Coordination between Flag State and PSC
A.1206(34), adopted on 3 December 2025, adds Appendix 20 on security and coordination with the existing DAO function under SOLAS XI-2/9; it neither creates the DAO nor has a convention-style entry-into-force date.
Operational Explanation
The Duly Authorized Officer function comes from SOLAS XI-2/9 and was addressed by earlier guidance. A.1206(34) adds Appendix 20, updates PSCO guidance on security aspects and governs coordination with the existing DAO.
Regulatory Reference
A.1206(34), adopted on 3 December 2025, adopts the 2025 PSC Procedures, invites Governments to implement them and revokes A.1185(33). It is not a Convention amendment entering into force on 1 January 2026. SOLAS XI-2/9 is the basis of the DAO function.
General coordination: share the PSC report, findings, deadlines and rectification plan with Company, flag and RO under their respective duties. Separate PSC authority notifications from ship communications. The flag retains its responsibilities and the RO acts within its authorization; a technical report or certificate does not replace port-State release. IMO A.1206(34).
Security: distinguish the RO from a Recognized Security Organization (RSO), authorized for relevant ISPS activities. Appendix 20 concerns SOLAS XI-2/ISPS ships in the ship/port interface; do not extend it to every ship or every PSC finding.
Appendix 20 §5.2 covers the security level, ISSC/interim ISSC, SSO identification and proficiency certificate, and drill/exercise evidence. The PSCO is not tasked with testing the security system; §5.5 aspects are not an automatic checklist and an individual anomaly does not always demonstrate a violation.
Scope of Application
Every ship and Company subject to PSC inspections, with the Company responsible for maintaining an effective communication channel with the flag Administration and the RO, especially in the event of a deficiency or detention.
Procedure / How to Complete It
- Establish whether the PSCO is also a DAO.
- If not, after clear grounds are established inform and coordinate with the DAO under Appendix 20.
- Keep Convention powers and procedural guidance distinct.
- Engage flag and RO within permitted roles without transferring the port-State decision.
Practical Example
Example: after detention, the Company involves the flag and authorized RO to define repairs and evidence, and agrees required verification with the port State. Any reconsideration request is distinct from rectification and does not itself suspend detention.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Saying A.1206(34) introduced the DAO | The function’s origin and powers are assigned to the wrong source | Refer the DAO to SOLAS XI-2/9 and Appendix 20 to coordination procedure |
| Treating a security clear ground as automatic detention | Assessment and proportionality of measures disappear | Record the clear ground, inform the DAO where required and await determination of the appropriate measure |
What the PSCO Checks
Operational Tips
- Check security documents and familiarisation under the applicable regime.
- Treat absence or invalidity of the SSO certificate as a clear ground for assessment without promising an automatic outcome.
- Maintain current channels with flag and RO in their respective roles.
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.
- Communication channel with the flag Administration and RO kept active and up to date
- Deficiencies and detentions notified promptly to the competent authorities
- Validity of the SSO certificate systematically checked before security inspections
- PSCO/DAO roles and security documents checked within scope, without treating guidance as an additional certification
- Structured periodic dialogue with the flag Administration maintained, not only reactive
FAQ
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Last substantive revision of this page: 15 September 2026 · page fingerprint 82a0d9e3e218