Persons with Reduced Mobility: Accessibility on Board
Physical accessibility, assistance rights and digital services follow different instruments: MSC/Circ.735 is guidance, EU Regulation 1177/2010 governs assistance and non-discrimination, and the EAA only specified service elements.
Operational Explanation
Keep three instruments separate. MSC/Circ.735 provides design and operational guidance unless made binding. Regulation (EU) 1177/2010 governs non-discrimination, access conditions and assistance within its scope. Directive (EU) 2019/882 concerns specified digital and ticketing elements of waterborne passenger transport services.
Regulatory Reference
MSC/Circ.735: IMO guidance. Regulation (EU) 1177/2010: rights and assistance with its own exclusions. Directive (EU) 2019/882, arts. 2 and 4: websites, apps, e-tickets, information and certain terminals; it excludes self-service information terminals integrated into ships and contains further exceptions.
Within Regulation 1177/2010, assistance is free. Normally notify the need at least 48 hours ahead unless a shorter period is agreed; without notification, all reasonable efforts to assist are still required. Lack of notice is not an automatic refusal ground. Also check reporting arrangements and Article 8 safety limitations. Regulation 1177/2010, Articles 8, 10–11.
For the EAA, check the exemption for microenterprises providing services (Article 4.5), documented Article 14 conditions and Article 32 transitions; these are not a general extension for all websites and services. Directive 2019/882.
For physical accessibility on domestic voyages also check Directive 2009/45/EC, Articles 3 and 8 and Annex III: passenger ships of at least 24 m and high-speed craft within its scope, subject to its exclusions. Article 8 distinguishes keels/equivalent stage from 1 October 2004 and modifications of earlier vessels, where guidelines apply as far as economically reasonable and practicable. Directive 2009/45/EC.
Regulation 1177/2010 Article 2.2 excludes, among others, ships carrying up to 12 passengers, services with operating crew up to three or distances below 500 m, excursions other than cruises, and specified non-mechanical or historic vessels; Article 2.4 allows specific public-service exemptions. Do not extend the EAA Article 3.35–36 urban/suburban/regional definitions to waterborne services: they cover the listed land modes.
MSC/Circ.735’s design guidance concerns new passenger ships, particularly public-transport ro-ro ferries; consider its operational recommendations separately.
Scope of Application
Determine each instrument's scope and exceptions separately. The EAA does not by itself make onboard cabins, routes or emergency stations mandatory from 2025 and does not cover information terminals integrated into the ship.
Procedure / How to Complete It
- Apply or consider MSC/Circ.735 as guidance unless implemented.
- Check rights and assistance under Regulation 1177/2010.
- Map only listed EAA elements and exceptions.
- Do not merge physical design, assistance and digital accessibility into one claim.
Practical Example
A company checks EAA-covered websites, apps and ticketing against national measures applying from 28 June 2025, documenting any transitions or exemptions. It separately arranges assistance and emergency procedures for PRM passengers.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Extending the EAA indiscriminately to every digital system and onboard self-service terminal | The compliance perimeter exceeds the Directive’s scope | Check the specific transport-service elements in Article 2, exceptions and transitions; exclude self-service information terminals integrated into ships |
| PRM needs not integrated into emergency procedures | Late or insufficient assistance | Integrate applicable needs into the muster plan and approved procedures |
What the PSCO Checks
Operational Tips
- Map physical accessibility, assistance under Regulation 1177/2010 and EAA-covered digital elements separately.
- For the EAA, verify scope, exceptions and transitions; self-service information terminals integrated into ships are excluded.
- Integrate PRM needs into emergency procedures and train personnel.
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.
- Applicable physical requirements checked and MSC/Circ.735 recommendations considered under relevant implementation
- Assistance to passengers with disabilities or reduced mobility provided per EU Regulation 1177/2010
- EAA elements checked against scope, national measures, applicable exemptions and transitions
- PRM assistance needs integrated into the muster plan and emergency procedures
- Onboard and terminal staff trained on practical assistance to PRM passengers
FAQ
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Last substantive revision of this page: 16 September 2026 · page fingerprint 2892a72e54a4