Document of Compliance (DOC) and Safety Management Certificate (SMC)
The two certificates that make ISM compliance tangible: what they attest, who issues them, when they must be renewed, and what happens if they expire or are suspended.
Operational Explanation
The Document of Compliance (DOC) is issued to the Company and attests that its Safety Management System has been verified as compliant with the ISM Code; it is a necessary condition for the Company to manage ships subject to the ISM Annex. The Safety Management Certificate (SMC) is issued to each ship and attests that it operates in compliance with the approved SMS of the Company holding the DOC.
The two certificates are linked but distinct: a ship cannot hold a valid SMC if the Company managing it does not have a valid DOC for that ship type.
Regulatory Reference
ISM Code, par. 13 (Certification, Verification and Control) and SOLAS Chapter IX: the DOC is issued by the flag Administration (or a recognized organization) to the Company after an external audit; the SMC is issued to the individual ship after verification of compliance with the Company's SMS.
The two certificates are not on the same verification regime, and conflating them is the costliest error on this page. The DOC is subject to annual verification (§13.4): “The validity of a Document of Compliance should be subject to annual verification … within three months before or after the anniversary date”. The SMC is subject to at least one intermediate verification (§13.8): “If only one intermediate verification is to be carried out and the period of validity of the Safety Management Certificate is five years, it should take place between the second and third anniversary date”. An annual cadence with a ±3-month window on one side; a single appointment inside a continuous twelve-month interval on the other.
The consequence that makes the distinction operational. §13.5 provides that the DOC be withdrawn when the annual verification “is not requested” or where there is evidence of major non-conformities. And §13.5.1 adds the part most people have not read: “All associated Safety Management Certificates and/or Interim Safety Management Certificates should also be withdrawn if the Document of Compliance is withdrawn”. An annual DOC verification not requested in the office brings down the SMCs of every ship in the Company, each of which was perfectly in order. §13.9 is the mirror provision, and concerns the SMC alone: withdrawal if the §13.8 intermediate verification is not requested.
Scope of Application
Every Company and every ship subject to SOLAS Chapter IX, which distinguishes the categories instead of flattening them: passenger ships, including passenger high-speed craft; oil tankers, chemical tankers, gas carriers, bulk carriers and cargo high-speed craft of 500 gross tonnage and above; other cargo ships and mobile offshore drilling units (MODUs) of 500 gross tonnage and above. Government-operated ships used only on non-commercial service fall outside the chapter. Extensions are possible under flag State regulations.
Procedure / How to Complete It
- Verify the validity and expiry dates of the DOC (Company) and SMC (ship), and track their periodical verifications on two different schedules: for the DOC one verification every year, within the ±3-month window around the anniversary date; for the SMC a single intermediate verification, to be placed between the second and third anniversary date.
- Schedule the external renewal audit with sufficient lead time, including a review of internal audit results and the Management Review.
- Prepare documentary evidence: the NC/CAPA register, Management Review minutes, the internal audit programme, crew training.
- Address any NCs identified during the external audit with prompt CAPAs, to avoid suspension of the certificate.
- Keep on board the required copy of the Company DOC and the ship's valid SMC, including applicable endorsements: §13.6 of the Code — introduced by res. MSC.104(73) — requires a copy of the DOC to be placed on board so that the Master can produce it, and states that the copy need not be authenticated or certified, whereas the SMC is the certificate issued to the ship and is carried as such (or the corresponding Interim certificate, if applicable). Where the Administration accepts electronic statutory certificates, its own regime applies.
Practical Example
The DOC is not “subject to an intermediate audit between the second and third year”: that window belongs to the SMC alone.
Example schedule, for a DOC and an SMC issued on the same day with five-year validity. DOC: annual verification four times, once around each of the first four anniversary dates, each time within a six-month window (three before and three after); renewal by the fifth anniversary. SMC: one intermediate verification, to be placed anywhere in the twelve months between the second and the third anniversary date; renewal by the fifth anniversary. Four appointments on one side, one on the other: they are two different rows of the survey calendar, not one row with two names.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| DOC and SMC periodical verifications treated as if they had the same cadence, applying the SMC's intermediate window to the DOC | The Code does not say the certificate lapses by itself: §13.5 provides for withdrawal of the DOC when the annual verification is not requested, §13.9 for withdrawal of the SMC when the intermediate one is not. Both omissions are detainable deficiencies (A.1206(34), App. 2, §5 “Areas under the ISM Code”): item .8 “Evidence of the DOC annual verification is not available on board” and item .4 “The SMC intermediate verification is overdue” | Keep two distinct rows in the survey calendar: four annual windows for the DOC, one intermediate window for the SMC |
| On-board copy of the DOC/SMC not updated after a renewal | PSC deficiency for inconsistent documentation | Verify that the on-board copy is always the latest valid version, replaced immediately after every renewal |
| Major NCs identified in an external audit not addressed within the required timeframe | Risk of certificate suspension | Treat NCs from external audits with the highest priority and verify CAPAs quickly |
What the PSCO Checks
Operational Tips
- Include the DOC and SMC periodical verifications in the same calendar used for statutory certificates, not in a separate register — but on two distinct rows: the DOC has four annual appointments, the SMC one.
- The DOC annual verification happens in the office, and its omission is invisible on board until the PSCO arrives: item .8 of Appendix 2 requires that evidence of the DOC annual verification be available on board. A Company in order with an out-of-date copy on the ship still produces the deficiency.
- Update the on-board copy of the DOC/SMC immediately after every renewal or external audit.
- Give absolute priority to CAPAs linked to NCs identified during an external certification audit.
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.
- Company DOC valid and consistent with the ship types managed
- Ship SMC valid, with an up-to-date copy on board
- DOC: annual verification scheduled within the ±3-month window around the anniversary date, and evidence of the latest annual verification present on board
- SMC: the single intermediate verification scheduled between the second and third anniversary date
- NCs from the external audit addressed with prompt CAPAs
- Interim DOC/SMC (if applicable) managed under the flag procedure
FAQ
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Last substantive revision of this page: 29 August 2026 · page fingerprint 29976b1edcd0