Operational Guide · Registers & Logbooks

# Autonomous Ships (MASS): the Company's Responsibility under the SMS

The MASS Code governs the ship; but according to the IMO, who answers when a remote operation goes wrong remains the ISM Company, and its SMS must say so explicitly.

MASS ISM Code MSC 108 Remote Operation Centre SMS

## Operational Explanation

Alongside the development of the MASS Code (Maritime Autonomous Surface Ships, adopted as a non-mandatory instrument at MSC 111, May 2026), the Maritime Safety Committee addressed, already at its 108th session (May 2024), a distinct but complementary question: who is responsible, within the ISM framework, for the operational safety of an autonomous or remotely controlled ship. The position agreed at MSC 108 is that responsibility for the safe operation of a MASS ship remains with the ISM Company, exactly as for a conventional ship, regardless of the degree of operational autonomy.

This means the Company's Safety Management System must be able to answer, explicitly and with documentation, questions the traditional ISM Code never had to address: who is the Designated Person Ashore (DPA) responsible for a Remote Operation Centre (ROC)? What competence and certification must a remote operator hold? What procedures govern the handover between autonomous and manual control in the event of system degradation? The Company's responsibility does not change; what changes is the practical content the SMS must regulate to fulfil it.

## Regulatory Reference

MSC 108 (May 2024): responsibility for the safe operation of a MASS ship remains with the ISM Company. To be read alongside the MASS Code (adopted at MSC 111, May 2026, non-mandatory, in force from 1 July 2026) and the existing ISM Code (in particular the responsibility and authority requirements of Section 3, and Management of Change procedures).

## Scope of Application

Every Company that operates or plans to operate MASS ships, or ships with partial remote-control/autonomous functions, subject to the ISM Code.

## Procedure / How to Complete It

1. Explicitly define in the SMS the responsibility and authority structure for MASS/remote operations, including the role of the Designated Person Ashore for the Remote Operation Centre (ROC).
2. Establish competence and certification requirements for remote operators, consistent with the ship's level of autonomy and with the evolution of the MASS Code.
3. Document handover procedures between autonomous and manual control, particularly in the event of system degradation or loss of communication with the ROC.
4. Treat the introduction of MASS or remote operations as a formal Management of Change, not as a simple extension of existing procedures.
5. Coordinate the SMS's evolution with the development of the MASS Code (voluntary introduction phase 2026-2028, Experience-Building Phase from December 2026), updating procedures as the regulatory framework evolves.

## Practical Example

Example: a Company launching a remote-controlled ship pilot project designates a DPA specifically responsible for the Remote Operation Centre, establishes a documented handover procedure for switching to manual control in the event of loss of communication, and treats the entire project as a formal Management of Change with a corresponding risk assessment.

## Real Cases

The most concrete practical risk in MASS operations is not technological but organisational: without an explicit responsibility structure in the SMS, an incident during a remote operation risks leaving the Company unprepared to answer the simplest question an auditor or investigator can ask: who was responsible, at that moment, for that operational decision?

## Common Mistakes Mistake Library

Mistake | Consequence | How to avoid it
--- | --- | ---
MASS/remote operations introduced without a formal Management of Change in the SMS | Absence of a documented risk assessment specific to the new operating model | Always treat the introduction of MASS/remote operations as a full Management of Change
No DPA or explicit person designated as responsible for the Remote Operation Centre | Ambiguous responsibility structure in the event of an incident during a remote operation | Explicitly designate in the SMS the DPA or the person responsible for the ROC
Handover procedures between autonomous and manual control not documented or not tested | Improvised handling of a system degradation situation, with a risk to safety | Document and periodically test handover procedures, including them in the training of remote operators

## PSC Observations

The MASS Code is not yet mandatory and is therefore not subject to direct PSC verification; however, for ships already operating remote-control or partial autonomous functions, ISM certification auditors may verify the SMS's consistency with the operational responsibility agreed at MSC 108, as part of the normal verification of the safety management system.

## Operational Tips

- Don't wait for the MASS Code to become mandatory (not expected before 2032) to define MASS operational responsibility in the SMS: the IMO's position on this point has already been clear since 2024.
- Always designate a DPA or an explicit person responsible for the Remote Operation Centre, distinct if necessary from the traditional DPA for the conventional fleet.
- Treat every introduction of remote/autonomous operations as a formal Management of Change, not as a minor technical adjustment.

## Checklist

- Responsibility and authority structure for MASS/remote operations explicitly defined in the SMS
- DPA or person responsible for the Remote Operation Centre designated
- Competence and certification requirements for remote operators established
- Handover procedures between autonomous and manual control documented and tested
- Introduction of MASS/remote operations treated as a formal Management of Change

## FAQ

Who is responsible for the operational safety of a MASS ship according to the IMO?
Under the position agreed at MSC 108 (May 2024), responsibility remains with the ISM Company, as for a conventional ship, regardless of the degree of operational autonomy.
Does the MASS Code replace the ISM Code for autonomous ships?
No: the MASS Code (adopted at MSC 111, May 2026) governs the specific technical and operational requirements of the autonomous ship, but managerial responsibility remains with the ISM Company under the existing ISM Code.
What must a Company introducing MASS or remote operations actually do?
Explicitly define in the SMS the responsibility structure (including the DPA for the Remote Operation Centre), the competence requirements for remote operators, the handover procedures between autonomous and manual control, and treat the introduction as a formal Management of Change.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

MASS Code: the IMO's New Framework for Autonomous Ships Management of Change

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