Operational Guide · Registers & Logbooks

# Change of Flag and the Shadow Fleet: What Changes for Surveys and Certificates

A ship removed from a registry for sanctions violations can obtain a new flag within days: the flag-hopping phenomenon of the so-called shadow fleet is putting the entire statutory verification system under pressure.

change of flag shadow fleet flag hopping statutory certificates

## Operational Explanation

The flag-hopping phenomenon reached a peak in 2025-2026, with ships repeatedly changing flag to evade controls, particularly among vessels involved in the trade of sanctioned oil (Russia, Iran, Venezuela). Over 300 tankers in the so-called shadow fleet fraudulently changed flag during 2025, often after being deregistered from permissive registries (including Gabon, Cook Islands, Barbados, Comoros, Gambia) under Western pressure, at times remaining effectively without a valid flag (stateless).

A legitimate change of flag always requires a complete new set of statutory certificates issued under the requirements of the new Flag Administration, with verification surveys often conducted on a fast timeline. The shadow fleet phenomenon has driven a significant increase in flag changes toward registries perceived as less rigorous in their verification, including a wave of re-flagging toward the Russian registry observed since May 2025, accelerated by the seizure of sanctioned ships by the United States, the United Kingdom and France.

## Regulatory Reference

There is no single dedicated IMO standard for change of flag; the requirements of the destination Flag Administration apply for the issuance of statutory certificates, supplemented by guidelines on Flag State Reform discussed at the international level in response to the shadow fleet and flag-hopping phenomenon observed in 2025-2026.

## Scope of Application

Every ship undergoing a change of flag (transfer of flag), with particular attention to the implications for the continuity and validity of statutory certificates during the transition period between the old and new Flag Administration.

## Procedure / How to Complete It

1. Verify that the change of flag is completed through a formal, documented procedure, with continuity of statutory certificate validity during the transition.
2. Request prompt issuance from the new Flag Administration of the complete set of required statutory certificates, coordinating the necessary verification surveys.
3. Verify that the Classification Society (if changed together with the flag) re-establishes coordination between class and statutory surveys under the new RO.
4. Pay particular attention to the reputation and verification rigor of the new Flag Administration, especially in the case of frequent flag changes or changes toward registries with a weaker track record.
5. Document the ship's history of flag changes, since a pattern of frequent flag-hopping can attract heightened PSC attention.

## Practical Example

Example: a ship changing flag coordinates with the new Flag Administration the issuance of statutory certificates (Load Line, Safety Construction, Safety Equipment) before the previous flag's certificates expire, avoiding a documentary gap that would compromise the ship's ability to operate legally.

## Real Cases

The shadow fleet phenomenon, with over 300 tankers fraudulently changing flag in 2025 and a wave of re-flagging toward the Russian registry accelerated by Western seizures since December 2025, illustrates how the Flag Administration-based verification system can be exploited when registries fail to apply rigorous control, with direct consequences for the credibility of the statutory certification system across the entire industry.

## Common Mistakes Mistake Library

Mistake | Consequence | How to avoid it
--- | --- | ---
Change of flag completed without ensuring continuity of statutory certificate validity during the transition | Documentary gap period in which the ship operates without fully valid statutory certificates | Always plan the change of flag to ensure documentary continuity, coordinating issuance of the new certificates before the previous ones expire
History of the ship's flag changes not documented or not considered relevant | Surprise in the face of heightened PSC attention for a pattern of frequent flag-hopping | Always document the history of flag changes, aware that a frequent pattern can attract additional controls
Verification rigor of the new Flag Administration not assessed before the change of flag | Unintended association with a registry perceived as permissive, with reputational impact | Always assess the reputation and verification track record of the destination Flag Administration before the change

## PSC Observations

PSCOs pay particular attention to ships with a history of frequent or recent flag changes, especially toward registries associated with weaker verification rigor, and may intensify documentary checks on recently issued statutory certificates.

## Operational Tips

- Always plan the change of flag to ensure continuity of statutory certificate validity, with no documentary gap.
- Document the ship's history of flag changes: a frequent pattern attracts heightened PSC attention.
- Assess the verification rigor of the destination Flag Administration before completing the change, considering the reputational implications.

## Checklist

- Continuity of statutory certificate validity ensured during the flag transition
- Complete set of statutory certificates from the new Flag Administration requested and promptly issued
- Class/statutory survey coordination re-established with the new RO if the Classification Society has changed
- Verification rigor of the new Flag Administration assessed before the change
- History of the ship's flag changes documented and available

## FAQ

What is flag-hopping as observed in the context of the shadow fleet?
The repeated, often fraudulent change of flag by ships involved in the trade of sanctioned oil, to evade controls; in 2025 over 300 tankers followed this pattern, often after being deregistered from permissive registries under Western pressure.
What happens to statutory certificates when a ship changes flag?
The new Flag Administration must issue a complete new set of statutory certificates, with verification surveys often conducted on a fast timeline; documentary continuity must be ensured during the transition.
Why can a pattern of frequent flag changes attract PSC attention?
Because it can be associated with an attempt to evade controls or with registries offering weaker verification rigor, prompting PSCOs to intensify documentary checks on recently issued certificates.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

Harmonized System of Survey and Certification (HSSC)Coordination between Class Surveys and Statutory Surveys (RO)

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