Guidance

MGN 705 (M) Amendment 1 Remotely operated unmanned vessels (ROUVs) of 2.5 metres to less than 4.5 metres in length overall

Published 19 January 2026

Summary

This Marine Guidance Notice (MGN) explains a General Exemption which has been issued for Remotely Operated Unmanned Vessels of 2.5 to <4.5 metres in length overall.

This General Exemption enables eligible vessels to operate without certification issued by the Maritime and Coastguard Agency (MCA) or its delegates.

This General Exemption is effective from 31 December 2024.

1. Introduction

1.1 This Marine Guidance Notice (MGN) explains a General Exemption which has been issued, subject to set conditions for Remotely Operated Unmanned Vessels of 2.5 to <4.5 metres in length overall.

1.2 Remotely Operated Unmanned Vessel (ROUV) means a vessel with no persons on board that is operated from a location remote to the vessel.

2. Background

2.1 To date, there have been three pathways for ROUVs under 24 metres in load-line length:

i. MASS, including ROUVs, of less than 2.5 metres in length overall may comply with the General Exemption set out in MGN 702 which permits eligible vessels to operate without certification issued by the Maritime and Coastguard Agency or its delegates;

ii. ROUVs may undertake a case-by-case assessment through application of the MGN 664 process and, if successful, may be issued with Load Line Certification; or

iii. ROUVs of <24 metres in load-line length may be surveyed and issued with a Workboat Code Edition 3 certificate.

2.2 To provide specific support to operators of the smallest ROUVs the Maritime and Coastguard Agency have issued a General Exemption for ROUVs of 2.5 meters to <4.5 metres in length overall, which ensures that eligible vessels have an available proportional pathway.

2.3 Vessel owners/operators of ROUVs of 2.5 to <4.5 metres in length overall may alternatively still choose to follow either of the pathways set out in 2.1.

2.4 The MCA has also published MGN 702 which explains a General Exemption which has been issued for Maritime Autonomous Surface Ships of <2.5 metres in length overall.

2.5 Non-UK Maritime Administrations or Port State Authorities are under no obligation to accept UK General Exemptions for vessels in their waters. United Kingdom vessels may be subject to additional requirements of the port state or overseas administration when operating outside of United Kingdom waters, over and above the requirements of this General Exemption. Vessel owners/operators shall contact the administration controlling those waters for further information.

2.6 This General Exemption is effective from 31 December 2024.

3. General Exemption for ROUVs 2.5 to <4.5 Metres in Length Overall

3.1 This General Exemption only applies to ROUVs of 2.5 to <4.5 metres in length overall which comply with all of the conditions set out within this General Exemption.

3.2 This General Exemption only applies to ROUVs. Vessels subject to this General Exemption shall be under the constant supervision of a human operator, with means to take control at any time.

3.3 This General Exemption shall remain in force until the 31st December 2027.

3.4 The Maritime and Coastguard Agency, on behalf of the Secretary of State, retains the right to retract this General Exemption at any time.

3.5 This General Exemption does not apply to a vessel unless all conditions of this General Exemption have been met, including submission of the completed self-declaration form to the Maritime and Coastguard Agency’s Code Vessel Team (see 5.2).

3.6 An ROUV of 2.5 to <4.5 metres in length overall must:

i. Comply with the conditions of this General Exemption; or

ii. Be issued with a UK Load Line Certification following completion of a successful case-by-case assessment through application of the MGN 664 process; or

iii. Be issued with a Workboat Code Edition 3 certificate.

3.7 An ROUV of 2.5 to <4.5 metres in length shall not operate at speeds exceeding 6 knots, or the declared planing speed, whichever is lower. The vessel’s maximum and planing speeds shall be recorded on the self-declaration form (see Appendix 1).

3.8 An ROUV of 2.5 to <4.5 metres in length which is capable of operating at speeds exceeding 6 knots is not eligible for this General Exemption.

3.9 An ROUV of 2.5 to <4.5 metres in length which does not comply with any of the options listed in 3.6 may be subject to enforcement action by the Maritime and Coastguard Agency.

3.10 The MCA has the power to inspect any ROUV at any reasonable time to verify if it complies with the requirements of this General Exemption and applicable legislation.

3.11 The MCA may prevent an ROUV from operating if they believe that its condition or manner of operation presents a serious risk to the safety of other water users or the environment.

4. Vessel Identification

4.1 When a vessel is declared against the General Exemption for Remotely Operated Unmanned Vessels (ROUVs) of 2.5 Metres to Less than 4.5 Metres in Length Overall for the first time, it will be assigned a unique identification number, in accordance with the standard format set out below.

4.2 An example unique identification number is:

M705000

which denotes that this is a vessel declared against the General Exemption for Remotely Operated Unmanned Vessels (ROUVs) of 2.5 Metres to Less than 4.5 Metres in Length Overall.

4.3 A vessel shall continue with the unique identification number assigned to it at initial declaration for the lifetime of the vessel

4.4 The vessel shall have clearly displayed means of identification positioned on its exterior above the static waterline, and in a contrasting colour to the area of the vessel it is applied to. This shall enable other water users to:

.1         identify the vessel; and

.2         identify the vessel owner/operator; and

.3         either provide contact details for the vessel owner/operator; or

.4         provide means of identification which would enable water users to source contact details for the vessel owner/operator.

If a single means of identification is not able to meet the requirements of this provision, a vessel may instead use a combination of means of identification.

4.5 Examples of means of identification include, but are not limited to:

.1         vessel’s MCA-issued unique identification number;

.2         vessel owner/operator’s contact details;

.3         vessel name;

.4         company logo;

.5         QR code.

4.6 Evidence of the chosen means of identification must be provided to codes@mcga.gov.uk.

5. General Requirements

This section sets out requirements which must be complied with, including but not limited to those listed on the General Exemption. The requirements and information set out in Section 4 of this MGN is not an exhaustive list. There may be other statutory requirements which are applicable to a specific vessel. The owner/operator of a vessel has a responsibility to identify which statutory requirements apply to a specific vessel and its intended operations and should ensure they are familiar with, and have an understanding of, their obligations.

Radiocommunications and Visibility

5.1 The owner/operator of an ROUV of 2.5 to <4.5 metres in length overall should implement appropriate means to enhance the visibility and detectability of the vessel by other water users.

5.2 All vessels of less than 150GT are required, if practicable, to fit a radar reflector, or other means (e.g. radar target enhancer), complying with international standards to enable detection by ships navigating by radar (both 3 and 9 GHz); as required by SOLAS Chapter V Regulation 19. For passive radar reflectors the largest suitable radar reflector in terms of Radar Cross Section should be fitted according to the manufacturer’s instructions, and as high as possible to maximise its effectiveness.

5.3 All vessels that proceed to sea are required to be correctly provided with, and exhibit, navigation lights, shapes and sound signalling devices consistent with the vessel’s length, type and circumstances, as required by Parts C and D, and Annex I of COLREGs.

Where day signals or navigational lights relating to special operational modes (Not Under Command (NUC)/Restricted Ability to Manoeuvre (RAM)) are not mandatory due to the vessel size, the MCA recommend that operators consider alternative arrangements, for example smaller dimensioned day signals or the inclusion of NUC/RAM navigational lights are considered as part of the hazard identification process.

5.4 Vessels which undertake towing shall comply with Rule 24 of COLREGs.

5.5 An ROUV shall not tow another vessel or object either on the surface or in semi-submerged form. Where necessary, an ROUV may stream and operate towed survey equipment beneath the water’s surface, provided it can be launched, recovered and monitored from the ROC.

5.6 Where an ROUV is fitted with AIS, the operator shall be aware of the limitations of AIS data (e.g. not all vessels are fitted with AIS), and ensure that navigational decisions for collision avoidance are primarily based on systematic visual and/or radar observations and other suitable means; not solely on AIS information. Particular attention shall be given to 4.11.1 and 4.11.2 of MGN 324, as amended which provides details on potential consequences of over-reliance on AIS information. The use of AIS does not remove the need for a visual lookout or use of “all available means”, but may be used to supplement information.

5.7 Vessels utilising AIS require an MMSI number issued by Ofcom.

5.8 Vessels utilising AIS as an aid to visibility to other vessels should be aware of the differences between Class A and Class B AIS transceivers:

i. Class A transceivers constantly transmit and provide far greater information about vessels than Class B transceivers; and

ii. Class B transceivers transmit only when free slots become available, with Class A taking priority. This could result in the ROUV not being visible to other vessels in areas of heavy AIS traffic.

5.9 If the owner/operator of a vessel to which this General Exemption applies chooses to carry EPIRBs they shall comply with The Merchant Shipping (EPIRB Registration) Regulations 2000 (SI 2000/1850), as amended.

5.10 Vessels shall be issued with a valid Ships’ Radio Licence by Ofcom^{[footnote 1]}.

5.11 Owners should consider whether a radio licence is required for the Remote Operation Centre (ROC).

Safety of Navigation

5.12 The Merchant Shipping (Safety of Navigation) Regulations 2020 (SI 2020/673), as amended implement the International Convention for the Safety of Life at Sea 1974, as amended, (SOLAS) Chapter V (Safety of Navigation). Further information on SOLAS Chapter V can be found at https://www.gov.uk/navigation-safety-for-uk-seafarers#solas-chapter-v, and provides information on the rules for the safety of navigation that apply to vessels of differing sizes.

5.13 With respect to navigation and collision avoidance, all vessels are required to comply with The Merchant Shipping (Distress Signals & Prevention of Collisions) Regulations 1996 (SI 1996/75), as amended. These UK regulations implement the International Regulations for the Prevention of Collisions at Sea, 1972 (COLREGs).

5.14 A vessel shall at all times proceed at a safe speed to:

i. take proper and effective action to avoid collision;

ii. be stopped within a distance appropriate to the prevailing circumstances and conditions; and

iii. at a speed where potential delays to detection of a collision hazard by a Remote Operator, due to system performance or configuration (e.g. data transmission or processing), does not prevent the vessel from complying with the applicable requirements of COLREGs.

5.15 The Master shall ensure that any intended voyage, including major alterations to a voyage, are planned using the appropriate nautical charts and publications.

5.16 All ROCs shall be equipped with charts and nautical publications to plan and display the ship’s route for the intended voyage and to plot and monitor positions throughout the voyage. These charts and publications should be of an appropriate scale and detail for the ROUV’s area of operation and are to be maintained at the ROC in lieu of onboard the ROUV. An ROUV shall not carry charts and nautical publications on board.

5.17 Where an ROC operates using a “paperless” system, it shall be equipped with an Electronic Chart System (ECS) appropriate for primary means of navigation, e.g. ECDIS or an ECS meeting the MGN 319 – “Mini-ECDIS” requirements and the relevant back-up facilities of SOLAS Chapter V or MGN 319, as appropriate, shall be maintained.

5.18 All Masters and Remote Operators at an ROC shall have access to an illustrated table of recognised life-saving signals at the control position. A table of Life Saving Signals is available through searching “Life Saving Signals” on https://www.gov.uk.

5.19 It is the responsibility of the owner/operator of an ROUV to assess the ability of a Remote Operator to comply with Rule 5 of COLREGs (Lookout). This includes the ability to visually identify targets by means of a continuous camera output and to observe sound signals.

5.20 The ROC control position shall be set-up so that the Remote Operator at all times:

i. has a minimum 225° front view with a pan-tilt-zoom function, from the perspective of the ROUV; and

ii. is able to monitor a 360° total field of view with a pan-tilt-zoom function.

5.21 An operational contingency plan shall be developed and in place at the ROC to enable recovery of the vessel in the event of a sustained loss of control or connectivity between the ROC and ROUV.

Hazards to Navigation, Distress Signals and Accident Reporting

5.22 Where an ROUV encounters a danger that may pose a direct risk to navigation of an ROUV or any vessels in the vicinity, the ROC shall communicate the information to ships in the vicinity and to the Coastguard or competent authority of the area.

5.23 Where an ROC receives information from any source that persons are in distress within the operating area of an ROUV, the ROC and ROUV shall respond with reasonable and proportionate action within the limitations of the ROUV to assist the person(s) in distress.

5.24 The owner/operator of a vessel has a statutory requirement to report accidents. The statutory requirements are given in The Merchant Shipping (Accident Reporting and Investigation) Regulations 2012 (SI 2023/1743), as amended.

Protection of Personnel Working with ROUVs

5.25 It is the duty of shipowners and employers to protect the health and safety of workers and others affected by their activities so far as is reasonably practicable. The principles for ensuring health and safety of personnel are:

i. the avoidance of risks;

ii. the evaluation of unavoidable risks and the taking of action to reduce them;

iii. adoption of work patterns and procedures;

iv. adaptation of procedures to take account of new technology and other changes in working practices, equipment, the working environment;

v. adoption of a coherent approach to management of the vessel or undertaking;

vi. giving collective protective measures priority over individual protective measures; and

vii. the provision of appropriate and relevant information and instruction for workers.

Equipment

5.26 Equipment placed on board UK vessels that were approved under the terms of the Marine Equipment Directive (MED) may remain on board for the duration of its operational life. Equipment replaced after 1st January 2023 must be replaced with UK approved marine equipment in accordance with Merchant Shipping Notice (MSN) 1874, as amended.

5.27 MSN 1874, as amended sets out performance and testing standards to be met by marine equipment placed or to be placed on board a UK ship in accordance with the UK’s conformity assessment procedures.

5.28 The Merchant Shipping and Fishing Vessels (Provision and Use of Work Equipment) Regulations 2006 (SI 2006/2183), as amended require shipowners to ensure that equipment provided for work is:

i. suitable for its intended use;

ii. safe for use;

iii. maintained in a safe condition and inspected regularly;

iv. only used by people who have received adequate information, instruction and training; and

v. is accompanied by suitable health and safety measures.

Training and Certification

5.29. The Master and Remote Operator(s) responsible for undertaking navigational watchkeeping duties for the vessel should hold the following certification:

i. A valid, commercially endorsed Certificate of Competence, as set out in the Workboat Code Edition 3, Appendix 5, as amended, applicable to the vessel and area of operation; or

ii. STCW Certificate of Competence, as applicable to the intended area of operation, function and tonnage limitations; or

iii. Qualification valid for the intended area category of water as set out in MSN 1853, Annex 3, as amended.

5.30. The Master and Remote Operator(s) responsible for undertaking navigational watchkeeping duties for the vessel, should undertake the following:

i. GMDSS training and certification appropriate to the intended area category of operation;

ii. Radio Operator certification appropriate to the intended area category of operation;

iii. MCA approved Small Ships Navigation and Radar: Radar and Meteorology Course, for Remote Operators undertaking navigational watchkeeping duties for vessels carrying a radar;

iv. MCA approved Small Ships Navigation and Radar: Electronic Chart Systems and Bridge Watchkeeping Course, for Remote Operators undertaking navigational watchkeeping duties;

v. Training in remote operations;

vi. Remote Operation Centre (ROC) and vessel-specific training and familiarisation;

vii. Company-specific training and familiarisation;

viii. Training in maritime cyber security;

ix. Training as required by The Management of Health and Safety at Work Regulations 1999 (SI 1999/3242), as amended; and

x. Training as required by The Health and Safety (Display Screen Equipment) Regulations 1992 (SI 1992/2792), as amended.

5.31 The Master and Remote Operator(s) responsible for undertaking navigational watchkeeping duties are recommended to undertake:

i. Training for navigational and operational equipment, in excess of the requirements set out in this MGN, i.e. launch and recovery systems, ship stability training, Dynamic Positioning etc., where fitted; and

ii. Refresher training in remote operations as required to maintain a level of competence that is applicable and current to the ROUV’s operation.

Manning

5.32 The owner/operator shall ensure that an adequate number of competent and experienced personnel are provided to perform the duties that are identified as necessary to safely navigate and operate the ROUV and respond to emergencies.

5.33 The Master of the vessel must assume the role and responsibility as the Master of the vessel for the duration of a working shift or navigational watch.

5.34 The Master that holds the authority and responsibility for the vessel must be readily available to take control of the vessel at the control position at all times.

5.35 The Master of the vessel must formally handover command to the relieving Master at the end of their working shift or watch.

5.36 The control position from where the vessel is conned must be manned at all times.

5.37 The owner/operator should allocate a sufficient number of Remote Operators to the ROUV to perform watchkeeping duties for the duration of the voyage.

5.38 The Master of the vessel must ensure that all Remote Operators are sufficiently rested and fit for duty, prior to undertaking watchkeeping duties.

5.39 The Master should continually assess the minimum levels of manning and take action as required to ensure the safe operation of the vessel; protection of the marine environment; preservation of life at sea; and the ability to respond to emergency situations.

5.40 In exceptional circumstances when the established minimum level of safe manning to safely operate the ROUV cannot be met, procedures and contingencies should be in place to ensure that the vessel enters into a safe state until the minimum level of safe manning can be re-established.

5.41 The owner/operator must provide Remote Operators with work schedules that include shift patterns and hours of work and rest.

5.42 Work shifts should be structured to ensure that sufficient periods of rest are provided to avoid fatigue, including screen fatigue. These should ensure that precautionary measures including rest breaks that include periods of fresh air and natural light are factored in throughout a watch.

5.43 The Merchant Shipping (Maritime Labour Convention) (Medical Certification) Regulations 2010 (SI 2010/737), as amended and MSN 1886 , as amended states the mandatory medical standards for seafarers. Remote Operators will require an ENG 1 or ML5 seafarer medical certificate, as appropriate.

Prevention of Pollution

5.44 All vessels installed with marine diesel engines constructed after 1st January 2000 with a power output greater than 130 kW shall be issued with an Engine International Air Pollution Prevention (EIAPP) Certificate and a Technical File, a copy of which shall be presented to the Administration.

5.45 All vessels with diesel and hybrid propulsion systems installed on or after 1st January 2021 operating in the Baltic and North Sea NOx emission control areas shall comply with The Merchant Shipping (Prevention of Air Pollution from Ships) Regulations 2008 (SI 2008/2924), as amended.

5.46 An ROUV of 2.5 to <4.5 metres in length overall which is designed or constructed to carry ballast water shall comply with The Merchant Shipping (Control and Management of Ships’ Ballast Water and Sediments) Regulations 2022 (SI 2022/737) as amended.

5.47 The IMO Convention for the Prevention of Pollution from Ships 1973, as modified by the Protocol of 1978 relating thereto covers the control of several types of ship-generated pollution. Generally prevention of pollution legislation applies to all vessels and includes controls on the discharge of waste into the sea from ships. The best practice advice to follow is to return all waste (except air pollution) generated on board to shore waste reception facilities.

5.48 The Merchant Shipping (Prevention of Pollution) Regulations 2019 (SI 2019/42) as amended, require that oil should be retained on-board for disposal to shore reception facilities.

5.49 Organotin compounds are prohibited on ships. The Merchant Shipping (Anti-Fouling Systems) Regulations 2024 (SI 2024/509), as amended, provide the legal framework required in the UK for the offences and penalties in relation to EC Regulation EC 782/2003 on the prohibition of organotin compounds. The UK Regulations also implement the IMO’s International Convention on the Control of Harmful Anti-Fouling Systems on Ships.

 6. Self-Declaration Form

6.1 A condition of this General Exemption is for the vessel owner/operator to complete, sign and date a self-declaration form. The self-declaration form includes a requirement for the vessel owner/operator to undertake a hazard identification and for all identified hazards to be reduced to as low as reasonably practicable (ALARP).

6.2 The completed self-declaration form shall be sent to the Maritime and Coastguard Agency for their records. The self-declaration shall be sent in an email to codes@mcga.gov.uk.

7. Safety Assurance

7.1 An assessment shall be undertaken for a vessel in accordance with the requirements of this Section to:

i. Ensure safe operation of the vessel;

ii. Reduce all identified hazards to ALARP; and

iii. Complete a hazard identification document. A template is included in Appendix 1.

7.2 . The safety of the System^{[footnote 2]}, including all:

i. Intended configurations;

ii. Manning;

iii. Modes of operation;

iv. Operational activities;

v. Areas of operation; and

vi. Operating environments;

shall be subject to a rational and systematic assessment, by suitably qualified and experienced personnel, and using methodologies appropriate to the level of risk, complexity and innovation^{[footnote 3]}.

7.3 Safety and operational risks shall be eliminated or reduced to ALARP using appropriate preventive and mitigating risk reduction measures.

7.4 This evidence of safety assurance shall be maintained by the owner/operator throughout the operational lifecycle of the ROUV. Any changes to the System, its environment and/or operation shall be evaluated, to support the identification of new hazards and ensure effective preventative controls and mitigations remain in place, where required.

7.5 The rational and systematic assessment carried out in line with the requirements stipulated within paragraph 6.1 of this Marine Guidance Notice shall include an output which identifies all the hazards, who is at risk from each hazard, the identified barriers/mitigation and an overview of the verification evidence, which is to be maintained throughout the lifecycle of the vessel and be available for review by the Maritime and Coastguard Agency on request.

7.6 An example of the output described in paragraph 6.2 can be found in Appendix 1 of this document. When reviewing the table in Appendix 1 the following elements should be taken into consideration:

i. The example hazard descriptions are non-exhaustive, and the identification of all relevant hazards shall be carried out by a rational and systematic assessment as described in paragraph 6.1;

ii. The barriers and mitigation measures identified within the output shall ensure that operational risks are eliminated or reduced to ALARP;

iii. Verification evidence shall ensure that there is a reasonable and auditable trail that ensures the effectiveness of the barriers and mitigation measures identified. This verification evidence should be maintained effectively to allow for both internal review and 3rd party review; and

iv. A more detailed or more specific hazard review template may be adopted in lieu of the example as long as it clearly covers the principles identified within the example.

8. Self-Declaration Form Invalidation

8.1   Owners/operators shall notify the Maritime and Coastguard Agency of any changes which invalidate existing declarations required by this exemption. These include:

i. Changes to vessel ownership, such as when the vessel is sold;

ii. Changes to vessel remote operating company;

iii. Changes to the physical characteristics or capabilities of the ROUV such as, but not limited to, an increase in vessel length or the introduction of more capable software which enables the vessel to navigate autonomously;

iv. Major modification(s) to the vessel or ROC which would affect compliance with the applicable requirements of Section 4 of this MGN or any of the conditions set out in the General Exemption;

v. If the vessel is lost or decommissioned.

 9. Further Information

9.1 Further information relating to Workboat Code Edition 3 can be obtained from the contact details listed below:

i. Workboat Code Edition 3 can be accessed at: https://www.gov.uk/government/publications/the-workboat-code-edition-3.

ii. The Merchant Shipping (Small Workboats and Pilot Boats) Regulations 2023 can be accessed at: https://www.legislation.gov.uk/uksi/2023/1216/contents/made.

9.2 Further information relating to MGN 664 can be obtained from the contact details listed below:

i. MGN 664 (Amendment 1) Certification Process for Vessels using Innovative Technology https://www.gov.uk/government/publications/mgn-664-mf-amendment-1-certification-process-for-vessels-using-innovative-technology

More Information

Code Vessel Team, UK Technical Services Ship Standards
Maritime and Coastguard Agency
Bay 2/23
Spring Place
105 Commercial Road
Southampton
SO15 1EG

Telephone: +44 (0)203 817 2000

Email: codes@mcga.gov.uk

Website: www.gov.uk/mca

1. https://www.ofcom.org.uk/spectrum/radio-equipment/maritime-information/ ↩

2. Including but not limited to the ROUV, ROC, command and control and GMDSS communications systems and networks ↩

3. e.g. IEC 31010:2019 Risk management – Risk assessment techniques ↩