Mainly, as it is reported, there's no mandatory requirement to have an implementation plan. On the contrary, Port State Control authorities are to possible take the status of any plan, or the lack thereof, into consideration when verifying compliance after January 1, 2020.
Consequently, the Club advises that vessels have one in place, based on what it is recommended in the Guidance.
In light of these developments, surveyors who are performing condition surveys will be instructed to determination the status of the ship’s implementation plan in preparation for the implementation date of January 1, 2020.
For more information, you may click on the PDF herebelow