Guidance

MIN 733 - Conflict in the Middle-East – MCA approach to survey and certification of UK vessels

Published 19 March 2026

Summary

This MIN sets out the policy of the MCA with respect to UK Vessels which were prevented from arranging the Surveys, audits and verifications required for compliance with the relevant Statutory Instruments due to the ongoing Conflict in the Middle-East.

It establishes specific provisions for the safe operation of affected vessels, clarifies the limits on certification extensions, and sets a strict hierarchy for the use of extensions, remote surveys, and alternative measures.

1. Introduction/background

1.1 The MCA has put in place contingency plans to mitigate disruption to essential statutory activities onboard vessels directly affected by the developments in the Middle East.

1.2 The UK acknowledges that due to exceptional circumstances, UK registered vessels may be unable to complete surveys, audits, verifications and servicing activities required under the national and international regulations due to:

    (i) lack of availability of surveyors;

    (ii) a restriction on surveyors travel to reach the port of survey and /or

    (iii) the vessel’s inability to safely proceed to, or remain in, a port of survey.

1.3 For the purposes of this MIN, an ‘affected vessel’ is a UK-flagged vessel located within an area affected by the conflict in the Middle-East, which is unable to arrange a safe port for surveys, audits or verifications owing to force majeure, including restrictions preventing safe egress. Vessels entering the area after the commencement of hostilities will not normally be considered affected vessels and are to arrange surveys before entering any conflict zones where restrictions that affect the ability to conduct physical surveys are in place or reasonably expected.

1.4 Notwithstanding the principles set out in this MIN, Masters and owners are reminded of their responsibilities under Regulation 10 of Statutory Instrument 2015 No. 508, The Merchant Shipping (Survey and Certification) Regulations 2015, to ensure that the ship and its equipment is maintained so as to ensure that the ship in all respects remains fit to proceed to sea without danger to the ship or persons on board.

1.5 The overarching principle for the survey, audit, verification or servicing is that UK registered ships remain subject to the mandatory statutory and classification regime of surveys and certification under the relevant Conventions and the Survey Guidelines under the Harmonized System of Survey and Certification (HSSC), 2025, Resolution A.1207(34) as adopted 3 December 2025.

1.6 It is the responsibility of the operator to investigate all relevant avenues to arrange for the necessary activity to be undertaken to the required standard, and within the relevant timeframe, in full compliance with the requirements.

1.7 The MCA acknowledges that in exceptional circumstances, compliance with the established statutory requirements contained within IMO Conventions and Classification Society rules may not be possible however it is the expectation that all avenues are explored from the earliest opportunity to arrange for the activities required by the regulations to be completed in line with the requirements.

2. Arrangement of statutory surveys of international trading ships

2.1 International conventions include provisions that permit the extension of a statutory certificate for a period of up to three months where a vessel is not in a port at which the required survey can be completed at the time of certificate expiry. In such circumstances, the MCA authorises Recognised Organisations to apply these provisions to maintain certification solely to enable the vessel to proceed to a port where the necessary surveys can be undertaken. For SOLAS certification, this may be applied in accordance with SOLAS chapter I, regulation 14(d) or 14(e).

2.2 The Survey Guidelines under the Harmonized System of Survey and Certification (HSSC), 2025, Resolution A.1207(34) as adopted 3rd December 2025 details the allowances and limitations of remote surveys due to exceptional circumstances.

2.3 Escalation of Survey, Verification and Service Options in Exceptional Circumstances

2.3.1 In accordance with the Harmonized System of Survey and Certification (HSSC), 2025, and MCA policy, the following order of escalation shall apply for UK‑flagged vessels affected by the conflict:

    .1 Physical survey remains the mandatory default and must be arranged wherever practicable.

    .2 Where a vessel is unable to reach a port of survey, a statutory 3‑month extension may be applied by the RO in accordance with SOLAS I/14(d) or 14(e) solely to allow the vessel to proceed to a suitable port.

    .3 Where physical attendance and extension options are exhausted, and where the criteria of Resolution A.1207(34) and this MIN are met, a remote survey may be considered.

Remote surveys shall be used only where extraordinary circumstances beyond the control of the parties prevent physical attendance despite all reasonable efforts.

    .4 Where neither physical survey, extension, nor remote survey is possible, the MCA may consider alternative measures under Section 10 of this MIN.
Alternative measures may only be applied following case‑by‑case evaluation and shall not alter the statutory requirements or reduce the intended level of safety.

2.4 Resolution A.1207(34) provides that, under extraordinary circumstances beyond the control of the parties (such as natural disasters, warfare, pandemic/epidemic outbreak, strike, riot, crime or sudden legal changes) which prevent on-site surveys despite all reasonable steps having been taken, consideration may be given to the use of remote surveys as alternative evidence on the condition of the ship in lieu of the physical survey, provided that a case-by-case assessment is carried out and approved by the flag Administration, including the verification and validation of remote survey results during subsequent physical inspection, for the purposes of:

    .1 a postponement, when permitted by conventions and codes;

    .2 periodical, annual and intermediate surveys; and

    .3 verification of rectification of deficiencies covered under section 4.8.5 of the Survey Guidelines identified in previous surveys.

2.5 Remote surveys conducted under this MIN shall provide a level of safety assurance equivalent to a physical survey, and the results shall be verified and validated at the next physical attendance, in accordance with Resolution A.1207(34).

2.6 Statutory Surveys not covered within HSSC are detailed in other sections of this MIN. If they are not stated, they are not available for remote Survey, audit or verification.

2.7 Affected vessels which are unable to complete surveys within the permitted 3-month extension under the normal statutory provisions will be considered under alternative measures (Section 10 of this MIN).

2.8 The Information for remote survey in this notice is for use under exceptional circumstance only in relation to the developments in the Middle East and are not to be used under normal circumstances.

3. Safety Management

3.1 Section 12.1 of the ISM Code requires that the Company carry out internal safety audits on board and ashore at intervals not exceeding twelve months. In exceptional circumstances, this interval may be exceeded by not more than three months.

3.2 The MCA accepts that vessels affected by the Middle East developments, may meet the definition of exceptional circumstances for affected vessels and will accept deferral of the next scheduled internal audits required by section 12.1 of the ISM Code by up to no more than 3 months where suitable evidence is provided.

3.3 Companies based within the affected area where auditors are unable to travel for Document of Compliance (DOC) audits, will be considered on a case-by-case basis through alternative measures (Section 10).  

 4. Ship Security (ISPS)

4.1 Due to the sensitive nature of the information addressed in ISPS verifications, in accordance with IMO guidance, remote verification in lieu of in-person attendance is limited strictly to extraordinary circumstances, and only for interim, intermediate and additional shipboard verifications.

4.2 Any requests for extension using remote verification will be considered under alternative measures and authorised only by MCA. Remote verification will not result in any endorsements to Certificates for Interim, Initial, Intermediate or Renewal Verification, and is purely for extension purposes.

5. Maritime Labour Convention (MLC)

5.1 Any requests for extensions for MLC, using remote verification will be considered under alternative measures by MCA.

5.2 Remote audits will not result in any endorsements to Certificates for Interim, Initial, Intermediate or Renewal Verification, and is purely for extension purposes.

 6. Operators of Vessels certificated under the MCA SCV Codes of Practice

6.1 Within this section the term survey should be taken to mean annual, mid-term or renewal examinations and the term certificate should be taken to include any annual endorsement of the five-year certificate.

6.2 Operators of vessels scheduled for survey during the period of the conflict should in the first instance contact their certifying authority to make arrangements for the required survey within the required timescales. Where circumstances dictate that it is not possible to complete a specific element of survey due restrictions in place due to the conflict it should not prevent the conduct of the remaining parts.

6.3 In circumstances, where no certifying authority surveyor is available to attend an affected vessel as a consequence of the Conflict, the MCA authorises the Certifying Authority (CA) to issue a short-term certificate on the basis of a declaration from the operator that the vessel remains in compliance with the requirements of the relevant instrument. The short-term certificate should be valid for not more than three months from the date of expiration of the previous certificate or the closure of the appropriate survey window.

6.4 On expiration of the short-term certificate, or earlier if the circumstances permit, the required survey should be undertaken, and a new certificate issued with an expiration date aligned with that of the original certificate. Extensions to the validity of the short-term certificate may be considered on an individual basis on application to the Certifying Authority.

6.5 If, due to the lack of availability of a CA Surveyor, the 3 year intermediate examination is not able to be completed within the certification timeframe, including any extension provided in this MIN, the Code certificate may be suspended pending completion of the intermediate examination. The CA may decide on the extent of the examination required based on the type, age and history of the vessel and may give credit for any recent and detailed competent examination of a vessel for which a report is available. A suspension under this section should not exceed three months in length.

6.6 Operators should ensure that annual inspections for self-certification are completed as required.

6.7 During the period of this short-term certificate the requirement for an annual disc is waived.

6.8 No short-term certificate may be issued to a vessel requiring an initial survey which has not been previously certified.

6.9 Affected vessel which are unable to complete surveys within the permitted 3 month extension will be considered under alternative measures (Section 10 of this MIN).

7. Vessels Laying Up

7.1 An operator considering laying their affected vessel up during conflict should contact the MCA for guidance on the requirements regarding survey, audit, verification and service inspections during this period.

7.2 Operators should co-ordinate with their Customer Service Manager or designated MCA contact as appropriate regarding the requirements and co-ordination with the local authorities.

8. Routine servicing of Life Saving and Fire Fighting Apparatus

8.1 SOLAS III Regulation 20.8.1.1 permits an administration to extend the period of servicing of inflatable liferafts, inflatable lifejackets and Marine Evacuation Systems (MES) to 17 months where servicing at the required interval is impracticable. The MCA recognised that servicing facilities available to vessels operating in an area of conflict are restricted and therefore, subject to an onboard inspection by the Master, the MCA was content to extend the servicing of inflatable liferafts, inflatable lifejackets and MES to 17 months.

8.2 SOLAS III Regulation 20.8.2 requires the rotational deployment of MES in conjunction with the servicing required by regulation 20.8.1. The MCA is content for the period of a scheduled rotational deployment to be extended in line with the servicing schedule set out in section 3.1, above.

8.3 Routine on-board inspections of Life Saving Apparatus should continue as normal on equipment subject to the above extensions.

8.4 The routine on-board inspection and maintenance of Fire-Fighting Apparatus should continue in line with MSC.1/Circ.1432. Where servicing of equipment by an external service provider was required but the provider was unable to attend the vessel for matters associated with the conflict the MCA were content for such servicing to be postponed by up to three months provided that on-board inspections did not identify any defects. A record of any postponement should be retained on board. The MCA is content to recognise the deferrals put in place under this policy until the three month period ends.

8.5 Where equipment on board a vessel was required to be serviced or calibrated through an external service provider every effort should have been made to ensure such activity was completed within the required period. The MCA accepted that the restrictions being placed on industry as the result of the conflict may have resulted in operators being unable to secure the services of external providers and put in place an extension to the service period limited to three months. The MCA is content to recognise the deferrals put in place under this policy until the three month period ends but from 01 July 2026 onwards any required servicing should be completed as scheduled unless agreed on a case-by-case basis with the relevant MCA Marine Office.

 9. Dry-docking and In-Water Surveys

9.1 The MCA recognised that the conflict may impact the ability of operators to complete the dry-docking, or in-water surveys, required under the relevant IMO Conventions, on affected vessels.

9.2 Vessels affected are to provide dock confirmation of original booking, RO confirmation and deferral requirement under force majeure circumstances and will be considered under alternative measures (Section 10).

 10. Alternative Measures

10.1 Remote Survey Assessment Requirements>

10.1.1 Until IMO develops formal guidance on remote surveys, each case‑by‑case assessment shall, as a minimum, address:

    .1 Type and age of vessel, safety and compliance records, and Company performance including PSC history.

    .2 Documented justification for using remote methods where physical attendance is not possible.

    .3 Scope of the remote survey, identifying items that can be verified remotely and those requiring on‑site verification.

    .4 RO procedures for conducting, reporting, validating, and confirming remote surveys.

    .5 Requirements and availability of ICT, including secure two‑way audio/video and protection of confidential data.

    .6 Roles and responsibilities of all personnel gathering and providing evidence, ensuring impartiality and respecting existing liability frameworks.

    .7 Training and any additional qualifications required for surveyors and on‑board personnel involved in evidence gathering.

    .8 Provision of sufficient evidence (audio/video, photographs, statements, logbooks, service reports).

    .9 Transparent reporting indicating which elements were conducted remotely or physically.

10.1.2 Any item(s) undertaken by remote methods require verification and validation during the next follow‑up physical attendance.

10.2  Considerations for RO/CA Recommendations

10.2.1 The RO/CA and Company must consider the following when applying for or supporting applications:

    .1 How statutory and Class rule intent can be met without altering the requirements.

    .2 Recognition that IMO Conventions and Class rules are based on internationally scrutinised risk‑mitigation principles.

    .3 Assessment of the owner’s proposed controls during exceptional circumstances.

   .4 Determination of whether the proposal provides an equivalent level of temporary assurance to the Convention’s intent.

    .5 Responsibility for Class rule equivalency remains with the Classification Society.

   .6 Evidence must clearly show alignment with statutory and Class intent and demonstrate controlled maintenance of compliance during the deferral period.

10.2.2 Applications submitted directly to the MCA by operators will not be considered.

10.2.3 Applications must include:

    .1 confirmation of the vessel’s location for the previous six months; and

    .2 a proposal for when missed surveys or audits will be completed.

10.3  Assessment Criteria

10.3.1 The assessment of eligibility for alternative measures shall be undertaken by MCA, however RO’s supporting any application must also consider the following:

    .1 Review of Class records

    .2 Review of PSC performance (as applicable)

    .3 Review of Company performance

    .4 Review of ISM performance (Company/Vessel)

    .5 Proposals for mitigation measures or operational restrictions

    .6 Incident, accident or casualty reports

    .7 Any other relevant information relating to vessel condition or operation

10.4  MCA Review

10.4.1 The MCA will review the request, considering internal profiling of the vessel and Company, and may approve the use of alternative measures.

10.5 Recommendation for Short‑Term Certification

10.5.1 If no concerns are identified, the RO/CA may recommend MCA approval for the issue of a short‑term certificate (up to three months), supported by alternative measures that maintain compliance during the deferral period.

10.6 Notification of Decision

10.6.1 The MCA will notify the RO/CA of its decision without delay and include any relevant MCA‑held documentation for the Survey, audit or verification.

10.7 Submission Method

10.7.1 All applications must be submitted electronically to: alternative.measures@mcga.gov.uk

10.8  When Alternative Measures Are Not Appropriate

10.8.1 Where concerns cannot be sufficiently mitigated, ROs/CAs should not recommend alternative measures.

10.8.2 In such cases, Class may be suspended and statutory certificates may become invalid until surveys are completed.

10.9  Notification of Rejected Applications

10.9.1 Where an RO/CA declines an operator’s request, the MCA must be informed promptly with details of the vessel and affected surveys. MCA endorsement of the rejection is not required.

10.10 Consideration of Proposals for Alternative Measures

10.10.1 Where operators cannot meet prescriptive requirements but propose measures intended to meet the underlying intent, the MCA will assess whether these provide satisfactory temporary assurance.

10.10.2 For deviations from Classification Society rules, the MCA will note but not approve RO recommendations.

11. Certification and Documentation

11.1 Instruments of Appointment

11.1.1 Surveys, audits or Verifications agreed by MCA through  alternative.measures@mcga.gov.uk, will not require an instrument of appointment. Any agreements not from this address, will be subject to the normal process for Authorisation to RO’s/CA’s.

11.2 Certification

11.2.1 Any Certificates issued by MCA, remain being issued by MCA. Where a short-term is agreed, upon the receiving of a survey report and/or audit report, a short-term Certificate will be issued by MCA.

11.3 Reports

11.3.1 Survey or audit reports for any element conducted under this MIN, is to be provided to MCA. Items undertaken remotely are to be clearly indicated.

More information

UK Technical Operations
Maritime and Coastguard Agency
Bay 2/22
Spring Place
105 Commercial Road
Southampton
SO15 1EG

Telephone: +44 (0)203 81 72 190

Email: alternative.measaures@mcga.gov.uk

Website: www.gov.uk/mca