Navigating New IMO Regulations: Technical Compliance Strategies

The regulatory landscape for international shipping continues to tighten as environmental, safety and operational requirements evolve. Throughout 2025 and into 2026, several significant IMO regulations have entered or are entering force, each requiring different compliance approaches and technical preparations. For shipowners, operators and technical managers, understanding these changes and planning accordingly is essential to avoid operational disruptions and maintain regulatory standing.

Hong Kong Convention: Ship Recycling Compliance

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships entered into force on 6 June 2025. The convention applies to ships of 500 gross tonnage and above engaged in international voyages, establishing requirements for how vessels must be prepared for eventual recycling.

The central requirement is the Inventory of Hazardous Materials, which must be developed and maintained throughout a vessel’s operational life. For existing ships, an International Certificate on Inventory of Hazardous Materials must be obtained by 26 June 2030, unless the vessel is bound for recycling earlier.

Preparing an IHM for existing vessels requires both document review and physical verification. Unlike newbuilds where material declarations can be collected during construction, existing ships need targeted visual inspections and sampling to identify hazardous materials in their structure and equipment. This process should identify materials listed in the convention’s appendices, including asbestos, heavy metals, ozone-depleting substances and various chemical compounds used in coatings, insulation and electrical equipment.

Classification societies are harmonising IHM surveys with other statutory surveys to reduce administrative burden. The initial International Certificate on Inventory of Hazardous Materials is typically issued at the next main class renewal survey falling between 26 June 2025 and 25 June 2030.

For vessels approaching the end of their service life, additional requirements apply. Ships bound for recycling must only use authorised recycling facilities holding valid documentation. A final survey must be completed before recycling begins, and the facility must prepare a ship-specific recycling plan detailing how hazardous materials will be managed.

SOLAS Amendments: Lifting Appliances

From 1 January 2026, new SOLAS regulations introduce stringent requirements for shipboard lifting appliances and anchor handling winches. Resolution MSC.532(107) sets enhanced safety standards covering certification, load testing, thorough examination and maintenance.

Lifting appliances installed before 1 January 2026 must undergo load testing and thorough examination according to IMO guidelines. Each appliance must be permanently marked with its safe working load and supported by documentary evidence. Existing certificates issued under other international instruments, such as ILO Convention No. 152, will be acceptable for compliance.

For equipment without valid certificates, determining the appropriate safe working load becomes the owner’s responsibility. This typically requires engineering assessment based on the equipment’s design, condition and operational profile. Training requirements also form part of the new regulations. Personnel operating lifting appliances must be properly trained, qualified and familiarised with the equipment.

Carbon Intensity Indicator: Updated Reduction Targets

The IMO has set new Carbon Intensity Indicator reduction factors extending through to 2030, requiring ships of 5,000 gross tonnage and above to update their Ship Energy Efficiency Management Plans. The reduction targets reach 21.5% by 2030, measured against the baseline.

All ships must revise their SEEMP Part III by 31 December 2025 to include implementation plans addressing the new reduction factors for the 2026-2028 period. The revised plan must include the required annual operational CII and be approved by the flag administration or recognised organisation.

Meeting these targets requires careful operational planning. Speed optimisation, route efficiency, hull and propeller maintenance, and energy management all contribute to reducing carbon intensity. Technical interventions such as improved coatings, propeller polishing and machinery optimisation can deliver measurable improvements in fuel efficiency.

The CII rating system assigns vessels to categories from A (best performance) to E (worst performance). Vessels receiving D or E ratings for three consecutive years face additional requirements. This makes continuous monitoring and adjustment essential. Condition monitoring systems provide valuable input for CII management. Hull roughness monitoring, propeller condition assessment and machinery performance tracking all indicate when maintenance interventions can improve efficiency.

MARPOL Annex VI: Fuel and Emissions Updates

Amendments to MARPOL Annex VI taking effect on 1 August 2025 bring clarity to definitions around gas fuels and low-flashpoint fuels. The revisions also address engine replacements, data reporting requirements and bunker delivery note procedures.

The amendments clarify that replacing a steam system with a diesel engine constitutes a major conversion rather than a minor modification. Where a Tier III engine would normally be required but a Tier II engine is permitted as the replacement, the flag administration must report this to the IMO.

Ships replacing steam systems after 1 August 2025 need to ensure new engines comply with applicable nitrogen oxide emission limits under Regulation 13. Early consultation with classification societies and flag administrations helps avoid compliance issues during installation.

Regional Requirements: Mediterranean Emission Control Area

The Mediterranean Sea became a Sulphur Oxides and Particulate Matter Emission Control Area on 1 May 2025. Ships trading in Mediterranean waters must use fuel with a sulphur content not exceeding 0.10% mass by mass, or employ approved equivalent abatement technology such as scrubbers.

This represents a significant reduction from the global limit of 0.50% applicable outside emission control areas. Vessels operating regular Mediterranean routes need to plan fuel procurement carefully, ensuring compliant fuel is available at bunkering ports. Scrubber systems, where fitted, must be operated correctly and monitored to demonstrate equivalent compliance.

Planning for Compliance

The regulatory changes entering force during 2025 and 2026 reflect the maritime industry’s ongoing evolution. Compliance requires technical understanding, careful planning and systematic implementation. With appropriate preparation and support, these requirements can be integrated into existing operations without disrupting service or creating unnecessary administrative burden.