot be used in ballast tanks where hard protective coating is in less than GOOD condition (GOOD = minor spot rusting with no general breakdown of coating — IACS UI SC223). FAIR or POOR coating means RIT is not permitted in that space. RIT firm certification is valid for 3 years. An RIT Inspection Plan must be approved before the survey. If RIT reveals damage, traditional close-up survey is still required.
RIT is a legitimate survey scope option after 2028, not a shortcut. Plan the RIT Inspection Plan as a formal document. Check tank coating condition ratings now — FAIR or POOR coating closes the RIT option for those spaces.
IMDG Code Amendment 43-26 was adopted at MSC 111. Voluntary from 1 January 2027, mandatory from 1 January 2028. Two items directly relevant for container vessels: New UN entries 3563 (lithium metal batteries in CTU) and 3564 (sodium ion batteries in CTU) are now in the Dangerous Goods List. The old "Lithium or sodium ion battery mark" has been simplified to "battery mark." Special Provision 980 introduces a pre-transport safety assessment for vehicles, with damaged or impacted vehicles now explicitly prohibited from loading — directly relevant for vessels carrying electric vehicles.
Several LSA Code amendments were adopted at MSC 111. Most have future entry-into-force dates. One does not. The requirement that a lifeboat release hook cannot support any load unless completely reset applies to lifeboats installed on or after 1 January 2026. That date has passed. If your vessel received a replacement lifeboat, fall, or hook release system delivered from January 2026 onward, this requirement applies now. Verify with your LSA contractor that delivered equipment meets LSA Code paragraphs 4.4.7.6.17/18.
On the horizon: Totally enclosed lifeboat ventilation minimum 5 m³/h per person for 24 hours — installations on/after 1 January 2029. Free-fall lifeboat release testing arrangement with safety factor of 6 — installations on/after 1 January 2031. New guard rail standard under Load Lines Protocol — minimum 1m height, 3 courses, max 380mm between courses, covering moonpool edges — keels laid on/after 1 January 2028.
Bonus: MSC 111 noted a proposal for a non-mandatory instrument addressing AI systems in safety-critical marine equipment. Not yet a formal work output — but watch MSC 112 (December 2026) for a formal proposal. AI governance is coming to the IMO agenda.
The maritime officers who transitioned to good superintendent roles share one habit. It is not technical depth — they all had that. It is documentation discipline, not as compliance, but as thinking out loud.
They wrote down why they made a decision, not just what they did. Not for the surveyors. For themselves. Because when you are ashore and the Chief Engineer calls you at 0200 with a main engine bearing alarm — a vessel you cannot board, a problem you cannot put your hands on — you need to have the thinking already sharp enough to guide someone standing in the machinery space. The habit of writing keeps your thinking sharp when your hands are not in the machinery.
The practical version: when you close a job card or sign off a PMS task this week, write one sentence about why you made the decision you made. Not what you did — why. That habit, compounded over a contract, is the difference between a good sea career and a good shore career.
| Topic | What Happened | What It Means for You |
|---|---|---|
| MASS Code | Non-mandatory, adopted MSC 111, effective 1 Jul 2026 | Know the 4 autonomy levels. Document override procedures for all automated systems. Expect SMS/ISM updates. |
| BWM Convention | MEPC 84 — operational compliance now mandatory | Start a live BWMS logbook. Sampling records against D-2 standard, consumable dates, alarm histories. |
| PFOS-free Foam | Mandatory from 1 Jan 2026, widely enforced through class and statutory survey pathways | Trace batch to manufacturer declaration, lab test, or TA certificate. Three accepted pathways. |
| ECRAM | IMO developing ECR alert performance standards post-Viking Sky (SDC, target 2028) | Address nuisance alarms now. Codify alert procedures in SMS before this becomes a survey item. |
| VDES | Adopted as AIS alternative under SOLAS V/18-19, EIF 1 Jan 2028 | Safety certificates will read "AIS or VDES." Annual surveyor testing required. IEC 61162-460 cyber compliance. |
| RIT for ESP | Drones approved for close-up hull surveys, EIF 1 Jan 2028 | Requires approved pre-survey plan. Valid only where coating is GOOD (IACS UI SC223). Plan dry-dock scope accordingly. |
| IMDG 43-26 | New UN 3563/3564 batteries in CTUs. Voluntary Jan 2027, mandatory Jan 2028 | Update DG acceptance procedures. Damaged/impacted EVs prohibited from loading. |
| LSA Hook Reset | Active NOW — hooks installed on/after 1 Jan 2026 | Verify with LSA contractor. Hook must not support load unless completely reset. LSA Code 4.4.7.6.17/18. |
| AI-PdM | RUL models at fleet-scale commercial deployment | Validate AI alerts against physical inspection and oil-lab data. Sensor calibration is not optional. |
| VLSFO Lubricant | DNV/ABS active guidance | Match cylinder oil BN to fuel sulphur content. Record in cylinder condition log. |
| NE Atlantic ECA | EIF 1 Sep 2027; SOx/PM cap 1 Sep 2028; Tier III NOx for contracts on/after 1 Jan 2027 | Check NOx Technical File. Confirm Tier III or abatement pathway (SCR/EGR) for North Atlantic trades. |
| SEEMP | Revised 2024 Guidelines — active management now required | Log all deviations and corrective actions. Paper trail for engine-load decisions and commercial speed requests. |
"AI gives you a better picture of the machine. The accountable professional still decides what to do with it."