Remote Survey Guidance: Remote Survey, ISM Audits and ISPS Verifications
MSC-MEPC.5/Circ.17 of 18 June 2026 distinguishes remote HSSC surveys, ISM audits and ISPS verifications. Eligibility, physical attendance and flag authorization depend on the activity; remote ISPS verifications are considered only in extraordinary circumstances.
Operational Explanation
Preparing remote verification means turning the request into a plan that can be checked. For each item, connect the activity and document concerned with the proposed method, the person providing evidence and the result to verify. The plan must identify attendance and outstanding work; the report then supports follow-up without confusing received data, a verified item and a completed activity.
The circular provides supplementary guidance for verification equivalent to physical attendance, without reducing the scope required by IMO instruments. The company may request remote methods but cannot independently determine eligibility. Risk assessment, detailed planning and acceptance under the flag and authorized recognized organization instructions are required (RO, or RSO for security). An item that cannot be verified reliably remains outstanding for in-person completion; a good connection does not itself make an activity eligible.
Regulatory Reference
MSC-MEPC.5/Circ.17 — 18 June 2026, final text; IRI library. Part A: common guidance; B-I: HSSC surveys; B-II: ISM audits; B-III and appendix: ISPS verifications. The circular refers to A.1207(34), HSSC 2025, §5.14, and A.1188(33), 2023 ISM implementation guidelines, §4.8. Also apply flag instructions for the ship and activity concerned.
Cross-reference note: HSSC 2025 A.1207(34) places remote surveys in §5.15; §5.14 addresses ships intended to carry industrial personnel. The §5.14 reference reported in the circular should not be used to locate the remote-survey section in the final HSSC text. HSSC 2025 §§5.14–5.15.
Scope of Application
HSSC surveys — Part B-I. Under normal circumstances, initial and renewal surveys are not performed remotely except for documentary/data checks. Other scheduled surveys may include assessed and planned remote portions, with in-person completion: the same remotely surveyed items should not be surveyed remotely again at the following survey. Passenger-ship surveys for SOLAS safety and Load Lines certificates, including deficiency follow-up, are not eligible except for documentary/data checks. Consider age, serious deficiencies, PSC history, detentions and casualties: under normal circumstances the guidance excludes remote surveys above 20 years for cargo ships, gas carriers, MODUs and LNG-fuelled vessels, and above 15 years for ESP oil tankers and bulk carriers. It also excludes remote surveys following major hull or machinery modifications or casualties. The flag assesses additional and follow-up activities case by case; eligibility must not be assumed.
ISM audits — Part B-II. Records and interviews may be examined remotely under the plan. Interim, initial, intermediate, renewal and additional shipboard audits still require onboard attendance to examine ship condition, personnel activities and working practices. Additional audits following a downgraded major non-conformity are conducted on board. Interim, initial, renewal and additional DOC audits require auditor attendance; separate consideration may be given to remote methods for an interim audit adding new ship types to an existing DOC and annual audits between five-year issuance/renewals.
ISPS verifications — Part B-III. Remote methods are not routine: the flag considers them case by case only in extraordinary circumstances preventing attendance despite reasonable efforts to arrange it. Initial and renewal verifications are not conducted remotely. Interim, intermediate and additional verifications are subject to the specific conditions in Part B-III; the cases in §2 include postponements allowed by conventions/codes, intermediate and additional verifications. Results require validation at the subsequent physical verification. Remote verification of rectification after significant security breaches or failures is not recommended. The appendix distinguishes YES, NO and ADMIN items: ADMIN requires flag assessment and is not a general authorization.
Procedure / How to Complete It
- Classify the activity, certificate, ship type and age and compliance history; identify eligible items and those requiring attendance.
- Submit the plan in advance to the RO/RSO and flag according to their responsibilities: scope, personnel, schedule, technology, tests and evidence, physical verification and termination criteria.
- Test audio/video, coverage and data quality; assign competent personnel and protect occupational safety and confidentiality. Stop if reliability, impartiality or verification objectives cannot be assured.
- Report findings and outstanding items and complete in-person work within the applicable window. For surveys, also plan subsequent verification of remotely checked items.
- Control electronic evidence through written procedures; the flag sets the minimum retention period under national law. Recording interviews is normally prohibited: if deemed essential, document the recording and interviewee consent in the report. If another person is present, also document that circumstance and the interviewee’s consent in the report.
Practical Example
For an eligible cargo ship, an annual survey plan may include remote examination of records and selected tests while retaining required physical checks on board. Remote items are identified so the same method is not repeated for them at the following survey. The plan cannot automatically be transferred to a renewal, a passenger ship or an ISPS verification.
What Typically Goes Wrong
Confusing eligibility of an individual item with eligibility of the entire survey; extending DOC exceptions to shipboard audits; treating remote ISPS verification as routine; routinely recording interviews.
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Treat an eligible portion as a fully remote survey | Required physical checks may be omitted and the survey may remain incomplete. | Assess and plan each item according to survey type and ship conditions; obtain competent acceptance and retain the required in-person completion. |
| Extend DOC possibilities to shipboard audits | Ship condition, personnel activities and safe working practices may be left without the auditor’s onboard examination. | Distinguish Company and ship audits and plan the attendance required by Part B-II without transferring DOC exceptions to the SMC. |
| Schedule remote ISPS verification as a routine activity | The proposed method may be ineligible even with a reliable connection. | Document extraordinary circumstances and submit the case to the flag, applying Part B-III limits and item-specific assessment; initial and renewal verifications are not conducted remotely. |
| Record interviews as standard evidence | Interview confidentiality and integrity may be compromised. | Observe the normal prohibition; if recording is deemed essential, document it and consent in the report. Also document any other person’s presence and, in that case, the interviewee’s consent. |
What the PSCO Checks
Operational Tips
- Use an item-by-item matrix: remote / attendance / special flag consideration, with responsibilities and deadlines.
- Retain authorization, plan, report and evidence under applicable instructions; distinguish technical evidence from interview recordings.
- Do not transmit sensitive ISPS documents without flag-accepted conditions and secure communications; if secure transmission cannot be ensured, do not examine them remotely.
Preparation checklist
- Applicable category and limits checked
- Risk, age and history assessed
- Plan and authorizations available
- Attendance and subsequent checks planned
- Termination criteria and connection tested
- Confidentiality, consent where needed and retention defined
FAQ
Related Topics
Certified substantive revision: 14 October 2026 · page fingerprint 4c5dfb511a83