Persons with Reduced Mobility: Accessibility on Board
Physical accessibility, assistance rights and digital services follow different instruments: MSC/Circ.735 is guidance, EU Regulation 1177/2010 governs assistance and non-discrimination, and the EAA only specified service elements.
Operational Explanation
Keep three instruments separate. MSC/Circ.735 provides design and operational guidance unless made binding. Regulation (EU) 1177/2010 governs non-discrimination, access conditions and assistance within its scope. Directive (EU) 2019/882 concerns specified digital and ticketing elements of waterborne passenger transport services.
Regulatory Reference
MSC/Circ.735: IMO guidance. Regulation (EU) 1177/2010: rights and assistance with its own exclusions. Directive (EU) 2019/882, arts. 2 and 4: websites, apps, e-tickets, information and certain terminals; it excludes self-service information terminals integrated into ships and contains further exceptions.
Scope of Application
Determine each instrument's scope and exceptions separately. The EAA does not by itself make onboard cabins, routes or emergency stations mandatory from 2025 and does not cover information terminals integrated into the ship.
Procedure / How to Complete It
- Apply or consider MSC/Circ.735 as guidance unless implemented.
- Check rights and assistance under Regulation 1177/2010.
- Map only listed EAA elements and exceptions.
- Do not merge physical design, assistance and digital accessibility into one claim.
Practical Example
Example: a shipping company operating routes within the European Union updates, by the 28 June 2025 deadline, its electronic ticketing system and real-time travel information to make them compliant with the European Accessibility Act's digital accessibility requirements, while separately keeping in place the physical assistance standards already required by EU Regulation 1177/2010.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Treating accessibility requirements as limited to the physical dimension on board alone, ignoring the digital extension introduced by the European Accessibility Act | Non-compliance of ticketing and information systems with the requirements binding from 28 June 2025 | Extend the compliance assessment to digital ticketing, travel information and self-service terminal systems as well |
| PRM passenger assistance needs not integrated into the muster plan and emergency procedures | Vulnerable passengers without a specific assistance plan in the event of an emergency | Explicitly integrate PRM assistance needs into the muster plan, not only into ordinary assistance services |
What the PSCO Checks
Operational Tips
- Do not limit the accessibility assessment to the physical dimension alone: from 28 June 2025 the European Accessibility Act also covers electronic ticketing and travel information.
- Always integrate PRM assistance needs into the muster plan and emergency procedures, not only into everyday assistance services.
- Train staff both on assistance in normal conditions and on the specific emergency protocols for PRM passengers.
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.
- Design of cabins, routes and emergency stations compliant with the MSC/Circ.735 recommendations
- Assistance to passengers with disabilities or reduced mobility provided per EU Regulation 1177/2010
- Electronic ticketing and travel information systems compliant with the European Accessibility Act (from 28 June 2025, for services operating in the EU)
- PRM assistance needs integrated into the muster plan and emergency procedures
- Onboard and terminal staff trained on practical assistance to PRM passengers
FAQ
Related Topics
Last substantive revision of this page: 14 August 2026 · page fingerprint 7f7f49996717