The Autumn 2025 edition of Lloyd’s Register’s Future IMO and ILO Legislation highlights a fast-evolving regulatory landscape that will reshape ship design, operations, fuel choices, and crew safety for the remainder of the decade. This article summarises the most important changes—both adopted and under development—affecting shipowners, operators, designers, and maritime regulators.
Why These Regulatory Updates Matter
The maritime sector is entering an era of accelerated regulatory tightening driven by decarbonisation, digitalisation, alternative fuels, and enhanced crew protection. The IMO’s revised climate ambitions, ongoing revisions to MARPOL and SOLAS, and upcoming ILO rules are converging into a multi-year compliance roadmap. As shown in the timelines on pages 5–6 of the LR report, major regulatory milestones will occur every year from 2025 onward.
Key Safety Requirements Entering into Force (2025–2028)
Computerised Flooding-Stability Support (2025)
Existing passenger ships of 120 m+ must be equipped with systems capable of calculating stability after damage, supporting masters during flooding events (p.12). This aligns older vessels with standards already required for newbuilds.
Revised EEDI Phase 3 Thresholds (2025)
A major change is the two-stage implementation of Phase 3 EEDI reductions. Dates and reduction factors have shifted for several ship types, making some requirements effective earlier than expected (pp.13–16). Newbuild designs must integrate more aggressive energy-efficiency measures, from hydrodynamic improvements to renewable-power integration.
Heavy Fuel Oil Restrictions in Arctic Waters (2024–2029)
MARPOL Annex I amendments introduce a phased ban on the use and carriage of HFO in Arctic waters, with limited waivers only until 2029 (p.16–17). This will influence fuel strategies for ships trading in polar regions.
Anti-Fouling Controls: Cybutryne Ban (2023–2025)
All ships must eliminate or seal anti-fouling systems containing cybutryne by the next renewal—no later than 60 months after the last application (pp.17–18). Updated AFS certificates are mandatory from 2025.
IGF Code Enhancements (2024)
Multiple amendments strengthen requirements for ships using gas or low-flashpoint fuels, including secondary enclosures for piping, enhanced gas-leak detection, and upgraded fire-safety provisions in fuel preparation rooms (pp.18–19). These significantly affect LNG-fuelled cargo ships and future hydrogen/ammonia-ready concepts.
Mooring and Towing Safety (2024 onward)
New SOLAS II-1/3-8 requirements introduce mandatory mooring-equipment design criteria, maintenance plans, and documentation for both new and existing ships (pp.19–21). The rules address rising accidents during mooring operations.
Modernised Watertight Integrity Requirements (2024 onward)
Broad SOLAS revisions update watertight-boundary standards, openings in shell plating, internal subdivision above the bulkhead deck, and rules for ro-ro passenger ships (pp.21–23). New ships must follow stricter design and testing requirements.
Mandatory Water-Level Detectors on Multi-Hold Cargo Ships (2024 onward)
Following safety lessons from the El Faro casualty, multi-hold cargo ships (other than tankers and bulk carriers) must be fitted with dedicated water-level detectors—not just bilge alarms (pp.23–24).
Environmental Regulations Taking Effect (2026–2031)
Ballast Water Management (BWM Convention Review, 2026+)
The convention enters a new stage with experience-building insights informing revisions to compliance and monitoring (timeline, p.6). Changes are expected to refine system performance and enforcement.
MARPOL Annex VI Updates
Several amendments will strongly influence carbon-intensity compliance and future emissions control:
- Short-Term GHG Measure Review (CII/EEXI), expected 2030 – Potential re-calibration or strengthening of CII ratings (p.6, p.9).
- NOx/SOx Emission Control Areas under consideration – Norwegian Sea and Canadian Arctic ECAs may impose Tier III-level restrictions (timeline, p.6).
- Regulation 27 – DCS Data Access – Increasing transparency in fuel and emissions reporting (p.6).
- New sewage-treatment performance standards under Annex IV will apply by 2031 (timeline, p.6).
Digitalisation, Navigation, and Communications
VHF Data Exchange System (VDES)
Draft SOLAS V amendments will introduce VDES as a mandatory communication and data-exchange system—reshaping ship-shore data connectivity (p.4).
Updated Meteorological, Radiocommunication and Navigation Warning Provisions
Draft amendments to SOLAS chapters IV and V modernise requirements for global distress, safety communications, and weather reporting (p.4).
Labour and Crew-Welfare Reforms (2027)
The ILO is preparing several amendments to the Maritime Labour Convention (MLC, 2006), expected by December 2027, covering:
- strengthened repatriation rights
- improved shore leave conditions
- enhanced investigation of marine casualties
- improved onboard complaints procedures
- expanded measures against harassment, bullying, and sexual assault (p.8)
These changes will require updates to company policies and DMLC documentation.
Future Regulations Currently Under Development (2028–2032)
Several transformative regulatory initiatives are still being negotiated:
Maritime Autonomous Surface Ships (MASS Code, target 2032)
A full goal-based instrument for autonomous-vessel design and operation is under development (p.4, p.10).
Alternative Fuels Safety Framework (Under Discussion)
A new overarching regulatory framework will address risks associated with hydrogen, ammonia, methanol, and emerging hybrid systems (p.4).
STCW Convention Comprehensive Review (2031–2032)
The global training convention is being restructured to reflect digital navigation, alternative fuels, cyber-security, and modern watchkeeping principles (p.4, p.9).
Hong Kong Convention for Ship Recycling (Entry into Force: 26 June 2025)
A major regulatory milestone:
-
From June 2025, all new ships must carry an approved Inventory of Hazardous Materials (IHM).
-
Existing ships must comply by 2030.
-
Ships being recycled must use authorised facilities with approved Ship Recycling Plans and certified IHMs (pp.25–26).
This marks the start of globally harmonised, mandatory ship-recycling standards.
What Shipowners Should Prioritise Now
Based on the timelines and rule-change summaries in the report, industry stakeholders should begin preparing for:
-
Design modifications for EEDI Phase 3 and alternative-fuel readiness
-
Upgrades to safety systems—flood-stability tools, water-level detectors, mooring-equipment compliance
-
Fuel-strategy adjustments for Arctic operations and upcoming ECAs
-
Enhanced documentation, maintenance records, and crew procedures
-
IHM compliance ahead of the Hong Kong Convention’s enforcement
-
Technology planning for VDES and next-generation communication systems
Conclusion
The 2025–2032 regulatory horizon is one of the most consequential in decades. The combination of GHG-reduction measures, safety reforms, alternative-fuel standards, labour protections, and digital navigation mandates will reshape maritime operations and fleet-renewal strategies. Shipowners and shipyards must begin forward-planning now, incorporating compliance considerations into newbuild designs, retrofits, and operational policies.
For maritime professionals, staying ahead of these developments is not only a compliance obligation—it is a strategic necessity for competitive, safe, and sustainable operations.