Lloyd’s Register has published its “Future IMO and ILO Legislation – Spring 2025” report, highlighting upcoming updates to mandatory statutory regulations and instruments with effective dates on or after 1 May 2025.
A comprehensive suite of new International Maritime Organization (IMO) and International Labour Organization (ILO) regulations come into force over the next few months, reshaping environmental standards, safety protocols, and seafarer welfare.
Several major regulations are set to enter force soon, including the Hong Kong Convention on Ship Recycling (26 June 2025) and updates to MARPOL Annex VI on data collection requirements under IMO DCS (1 August 2025). A significant portion of the upcoming and likely changes are aimed at reducing the environmental impact of shipping and in doing so, maintaining the industry’s high safety standards.
Summary of major developments:
New approvals or adoptions:
Adopted
- Amendment to the IGC Code – paragraph 16.9 – Alternative fuels and technologies – on the possibility to use toxic cargo as fuel if accepted by the Administration
- Amendments to the NOx Technical Code with regard to certification of an engine subject to substantial modification or being certified to a Tier to which the engine was not certified at the time of its installation
- Amendments to MARPOL Annex VI and the NOx Technical Code on the use of multiple engine operational profiles for a marine diesel engine
- Amendments to the IGF Code – 2028
Approved
- Draft IMO Net Zero Framework
- Draft amendments to SOLAS regulation V/23, draft MSC resolution on Performance standards and consequential draft amendments to the 1994 and 2000 HSC Codes and the 2008 SPS Code, to improve the safety of pilot transfer arrangements
- Draft amendments to SOLAS II-1 in relation to the application of the IGF Code to confirm gaseous fuels are within its scope
- Draft amendments to paragraph 8.3.5 and annex 1 of the 1994 and 2000 HSC Code
- Draft amendments to the IGC Code – 2028 version
- Draft Amendments to MARPOL Annex VI concerning an Emissions Control Areas for both NOx and SOx in the North-East Atlantic
- Draft amendments to MARPOL Annex VI regulation 27 on DCS data access
- Draft amendment to MLC, 2006 Standard A2.5.1 on repatriation (ILO16)
- Draft amendments to MLC, 2006 Standard A2.4 on shore leave (ILO17)
- Draft amendment to the MLC, 2006 on the investigation of marine casualties (ILO20)
- Draft amendment to the MLC, 2006 on onboard complaints procedures (ILO21)
- Draft amendments to the MLC, 2006 on the prevention of shipboard violence and harassment, including sexual harassment, bullying, and sexual assault (ILO23)
Significant new items being considered or milestones in ongoing developments:
- Review of the Ballast Water Management Convention
- Review of the Short-Term Reduction Measure (CII and EEXI)
- Development of a safety regulatory framework to support the reduction of GHG emissions from ships using new technologies and alternative fuels
- The review of the STCW Convention
- Development of a goal-based instrument for Maritime Autonomous Surface Ships (MASS)
- Evaluation of adequacy of fire protection, detection and extinction arrangements in vehicle, special category and ro-ro spaces in order to reduce the fire risk of ships carrying new energy vehicles
The major recent development is the agreement of the IMO’s Net-Zero Framework, expected to be adopted in October 2025 and entering force from March 2027. Ships are expected to start complying from 1 January 2028. This framework mandates ships reduce their greenhouse gas (GHG) emissions intensity, targeting a 30% base reduction by 2035 with a secondary higher direct compliance target of 43% and a 65% base reduction by 2040, compared to 2008 levels, ultimately aiming for net-zero emissions by around 2050.
The number and complexity of the regulatory updates that are taking place is challenging to understand. The recent agreement to a Net Zero Framework to reduce the GHG intensity of shipping, and the consequential measures to enable that to happen safely, are historically among the biggest regulatory disrupters to shipping’s business model.
…said Mark Towl, Principal Regulatory Risk Specialist, Lloyd’s Register.
Environmental regulations
A number of guidelines will be required to be drafted and the 2024 Guidelines on life cycle GHG intensity of marine fuels, effective from 2025, requiring further development to include fuel pathways and default emissions factors for use in calculating a ship’s greenhouse gas fuel intensity (GFI) and total emissions.
Environmental regulations also extend to specific geographic areas. The Mediterranean Sea became a Sulphur Oxides (SOx) Emission Control Area (ECA) from 1 May 2025, with a strict limit on the sulphur content in fuel of 0.10%, requiring ships trading in the Mediterranean Sea to either use compliant fuels or abatement technology as an equivalent means of compliance.
Similarly, the Canadian Arctic will see phased-in NOx and SOx controls, with NOx Tier III standards for newbuilds contracted from 2026 that are to be operated in the NOx ECA and a limit on the sulphur content of the fuel of 0.10% for all ships operating in the SOx ECA from March 2027.
Furthermore, the Hong Kong Convention on Ship Recycling takes effect from 26 June 2025. New ships and ships bound for recycling facilities must carry an approved Inventory of Hazardous Materials and be dismantled only at approved recycling facilities following a final survey and with a ship recycling plan in place. Existing vessels over 500GT on international voyages must have an approved Inventory of Hazardous Materials onboard by mid-2030.
Safety regulations
Numerous safety-related regulations are also being updated. From 1 January 2026, amendments to the LSA Code will limit the maximum lowering speed of a fully loaded survival craft and has a minimum lowering speed for high sided ships (>30m).
Also entering force in January 2026 are amendments to SOLAS Chapter II-2/7.5.5 concerning fire protection, which extend the fire protection requirements applied to accommodation, service spaces, and some control stations to all control stations and cargo control rooms on new cargo ships.
Emerging technologies and operational challenges are also addressed. The IMO is continuing to develop a mandatory Maritime Autonomous Surface Ships (MASS) Code, currently anticipated to enter force in 2032, establishing a framework for the safe deployment of autonomous cargo vessels.
A significant revision of SOLAS Chapter III and the LSA Code is also planned, predicted to enter force on 1 January 2032, aiming to restructure requirements and address gaps.
Seafarer welfare
Seafarer welfare and training receives renewed focus. Amendments to the STCW Code on the prevention of sexual assault and harassment enter force on 1 January 2026, requiring specific training for seafarers. Work continues on a comprehensive review of the STCW Convention expected to be completed in the early 2030s.
Newly agreed amendments to the Maritime Labour Convention are aimed at continuing to improve seafarers’ welfare, in particular their repatriation and leave ashore while in port.
Compliance will involve revising operational procedures, upgrading equipment, ensuring crews’ training is updated, and planning for future technologies that contribute to a safer and more sustainable future for shipping.
…said Mark Twol.
