The 12th Session of the Sub-Committee on Implementation of IMO Instruments (III 12) was held from 20 to 24 July 2026 at the IMO Headquarters in London.The highlights of the meetings are as follows:

1. Draft amendments to the Procedures for Port State Control, 2025.
III 12 continued its work on the draft amendments to the Procedures for Port State Control, 2025 (resolution A.1206(34)). The proposed amendments include new guidance for Port State Control Officers (PSCOs) on inspections relating to machinery and maintenance, as well as revised qualification requirements for PSCOs. The amendments are expected to enter into effect on 1 January 2028.
Although the Procedures for Port State Control, 2025 are non-mandatory, they are widely implemented and referenced by regional Port State Control (PSC) regimes, including the Paris Memorandum of Understanding (Paris MoU) and the Tokyo Memorandum of Understanding (Tokyo MoU), and are generally regarded as the global benchmark for PSC inspections. The Procedures are normally revised every two years to reflect amendments to IMO instruments and developments in inspection practices. 

2. Draft amendments to the Survey Guidelines under the Harmonized System of Survey and Certification (HSSC), 2025.
III 12 continued its work on the draft amendments to the Survey Guidelines under the Harmonized System of Survey and Certification (HSSC), 2025 (resolution A.1207(34)). Work has also commenced on the new Survey Guidelines under the HSSC, 2027, including updates to reflect new IMO requirements, incorporation of forthcoming requirements relating to pilot transfer arrangements, and the introduction of a coding system for remote surveys. The revision work will continue intersessionally and is expected to be finalized at III 13, with adoption anticipated at the thirty-fifth session of the IMO Assembly (A 35) in December 2027. The revised Guidelines are expected to take effect on 1 January 2028.
The Survey Guidelines under the Harmonized System of Survey and Certification (HSSC) are reviewed and updated regularly to incorporate new regulatory requirements. Although IMO does not designate the Guidelines as mandatory, under Regulation (EC) No 391/2009 of the European Parliament and of the Council, they are mandatory for all EU-recognized organizations (Recognized Organizations, ROs), which include most members of the International Association of Classification Societies (IACS). 

3. Revision of MSC/Circ. 1140-MEPC/Circ. 424 on the Transfer of Ships between States.
The draft amendments to MSC/Circ.1140-MEPC/Circ.424, Transfer of Ships between States, were finalized. The amendments introduce a notification mechanism for ships that have been deleted from a register but have not yet acquired a new flag State. They are expected to be approved by MSC 112 and MEPC 85 by the end of 2026. The purpose is to strengthen information-sharing through IMO and enhance Member States’ awareness of ships that may be temporarily operating without a flag.
The draft amendments will be submitted to MSC 112 and MEPC 85, to be held from November to December 2026, for approval. At that stage, the Committees may also consider whether related legal issues should be referred to the IMO Legal Committee (LEG). 
The Sub-Committee also noted that stateless or abandoned ships may pose risks relating to safety, environmental protection and seafarers’ welfare, as well as broader legal issues concerning the responsibilities of former flag States and the jurisdiction of port States. These matters have been referred to LEG for further consideration.

4. Comprehensive revision of the Guidelines on the implementation of the International Safety Management (ISM) Code by Administrations and companies. 
A study concluded that the International Safety Management Code (ISM Code) remains generally fit for purpose, although there is scope to improve its implementation. IMO had previously agreed to undertake a comprehensive revision of the guidelines for implementing the ISM Code, including resolution A.1188(33), which applies to Administrations, and MSC-MEPC.7/Circ. 8, which applies to companies.
IMO will therefore proceed with a comprehensive revision of the guidelines for implementation of the ISM Code by Administrations and companies, with the work targeted for completion in 2028.
At III 12, several proposals to modernize the implementation guidelines were considered. Key issues included digitalization, remote audits, oversight arrangements, and changes in company organizational structures, with the objective of ensuring the effective and consistent implementation of safety management across the shipping industry. The main outcomes included: 
(1) Identification of issues requiring further consideration during the comprehensive review, which may lead to amendments to the guidelines for implementation of the ISM Code by Administrations and companies;
(2) Establishment of a correspondence group, which will report to III 13; and
(3) Agreement to develop a roadmap for preparing draft amendments for consideration by III 14. 
Owing to time constraints during the session, the work could not be completed. Further work will therefore continue intersessionally. The correspondence group will report to III 13, and the draft amendments are expected to be submitted to III 14 for consideration.

5. Review of the Casualty Investigation Code and its related implementation guidelines. 
IMO has initiated a review of the Code of the International Standards and Recommended Practices for a Safety Investigation into a Marine Casualty or Marine Incident (resolution MSC.255(84)) and the Guidelines to assist investigators in the implementation of the Casualty Investigation Code (resolution A.1075(28)), with a target completion year of 2028. The review is primarily driven by concerns regarding the quality, consistency, and timeliness of marine casualty investigations and investigation reports.
To address these issues, draft amendments to resolutions MSC.255(84) and A.1075(28) have been developed. However, due to time constraints during the session, the work could not be completed. Further work will therefore continue intersessionally, with finalization expected at III 13, scheduled for July 2027.

6. Safety inspection of small fishing vessels. 
The Sub-Committee reviewed and finalized the draft guidelines on seaworthiness and safety inspections for small fishing vessels, together with the related inspection checklist. An expert group was established during the session to review and complete the guidelines. The guidelines are intended to enhance safety at sea while also facilitating access to insurance services for small fishing vessels, particularly those operating in developing countries.
III 12 agreed to the draft guidelines on seaworthiness and safety inspections for small fishing vessels, as well as the draft safety inspection checklist for small fishing vessels, with a view to submitting them to MSC 112 for approval. The documents are subsequently expected to be circulated as a joint publication of the Food and Agriculture Organization of the United Nations (FAO) and IMO.

References:
1. American Bureau of Shipping (ABS), News Brief: III 12. https://www.linkedin.com/posts/american-bureau-of-shipping_abs-iii-12-brief-activity-7486500199595528192-2u1d   
2. Bureau Veritas (BV), Implementation of IMO Instruments Sub-Committee 12th Session (III 12) Summary Report. https://marine-offshore.bureauveritas.com/newsroom/12th-session-implementation-imo-instruments-sub-committee-iii-12  
3. Det Norske Veritas (DNV), IMO III 12: Initiation of ISM Implementation Guidelines Revision and Progression of Survey Requirements Revision. https://www.dnv.com/news/2026/imo-iii-12-initiation-of-ism-implementation-guidelines-revision-and-progression-of-survey-requirements-revision/  
4. InterManager, Summary report on IMO Sub-Committee on Implementation of IMO Instruments 12th session (III 12). https://intermanager.org/imo-sub-committee-meeting-iii-12-20-24-july-2026/   
5. IMO, Sub-Committee on Implementation of IMO Instruments (III 12), 20 to 24 July 2026. https://www.imo.org/en/mediacentre/meetingsummaries/pages/iii-12-meeting-summary.aspx   
6. Lloyd’s Register (LR), III 12 Summary Report. https://maritime.lr.org/III-12-Summary-Report  
7. Safety4Sea, IMO III 12: Key outcomes. https://safety4sea.com/imo-iii-12-key-outcomes/