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

Autonomous or remote operations need explicit roles and operating conditions: the Company, Master and remote centre are not interchangeable. The non-mandatory MASS Code provides a framework to coordinate with ISM, authorisations and the ship's concept of operations.

Operational Explanation

The MASS Code, adopted by MSC.595(111) and effective from 1 July 2026 as a non-mandatory instrument, distinguishes Company responsibilities, the Master's authority and ROC functions. It does not allocate all responsibility to one person or replace ISM. Section 14.2.1 provides for a human Master responsible at all times, for only one MASS at a time; when persons are onboard, the Master must be onboard under this framework.

The SMS must describe who decides, who operates, and who provides support and monitoring, consistent with the concept of operations (ConOps), operational envelope (OE) and authorised conditions. The DPA retains ISM §4 functions and is not automatically the ROC's operational manager. A lost connection cannot be resolved by a generic 'switch to manual' instruction where no attended local control exists or remote control depends on the failed link.

Regulatory Reference

Sources: MSC.595(111), MSC 111/22 Annex 16 · IMO MASS FAQ · ISM A.741(18), §§3–5 · ISM amendments. The MASS framework is non-mandatory; applicable mandatory instruments and authorisations remain to be complied with. The roadmap towards a mandatory code in 2032 is a target, not an adopted entry-into-force date. MSC 112, scheduled for December 2026, is to develop the Experience-Building Phase framework; this is not an automatic start of that phase.

Scope of Application

The MASS Code addresses cargo ships to which SOLAS chapter I applies, including relevant ROCs; the Administration may determine its application to other ships where existing instruments are impracticable or insufficient. Cargo high-speed craft under SOLAS X and warships, naval auxiliaries or government ships on non-commercial service are excluded. An automated function alone does not make every ship a MASS: assess scope, ConOps and authorisations.

Procedure / How to Complete It

1. Determine applicable scope, ConOps, OE and authorisation conditions with the Administration and other competent parties.
2. Define Company responsibilities, the Master's authority, ROC management and operators in the SMS; preserve the DPA's monitoring and liaison functions.
3. Define operator competence, availability and responsibilities under the approved framework without inventing a universal certification requirement.
4. Document and test control transfer, degradation, link loss and fallback conditions: each response must be feasible in the actual configuration.
5. Manage the change through risk assessment, approvals, training and pre-use verification; separately monitor future Code developments.

Practical Example

What Typically Goes Wrong

Common Mistakes Mistake Library

What the PSCO Checks

Operational Tips

• Make roles and authority limits verifiable, beyond an organisation chart.
• Test fallback in actual conditions without assuming onboard personnel or continued connectivity.
• Keep the future roadmap separate from today's authorised conditions.

Preparation checklist

Educational checklist. This summary supports learning and preparation only. It does not replace the vessel’s approved procedures, manuals, statutory documents, company SMS, or applicable official requirements. Completing it demonstrates neither compliance nor readiness for an inspection: it shows that a list has been read, not that the ship is in order. Always verify the current documents carried on board.

• Scope, ConOps, OE and authorisations checked
• Company, human Master, ROC and DPA roles distinguished
• Competence and availability defined
• Control transfer and fallback demonstrated
• MoC, training and pre-use verification completed

FAQ

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Last substantive revision of this page: 15 September 2026 · page fingerprint 02715d14e0df