The IMO Adopts the First Global Code for Autonomous Ships
DANA S. MERKEL Partner
ALAN M. WEIGEL Of Counsel
VANESSA C. DIDOMENICO Associate
The International Maritime Organization(“ IMO”) formally adopted the International Code of Safety for Maritime Autonomous Surface Ships(“ MASS Code” or the“ Code”) on May 22, 2026, marking a significant regulatory milestone for autonomous shipping. Adopted at the conclusion of the 111th session of the Maritime Safety Committee( MSC 111), the Code establishes a goalbased framework to govern the design and operation of remotely controlled and fully autonomous commercial vessels. The Code took effect on July 1, 2026.
The U. S. Coast Guard(“ USCG”) also released guidance with respect to remotely controlled and autonomous vessels recently. Issued in the form of a Work Instruction, the policy provides guidance to USCG units and industry on approval and oversight of unmanned vessels.
An International Framework Built on Safety, Security, and Environmental Protection The MASS Code sets out to ensure that remotely operated and autonomous vessels meet the same standards of safety, security, and environmental protection expected of conventional vessels. Ships falling under the Code must also comply with the International Convention for the Safety of Life at Sea(“ SOLAS”) and other applicable mandatory IMO instruments. In its current form, the Code applies exclusively to cargo ships and, at this stage, is non-mandatory, giving IMO Member States the opportunity to test its application while laying the groundwork for a future binding instrument.
The Code introduces new requirements across several critical domains, including navigation, connectivity, remote operations, fire safety, and search and rescue. It places strong emphasis on risk assessment, robust system design, cybersecurity, and the integration of Remote Operations Centers(“ ROCs”), the landbased facilities from which some or all operational aspects of a MASS may be managed. Importantly, the Code is designed as a goal-based, technology-neutral instrument, meaning it complements existing IMO instruments and focuses on areas not adequately addressed by the current regulatory framework, without prescribing specific technologies.
One of the Code’ s most significant provisions is its treatment of the human element. The MASS Code requires that a human master remain responsible for the ship at all times. While the master may not always be physically on board, depending on the technology employed and the degree of autonomy, that individual must retain the ability to intervene when necessary. This principle ensures that human oversight remains a cornerstone of autonomous shipping, even as the industry moves toward higher levels of automation.
Although the adoption of the non-mandatory MASS Code is a notable achievement, it is deliberately the first step in a phased approach. According to the roadmap agreed upon at MSC 109, the IMO will develop a framework for an Experience-Building Phase(“ EBP”) following the
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