Briefing Note for the Global SAR community on the IMO MSC 111 Adoption of the Maritime Autonomous Surface Ship (MASS) Code and considerations for the maritime SAR community

This briefing is to explain the recent development at the IMO on the Maritime Autonomous Surface Ship (MASS) Non-Mandatory Code.

The IMO has been working for many years on creating a code of practice which will eventually lead to regulations governing the design, building and operation of remotely operated and autonomous ships.

At the IMO Maritime Safety Committee (MSC) 111^th meeting, held from 13 to 22 May 2026 and attended by the IMRF, member States agreed to adopt the first phase of this process through the creation of a non-mandatory MASS Code. This initial period is intended to allow industry to gain operational experience with MASS technology and operations.

Experience Building Phase (2026 to 2032)

The initial implementation period will be known as the Experience Building Phase (EBP) and is currently planned to run from 2026 to 2032. During the EBP, information and data relating to MASS will be gathered and submitted to IMO by MASS owners and operators. This data will then be analysed by various IMO technical working groups. Based on this experience, the MASS Code will be revised and finalised as a mandatory international regulatory instrument.

The IMRF role and engagement

The IMRF, representing the interests of the global maritime SAR community, has played an active role throughout the development of the MASS Code, particularly regarding maritime search and rescue (SAR) obligations and operational requirements.

The IMRF participated in MSC 111 and has consistently engaged with IMO working groups to ensure that MASS are not exempted or allowed to diverge from existing SAR responsibilities under international law. The IMRF submitted a paper to MSC 110 on the importance of SAR requirements for MASS and intervened firmly during discussions of the SAR chapter during that meeting to ensure that the longstanding obligations under SOLAS and international SAR conventions remain fully applicable to MASS.

The IMRF will continue representing the maritime SAR community through ongoing engagement with IMO committees, the Navigation, Communications and Search and Rescue (NCSR) Sub-Committee, and the ICAO–IMO Joint Working Group on SAR.

Maritime SAR requirements in the MASS Code

The IMRF is primarily concerned with the maritime SAR obligations and requirements placed on MASS. This is contained in Chapter 21 of the non-mandatory MASS Code. The chapter is very short and, like the rest of the code, simply outlines the Functional Requirements and Expected Performance to achieve what the code requires.

Maritime SAR Chapter of IMO Non-Mandatory MASS Code

CHAPTER 21 – SEARCH AND RESCUE

21.1 Goal

The goal of this chapter is to ensure that the duties and tasks regarding search and rescue are fulfilled. 

21.2 Functional requirements

21.2.1 To achieve the above-mentioned goal, the master should comply with all relevant requirements in SOLAS for providing assistance to persons in distress, and as provided in the functional requirements of this chapter and applicable international law.

21.2.2 A MASS and its associated Remote Operations Centre(s) (ROC(s)) should be provided with a ship-specific plan and procedures which enable the master to provide assistance to persons in distress when obligated to do so.

21.2.3 Rescue equipment provided on board should be able to be safely used independently of the presence of crew^{. 10}

21.2.4 Persons retrieved on board should be able to be safely accommodated until such time as they can be delivered to a place of safety.

EP 1 Persons retrieved on board should be provided with information and arrangements to communicate with a ROC. 

EP 2 Persons retrieved on board should be provided with access to any arrangements provided for their safety.

Footnote: 10. According to SOLAS regulation III/I7-1 and the Guidelines for the development of plans and procedures for the recovery of persons from the water (MSC.1/Circ.1447), the Guide to recovery techniques (MSC.1/Circ.1182) and the Guide for cold water survival (MSC.1/Circ.1185/Rev.1).

Goal-based requirements and remaining challenges

The SAR chapter is concise because the purpose of the various IMO MASS Working Groups is to develop Goal-Based Requirements (GBR) for MASS. In other words, the Code specifies what a MASS must be capable of achieving, rather than prescribing detailed technical solutions for how these outcomes must be delivered.

The practical and technical implications will therefore be left largely to designers and builders.  However, the IMRF has considerable concerns that the general nature of GBRs leaves many important technical questions unanswered regarding how MASS will safely and effectively conduct rescue operations involving persons in distress.

Survivor recovery and accommodation concerns

There are also questions about whether, how, and where a MASS will accommodate rescued survivors.  Without this information, the IMRF believes that designers may face uncertainty regarding how much space and equipment is required to support rescued persons safely.

Conventional ships do not have this requirement imposed on them because they already have spaces on board for human crew habitation, and these can be repurposed for use for survivors when needed.

Human factors and technical complexity

The technical challenges of replicating human functions for rescuing people at sea pose significant engineering and operational challenges.

The IMRF will continue to provide its members' views on this through our engagement with the relevant working groups and committees as the development and deployment of MASS proceed.

Future IMO and SAR discussions

The detailed implementation of Chapter 21 on how MASS can achieve the requirements will be debated and worked out in future working groups at the IMO.

In the first instance, this discussion will be passed to the Navigation, Communications and SAR (NCSR) Subcommittee, which next meets in June 2026. The IMRF regularly participates in this forum. This meeting may then also pass the detailed technical discussions on to the ICAO-IMO SAR Joint Working Group, where the IMRF also participates as an observer and where many detailed IMO SAR challenges have been and are discussed.

Operational coordination between MASS and SAR units

Another key area of concern for the IMRF is how SAR units will be able to safely and efficiently work with MASS that are remotely controlled from shore-based Remote Operations Centres (ROCs).

These ROCs will effectively perform the functions traditionally undertaken by  ‘bridge and engineering’ crew onboard conventional vessels. Because MASS will rely heavily on satellite connectivity, and this may bring latency challenges, there might be delays during the sending of commands to and from the ship. This could potentially result in slower responses of the MASS at sea to requests made by SAR units working with them. Therefore, SAR units may need to develop safety and operational procedures and protocols to enable effective and safe joint operations.

Potential benefits of MASS for SAR

MASS may also bring considerable benefits to SAR. For example, MASS are likely to be fitted with various visual and electronic detection sensors  to operate safely at sea and prevent collisions. This means that they may be more effective at detecting objects , which may include persons in the water, potentially making MASS valuable assets during SAR operations.

Further work will need to be done to ensure that MASS can meet their responsibilities under SOLAS and UNLCOS.  The IMRF will remain actively involved throughout this process, representing our maritime SAR community members, and the wider global SAR system.

The full report to IMO MSC 111, of the IMO MASS Working Group, can be found here.