IMO III 11: Remote Surveys, ISM Audits and ISPS Verifications – Guidance Finalized
The IMO Sub-Committee on Implementation of IMO Instruments (III) held its 11th session from 21 to 25 July 2025, finalizing key regulatory updates that will shape how remote methods can be used in surveys, ISM audits, and ISPS verifications going forward.
These updates directly impact:
- Shipowners and technical managers
- Flag administrations and Recognized Organizations (ROs)
- Port State Control (PSC) authorities
- Compliance and HSEQ professionals
Key Outcomes of IMO III 11
1. Remote Surveys and Audits – Clear Limits and Requirements
- Remote surveys may be allowed for specific items, based on risk assessment and subject to flag state approval.
- Remote methods cannot be used for the same item for two consecutive years.
- Remote surveys are not permitted for SOLAS safety certificates or the International Load Lines Certificate on passenger ships.
2. ISM Code Audits – Physical Attendance Still Required
- Initial, renewal, and interim company audits must be done in person.
- Annual audits and interim audits for new ship types may use remote methods, but only with prior flag state approval.
- The audit plan must be submitted well in advance.
3. ISPS Verifications – Remote Use Extremely Limited
- ISPS verifications may be conducted remotely only in exceptional cases, and only for selected items.
Lessons Learned from Marine Casualties
IMO III 11 reviewed 39 casualty reports and identified 36 key lessons, now published via circular. Root causes included:
- Poor management oversight (22 cases)
- Inadequate risk assessment (19 cases)
- Weak safety culture (20 cases)
- Insufficient training (12 cases)
Topics flagged for further work:
- Parametric rolling risks → forwarded to technical sub-committees
- Fire safety on self-unloading bulk carriers → new proposal under development
- Inflatable lifejacket reliability → subject of ongoing research
- Enclosed space & lifeboat accidents → work in progress
Port State Control (PSC) – Harmonization and Updates
The PSC Procedures have been amended, with new consolidated guidelines set to be adopted at IMO Assembly 34 in December 2025 and come into effect on 1 January 2026.
🔹 Key updates include:
- New Appendix 20: Guidance for PSCOs on handling security-related inspections
- Revised Model Course 3.09 on Port State Control
- Clarifications on roles of PSCOs vs Duly Authorized Officers
- Emphasis on pragmatic inspection of escape routes from machinery spaces
- Reminder that flag states, not PSC, determine minimum safe manning
IMO III 11 also called for:
- Greater consistency across PSC regimes
- Objective criteria for ISM Code deficiencies
- Ongoing training and internal reviews within regional PSCs
HSSC Survey Guidelines and Fraudulent Practices
Updates to the Harmonized System of Survey and Certification (HSSC) now include:
- New provisions for the Industrial Personnel (IP) Code
- Removal of the AFS certificate, as the AFS Convention is outside the harmonized system
- A re-established Correspondence Group to address fraudulent ship registrations and consider updates to circulars MSC/Circ.1140 and MEPC/Circ.424 on flag transfers
Unified Interpretations (UIs) Updated
The Sub-Committee revised circular MSC-MEPC.5/Circ.3 to clarify that the “based on” date on certificates refers to the initial or renewal survey date – not follow-up or intermediate assessments.
Conclusion
The final guidance from IMO III 11 represents a milestone in formalizing remote inspection practices, while maintaining a firm emphasis on physical attendance where safety-critical elements are involved.
Marine Surveyor Consultant Sagl is ready to support:
- Pre-audit assessments
- ISM & ISPS compliance reviews
- Flag state inspection preparation
- Remote audit planning and approval support
