1. INTRODUCTION

The 12th session of the IMO Sub-Committee on Implementation of IMO Instruments (III 12) was held from 20 to 24 July 2026.

The Sub-Committee progressed several matters concerning the consistent implementation and enforcement of IMO instruments, including the implementation of the International Safety Management (ISM) Code, statutory survey and certification requirements, Port State Control activities and marine casualty investigations.

2. REVISION OF THE ISM CODE IMPLEMENTATION GUIDELINES

III 12 initiated a comprehensive revision of the IMO guidelines concerning the implementation of the ISM Code by Administrations and companies. The review is intended to improve the clarity, consistency and effectiveness of ISM Code implementation, taking into consideration experience gained by flag Administrations, Recognized Organizations, companies and other stakeholders.

The work is expected to address both:

• the guidelines for Administrations concerning the implementation of the ISM Code; and
• the guidance provided to companies for the development, implementation and maintenance of effective Safety Management Systems.

The revision remains under development. Consequently, no immediate amendments to existing Safety Management Systems or ISM certification arrangements arise solely from the outcome of III 12.

3. SURVEY GUIDELINES UNDER THE HARMONIZED SYSTEM OF SURVEY AND CERTIFICATION

The Sub-Committee continued its work on updating the Survey Guidelines under the Harmonized System of Survey and Certification (HSSC). The revisions are intended to ensure that the Survey Guidelines remain aligned with amendments to the relevant IMO conventions and mandatory instruments and provide clear and consistent requirements for statutory surveys and certification. The work also includes consideration of how survey items and requirements may be more systematically identified and categorized, including matters associated with the performance and eligibility of remote surveys.

The revised Survey Guidelines will be finalized through the relevant IMO approval and adoption process before becoming applicable.

4. PORT STATE CONTROL

III 12 advanced its work on the harmonization of Port State Control activities and the continued review of the IMO Procedures for Port State Control.

The work aims to support greater consistency among regional PSC regimes and individual port States in areas such as:

• inspection practices;
• identification and assessment of deficiencies;
• application of detention criteria;
• reporting and exchange of inspection information; and
• treatment of matters requiring further investigation by the flag Administration.

Shipowners and managers should continue to ensure that vessels are maintained in full compliance with the applicable statutory requirements and that deficiencies identified through inspections, audits, surveys or internal monitoring are addressed promptly and effectively.

5. MARINE CASUALTY INVESTIGATIONS

The Sub-Committee reviewed casualty investigation reports and lessons learned from marine casualties and incidents.

The outcome of casualty analyses may contribute to the development of future IMO requirements, recommendations and guidance. Relevant lessons learned should also be considered by companies when reviewing:

• risk assessments;
• operational procedures;
• emergency preparedness arrangements;
• familiarization and training;
• internal audit findings; and
• the effectiveness of corrective and preventive actions.

6. REQUIRED ACTION

At this stage, the matters described in this Circular principally concern ongoing work within the IMO and do not introduce immediate mandatory requirements.

PHRS Regulatory Affairs Dept. will continue to monitor the progress of these matters and will provide further information once the relevant amendments, guidelines or implementation dates have been finalized.

For any questions or further assistance, please do not hesitate to contact our Regulatory Department at regulatory@phrs.co.com.