Guidance

MGN 702 Amendment 1 (M) Maritime autonomous surface ships (MASS) of less than 2.5 metres in length overall

Published 19 March 2025

Summary

This Marine Guidance Notice (MGN) explains a General Exemption which has been issued for Maritime Autonomous Surface Ships of <2.5 metres in length overall.

This General Exemption enables eligible vessels to operate without certification issued by the Maritime and Coastguard Agency (MCA), or its delegates.

This General Exemption does not exempt eligible vessels from all merchant shipping regulations or other maritime requirements.

For the General Exemption for the vessel to be valid all applicable conditions of this General Exemption are required to be met.

Failure to maintain compliance with the conditions set out in herein will invalidate any exemption and the vessel will be expected to fully comply with all the applicable regulations.

This General Exemption is effective from 05 August 2024.

1. Introduction

1.1 Maritime Autonomous Surface Ships (MASS) include every description of vessel or craft used in navigation that can for any part of its voyage, fully or in part navigate or operate autonomously or through remote operations.

1.2 Remotely Operated Unmanned Vessel (ROUV) means a vessel with no persons on board, that is operated from a location remote to the vessel.

 2. Background

2.1 To date, there have been two pathways to certification available for MASS:

    2.1.1 MASS may undertake a case-by-case assessment through application of the MGN 664 process and, if successful, may be issued with a load-line exemption certificate; or

    2.1.2 ROUVs of <24 metres in load-line length may be surveyed and issued with a Workboat Code Edition 3 certificate.

2.2 To provide specific support to the MiniMASS sector the Maritime and Coastguard Agency have issued a General Exemption for MASS of <2.5 metres in length overall, which ensures that eligible vessels have an available proportional pathway.

2.3 Owners or operators of MASS of <2.5 metres in length overall may alternatively still choose to follow either of the pathways set out in 2.1.

2.4 This General Exemption is effective from 05 August 2024.

3. General Exemption for MASS <2.5 metres in Length Overall

3.1 This General Exemption only applies to MASS of <2.5 metres in length overall which comply with all of the conditions set out within the General Exemption.

3.2 There may be other Regulations which apply to a specific vessel. The owner/operator of a vessel has a responsibility to identify which Regulations apply to a specific vessel and its intended operations.

3.3 The Maritime and Coastguard Agency has made the assumption that MASS of <2.5 metres in length overall will not carry EPIRBs.

If the owner/operator of a vessel to which this General Exemption applies chooses to carry EPIRBs they shall comply with The Merchant Shipping (EPIRB Registration) Regulations 2000 (SI 2000/1850).

3.4 The Maritime and Coastguard Agency has made the assumption that MASS of <2.5 metres in length overall will not be designed or constructed to carry ballast water.

A MASS of <2.5 metres in length overall which is designed or constructed to carry ballast water shall comply with The Merchant Shipping (Control and Management of Ships’ Ballast Water and Sediments) Regulations 2022 (SI 2022/737).

3.5  The Maritime and Coastguard Agency recommends that the operator of a MASS of <2.5 metres in length overall implements appropriate means to enhance the visibility and detectability of the vessel by other water users.

3.6 All MASS of <2.5 metres in length overall should consider fitting, where practicable, the most effective and appropriate radar reflector or radar target enhancer for their circumstances; and ensure those comply with international standards (see MGN 349, as amended).

3.7 The General Exemption will be reviewed alongside the Post-Implementation Review (PIR) of Workboat Code Edition 3.

3.8  The Maritime and Coastguard Agency retains the right to retract this General Exemption at any time.

 4. Further Information

4.1 Further information relating to Workboat Code Edition 3 can be obtained from the links listed below:

    4.1.1 Workboat Code Edition 3 can be accessed at: https://www.gov.uk/government/publications/the-workboat-code-edition-3.

    4.1.2 The Merchant Shipping (Small Workboats and Pilot Boats) Regulations 2023 can be accessed at: https://www.legislation.gov.uk/uksi/2023/1216/contents/made.

4.2 Further information relating to MGN 664 can be obtained from the link listed below:

    4.2.1 MGN 664 (Amendment 1) Certification Process for Vessels using Innovative Technology https://www.gov.uk/government/publications/mgn-664-mf-amendment-1-certification-process-for-vessels-using-innovative-technology

More Information

Code Vessel Team, UK Technical Services Ship Standards
Maritime and Coastguard Agency
Bay 2/23
Spring Place
105 Commercial Road
Southampton
SO15 1EG

Telephone: +44 (0)203 817 2000

Email: codes@mcga.gov.uk

Website: www.gov.uk/mca

GENERAL EXEMPTION

The Secretary of State, in exercise of their powers conferred by Section 294(1) of the Merchant Shipping Act 1995 hereby exempts:

Maritime Autonomous Surface Ships (MASS) of less than 2.5 metres in length overall

from the following requirements (to the extent that they apply):

• Regulations 19.2.1.4 and 19.2.1.5 of Chapter V of the International Convention for the Safety of Life at Sea (SOLAS), 1974^{[footnote 1]}

• The Merchant Shipping (Standards of Training, Certification and Watchkeeping) Regulations 2022 (SI 2022 No. 1342)^{[footnote 2]}

• The Merchant Shipping (Life-Saving Appliances and Arrangements) Regulations 2020 (SI 2020 No. 501)^{[footnote 3]}

• The Merchant Shipping (Survey and Certification) Regulations 2015 (SI 2015 No. 508)^{[footnote 4]}

• The Merchant Shipping (Musters, Training and Decision Support Systems) Regulations 1999 (SI 1999 No. 2722)^{[footnote 5]}

• The Merchant Shipping (Carriage of Cargoes) Regulations 1999 (SI 1999 No. 336)^{[footnote 6]}

• The Merchant Shipping (Load Line) Regulations 1998 (SI 1998 No. 2241)^{[footnote 7]}

• The Merchant Shipping (Fire Protection: Small Ships) Regulations 1998 (SI 1998 No. 1011)^{[footnote 8]}

The vessel must comply with all other applicable Regulations (to the extent that they apply), including those set out in the:

• Convention on the International Regulations for Preventing Collisions at Sea 1972, as amended (COLREGS);

• The International Convention for the Safety of Life at Sea (SOLAS), 1974;

• The International Convention for the Prevention of Pollution from Ships 1973, as modified by the Protocol of 1978 relating thereto, as amended (MARPOL);

• The Merchant Shipping (Safety of Navigation) Regulations 2020 (SI 2020 No. 673);

• The Merchant Shipping (Prevention of Pollution by Garbage from Ships) Regulations 2020 (SI 2020 No. 621);

• The Merchant Shipping (Prevention of Oil Pollution) Regulations 2019 (SI 2019 No. 42);

• The Merchant Shipping (Marine Equipment) Regulations 2016 (SI 2016 No. 1025);

• The Merchant Shipping (Accident Reporting and Investigation) Regulations 2012 (SI 2012 No. 1743);

• The Merchant Shipping (Prevention of Air Pollution from Ships) Regulations 2008 (SI 2008 No. 2924);

• The Merchant Shipping (Distress Messages) Regulations 1998 (SI 1998 No. 1691);

• The Merchant Shipping (Tonnage) Regulations 1997 (SI 1997 No. 1510); and

• The Merchant Shipping (Distress Signals and Prevention of Collisions) Regulations 1996 (SI 1996 No. 75).

This exemption is subject to the following conditions:

(a) The vessel is a MASS^{[footnote 9]} of less than 2.5m in length overall;

(b) The vessel is a British ship^{[footnote 10]} wherever they may be, or a non-British ship operating from United Kingdom ports whilst in United Kingdom waters;

(c) The vessel is unmanned (i.e. operates with no persons onboard);

(d) The vessel is not permitted to carry any dangerous goods^{[footnote 11]};

(e) The vessel is not permitted to tow another vessel or object;

(f) The vessel is not permitted to be fitted with a lifting device^{[footnote 12]};

(g) The vessel is not permitted to have an engine which can only be hand started;

(h) The vessel is not permitted to have open flame appliances or gas installations;

(i) The vessel is not permitted to have liquid fuelled cookers or heating appliances installed;

(j) The vessel is not permitted to be fitted with a diver lift or be used as a diving platform;

(k) The vessel is not permitted to operate as a mother vessel^{[footnote 13]};

(l) The vessel is not in commercial use for sport or pleasure;

(m) The vessel is not a pleasure vessel;

(n) The vessel does not have an anti-fouling system applied which contains Cybutryne or an organic compound which acts as a biocide;

(o) The vessel has a continuously available communications system(s) operated from or installed at the control position providing the following capabilities for the area in which the vessel is operating, not the location of the control position:

a. Transmitting ship-to-shore distress alerts, consideration should be given to having two separate and independent means, each using a different radiocommunication service;

b. Receiving shore-to-ship distress alert relays;

c. Transmitting and receiving ship-to-ship distress alerts;

d. Transmitting and receiving on-scene communications including search and rescue co-ordinating communications;

e. Transmitting and receiving signals for locating;

f. Receiving Maritime Safety Information^{[footnote 14]}

g. Transmitting and receiving urgency and safety communications; and

h. Transmitting and receiving bridge-to-bridge communications;

(p) The vessel owner should ensure that Remote Operator(s)^{[footnote 15]} are suitably trained to safely operate the vessel;

(q) The following is kept at the control position:

a. Nautical charts and nautical publications to plan and display the ship’s route for the intended voyage and to plot and monitor positions throughout the voyage; and

b. Back-up arrangements to meet the requirements of (a), if this function is partly or fully fulfilled by electronic means; and

(r) The following information is emailed to codes@mcga.gov.uk:

a. Name and address of vessel owner;

b. Name and address of vessel operator (if different);

c. Vessel name;

d. Vessel length overall;

e. Vessel’s maximum speed; and

f. Date of build.

A vessel to which this exemption applies operating in non-United Kingdom waters must comply with any provisions required by Maritime Administration(s) of the waters in which they are operating.

This exemption shall have immediate effect for vessels which meet conditions (a) to (r) and remain effective to the extent that:

    (1) Conditions (a) to (r) continue to be met; and

    (2) Each and any of the regulations listed above remain in force, or the exemption is amended or revoked.

This exemption shall remain in force until 31 December 2028, unless cancelled or modified by the Maritime and Coastguard Agency.

1. In exercise of the power conferred by Regulation 6(1)(a) of The Merchant Shipping (Safety of Navigation) Regulations 2020 (SI 2020 No. 673); only applies to ships which do not undertake an international voyage. International voyage means a voyage from a country to which SOLAS Chapter V applies to a port outside such country, or conversely ↩

2. In exercise of the power conferred by Regulation 59(1) of the Merchant Shipping (Standards of Training, Certification and Watchkeeping) Regulations 2022 (SI 2022 No. 1342) ↩

3. In exercise of the power conferred by Regulation 8(1),(2) of the Merchant Shipping (Life-Saving Appliances and Arrangements) Regulations 2020 (SI 2020 No. 501) ↩

4. In exercise of the power conferred by Regulation 5(3) of the Merchant Shipping (Survey and Certification) Regulations 2015 (SI 2015 No. 508) ↩

5. In exercise of the power conferred by Regulation 14(1) of the Merchant Shipping (Musters, Training and Decision Support Systems) Regulations 1999 (SI 1999 No. 2722) ↩

6. In exercise of the power conferred by Regulation 15(3) of the Merchant Shipping (Carriage of Cargoes) Regulations 1999 (SI 1999 No. 336) ↩

7. In exercise of the power conferred by Regulation 5(1),(2) of the Merchant Shipping (Load Line) 1998 (SI 1998 No. 2241) ↩

8. In exercise of the power conferred by Regulation 47 of the Merchant Shipping (Fire Protection: Small Ships) Regulations 1998 (SI 1998 No. 1011) ↩

9. “MASS” means Maritime Autonomous Surface Ship and includes every description of vessel or craft used in navigation that can for any part of its voyage, fully or in part navigate or operate autonomously or through remote operations ↩

10. The definition of “ship” provided in Section 313 of the Merchant Shipping Act 1995 is – “ship” includes every description of vessel used in navigation ↩

11. “Dangerous goods” means cargoes classified in the International Maritime Dangerous Goods (IMDG) Code which is given force of law through the Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997 (SI 1997 No. 2367), as amended. “Cargo” means all items which are transported by the vessel except: fuel for the vessel; ballast (either solid or liquid); permanent outfit and equipment of the vessel and; ships stores for the vessel ↩

12. “Lifting device” means a device used for lifting or lowering loads, and includes its attachments used for anchoring, fixing, supporting the device and connections between device and load ↩

13. A mother vessel is a vessel which leads, serves, or carries tenders, and may provide a safe haven for a tender ↩

14. Maritime Safety Information should be received in accordance with MSC.1/Circ.1645 ↩

15. “Remote Operator” means any person, including the Master, who is engaged in the remote operation of a MASS ↩