Remote surveys, ISM audits and ISPS checks after MSC 111

Under IMO guidance approved at MSC 111, parts of some statutory surveys, some ISM company audits and, in exceptional cases, a few ISPS items may be done remotely, but only with flag approval. Shipboard ISM audits cannot normally be fully replaced by remote audits, and initial, renewal and interim company audits still need an auditor in person. The guidance harmonises remote survey and audit provisions that already existed in the 2023 HSSC Survey Guidelines and ISM implementation guidelines. It does not create the option for the first time.

Key points

• MSC 111 (13 to 22 May 2026) approved Guidance on assessments and applications of remote surveys, ISM Code audits and ISPS Code verifications, in concurrence with MEPC 84. Its circular number is not yet confirmed.
• Parts of a statutory survey can be done remotely, based on a risk assessment and on whether the item is eligible for remote methods. The flag must approve the survey plan in every case.
• The same survey item cannot be surveyed remotely in two consecutive years.
• Under normal circumstances, initial and renewal surveys should not be done remotely, except for document checks (HSSC Survey Guidelines, A.1207(34), 5.15.4).
• DNV says remote surveys are not accepted for "SOLAS safety certificates and the International Load Lines Certificate for passenger ships". Its sentence can be read two ways. See below.
• ISM: initial, renewal and interim company audits need an auditor present. Remote methods may be considered for annual audits, and for an interim audit to add a new ship type to an existing DOC, with flag approval. Shipboard audits cannot normally be fully replaced by remote audits.
• ISPS verifications can be remote only in exceptional circumstances, and only for selected items. The Liberian Registry's summary of III 11 says this applies only to interim, intermediate and additional verifications. We have not confirmed that in the approved text.
• Remote inspection techniques (RIT) under the amended ESP Code, resolution MSC.584(111), are not remote surveys. The surveyor is still on board. The amendments enter into force on 1 January 2028.

What MSC 111 approved

Remote surveys and audits are not new in IMO guidance. The HSSC Survey Guidelines (resolution A.1186(33), 2023, now replaced by A.1207(34), 2025) and the guidelines on implementing the ISM Code (resolution A.1188(33), 2023) already allow them, mainly in extraordinary circumstances such as natural disasters, war or a pandemic. The IMO's Sub-Committee on Implementation of IMO Instruments (III) finalised common guidance at III 11 in July 2025 to harmonise how flags and recognised organisations (ROs) apply them. MSC 111 approved it in concurrence with MEPC 84.

The number. The IMO's MSC 111 meeting summary names the guidance but gives no circular number. The Liberian Registry lists it as MSC-MEPC.5/Circ.17 in an annex it calls provisional. IRClass shows the number as "XXXX". We refer to it by title until the IMO publishes it.

What we read. We could not find the text of the circular on the IMO website, so we have not seen it. What we say about it comes from the IMO meeting summaries and from summaries by DNV, the Liberian Registry and other Class societies, and we name the source for each point. We did read the HSSC Survey Guidelines, A.1188(33) and the text of MSC.584(111). Check the circular itself before you rely on a fine point.

Two terms first:

• Remote survey: the surveyor or auditor checks an item without being on board. The crew or a service supplier shows it on live video, sends photos or shares documents, under the surveyor's direction.
• Flag administration: the ship's flag state, which issues statutory certificates or authorises an RO (usually the Class society) to issue them for it.

The guidance is not mandatory. It tells flags and ROs how to judge requests. It does not give a ship a right to a remote survey.

What can be remote and what cannot

Passenger ships. DNV's MSC 111 and III 11 summaries both say remote surveys are not accepted for "SOLAS safety certificates and the International Load Lines Certificate for passenger ships". It is unclear whether "for passenger ships" covers both certificates or only the Load Line Certificate. No other summary we read mentions it. Note that the Passenger Ship Safety Certificate is renewed every year, and renewal surveys are normally attended anyway under A.1207(34).

ISM changes ahead. The Liberian Registry noted an ambiguity between section 4.8 of A.1188(33) and the new guidance, to be resolved in a full revision of the ISM implementation guidelines. III 12 began that revision in July 2026 (DNV), so check for updates before you plan audits.

Two points the summaries leave open, so ask your flag or RO:

1. Which items are eligible. There is no IMO list yet. III 12 endorsed a coding system to mark the remote eligibility of individual items in the HSSC Survey Guidelines, with work continuing between sessions (DNV). Lloyd's Register describes it as part of draft amendments for a 2027 edition planned to take effect on 1 January 2028. The Liberian Registry says the guidance may be reviewed once the coding system exists.
2. What counts as "exceptional" for ISPS. DNV says "exceptional", the Liberian Registry "extraordinary". Neither defines it.

Where flag practice differs

Every remote survey or audit needs flag approval, so the flag decides in the end.

• A flag can refuse remote methods for an item even if the guidance would allow them.
• Flags can set their own lead times, required evidence (live video, photos, records) and formats.
• Some flags issued their own remote survey notices before the guidance. We did not check which have updated them.
• Class surveys are a separate matter. The guidance covers statutory surveys, ISM audits and ISPS verifications. Your Class society's rules decide what can be remote for Class.

Worked example: annual survey in a remote port

This is a hypothetical ship.

A 2015-built Supramax bulk carrier has a certificate anniversary date of 20 April 2027. Her annual survey window runs from three months before to three months after that date, so 20 January to 20 July 2027 (SOLAS regulation I/10; A.1207(34)). Her only port call inside the window is a remote anchorage where no RO surveyor is available.

1. Late 2026. The superintendent asks the RO which annual survey items could be done remotely, and the risk assessment is done as the flag directs. January would be late, because the window opens on 20 January.
2. January 2027. The RO sends the flag a survey plan listing the remote items and those that wait for an attended visit. The flag approves it.
3. April 2027. The remote items are done by live video with the chief officer and chief engineer. Anything not cleared remotely is handled under the approved plan.
4. Record it. List the items surveyed remotely in 2027. At the 2028 annual survey, they cannot be surveyed remotely again.

Two limits apply. First, the Class annual survey usually falls in the same window. If Class needs a surveyor on board, remote statutory items may not save a visit. Second, she is surveyed under the ESP Code, so her annual survey includes cargo hold examinations. None of the sources we read says that ESP Code survey items can be surveyed remotely, so plan them as attended. The new RIT rules do not help here, because RIT still needs the surveyor on board.

Worked example: ISM audits for a ship manager

This is a hypothetical company.

A manager's Document of Compliance (DOC, the ISM certificate for the company's office) has an anniversary date of 10 September 2027.

• Annual verification, window 10 June to 10 December 2027 (ISM Code 13.4). DNV's summary says remote methods may be considered for annual audits. Ask the flag and send the audit plan well in advance, ideally before June.
• Adding gas carriers to the DOC in 2027. The interim audit for the new ship type may also be considered for remote methods, with the same approval.
• DOC renewal audit, when due. An auditor must attend.
• Shipboard audits for the Safety Management Certificate (SMC). Remote audits cannot normally fully replace them, so plan attendance around port calls as before.

RIT under the amended ESP Code is not a remote survey

MSC 111 adopted amendments to the International Code on the Enhanced Programme of Inspections during Surveys of Bulk Carriers and Oil Tankers, 2011 (ESP Code) by resolution MSC.584(111). They allow remote inspection techniques (RIT), such as drones, robots and remote cameras, to support close-up surveys and thickness measurements, and enter into force on 1 January 2028. Lloyd's Register says they apply to ESP surveys starting on or after that date where RIT is to be used, whatever the ship's build year. MSC.1/Circ.1700, Guidelines on the use of remote inspection techniques for ESP Code surveys, was approved with them.

RIT itself is not new. Lloyd's Register says it was already permitted as "other equivalent means", with flag agreement case by case. The amendments set a standard framework.

The amended Code defines RIT as a means of survey without the surveyor needing direct physical access to the structure. DNV calls RIT distinct from remote surveys. The Liberian Registry says it "does not constitute a 'remote survey'".

Main conditions in the text of MSC.584(111):

• RIT is done by a firm approved as a service supplier, in the surveyor's presence and under their continuous direction and control. The firm's certificate is renewed at intervals of no more than three years.
• If RIT shows damage or deterioration needing attention, the surveyor requires a traditional survey without RIT. The surveyor also picks locations for random confirmatory surveys.
• For periodic surveys after the third renewal survey, RIT needs the agreement of the flag Government itself, not the RO, which may add requirements. Lloyd's Register puts it as "from the third special survey onwards" (typically ships over 15 years old). Ask your flag how it reads this.
• At renewal surveys, RIT may only be used where no permanent means of access is provided, and not in areas with a recorded significant history of structural failures.
• RIT must not be used in ballast tanks or other spaces where a hard protective coating is required and is in less than GOOD condition. It is also barred in ballast tanks with soft or semi-hard coating, and in ballast tanks not hard-coated since construction. It is not barred from all ballast tanks.
• The RIT proposal goes to the flag for approval in the survey programme. The RIT firm joins the survey planning meeting, and RIT is validated on board before every survey.

Example (hypothetical). A 2008-built Capesize faces her fourth renewal survey in mid-2028. If the survey starts on or after 1 January 2028 and RIT is planned, the amended Code applies. Her third renewal survey was in 2023, so on either wording above, RIT needs her flag's agreement. RIT can only be used where no permanent means of access is provided. In her ballast tanks it is ruled out wherever the hard coating is below GOOD; tanks with hard coating in GOOD condition are not excluded by that rule. The surveyor still boards, directs the drone operator, picks confirmatory spots and examines any damage close up. This is not a remote survey, and the two-consecutive-years rule has nothing to do with it.

How to plan with this

• Ask your RO early which items are candidates for remote survey. The flag approves the plan, so build in time.
• Keep a record of which items were surveyed remotely each year. The next year's plan depends on it.
• Plan in-person attendance for initial and renewal surveys, SMC audits, DOC initial, renewal and interim audits, and passenger ship surveys.
• Treat remote ISPS verification as a last resort, not a planning option.
• For ESP surveys from 1 January 2028, discuss RIT with Class and the flag as a question of access, and check ballast tank coating condition early.