MCA consultation on the Domestic Safety Management Code
MCA consultation on new Domestic Safety Management Code rules for UK domestic passenger ships closes 17 November 2026. What it proposes and how to respond.
This is a plain summary of an open consultation. It is not legal advice, and it is not the MCA’s text. Read the consultation and the draft documents before you reply.
What is being consulted on
The Maritime and Coastguard Agency published an open consultation on 21 October 2026: Consultation on Merchant Shipping Domestic Safety Management Code Regulations.
The consultation page says it is a consultation on a revised approach to Domestic Safety Management Code regulations following the UK’s exit from the EU. It proposes a new Merchant Shipping (Domestic Safety Management (DSM) Code) to revoke and replace the Merchant Shipping (Domestic Passenger Ships) (Safety Management Code) Regulations 2001, to update and modernise the safety management standards for domestic passenger ships and to remove reliance on obsolete vires in repealed legislation.
The consultation document (published the same day) asks for views on a new statutory instrument, “the new Regulations”. That instrument would revoke and replace the Merchant Shipping (Domestic Passenger Ships) (Safety Management Code) Regulations 2001 (SI 2001/3209). The document says the purpose is to update and improve the safety management requirements for domestic passenger ships, and to make sure UK legislation which gives effect to the Safety Management Code for Domestic Passenger Ships (“the DSM Code”) still works after EU exit.
The document says the new Regulations broadly restate existing requirements, remove reliance on obsolete vires in repealed legislation, and modernise the framework so the regime can still be operated. It also says they strengthen the safety management, audit, survey and certification framework, including a requirement for operators to be issued with a Document of Compliance.
The same document says the new Regulations are needed so the UK can keep implementing and enforcing the DSM Code on UK-flagged ships wherever they are, and on non-UK flagged ships while they are operating in UK waters.
Which ships the code covers
The consultation document says the DSM Code is written so it can be applied to domestic passenger ships. For the code, those are passenger ships on domestic voyages: voyages where the ship does not call into a foreign port. The code does not apply to ships that comply with the International Safety Management (ISM) Code.
It says the code is a common standard for the safe operation of domestic passenger ships which do not comply with the ISM Code. It is kept short so an operator responsible for one or more such ships (ships carrying more than 12 passengers) can develop it for that operation.
The document lists the code’s primary objectives as:
- ensure safety at sea by preventing human injury and loss of life;
- prevent damage to and pollution of the marine environment;
- ensure compliance with applicable regulations and rules.
It says operators responsible for one or more domestic passenger ships are required to develop and implement safe working practices and a safe working environment covering:
- health, safety and environmental protection;
- procedures to ensure the safe operation of ships in compliance with relevant rules;
- lines of communication between personnel ashore and afloat;
- procedures for reporting accidents;
- procedures for responding to emergency situations.
A footnote in the document says regulation 4 of the draft regulations specifies the operational parameters for passenger ships within the scope of the DSM Code. Those parameters are in the draft, not restated here.
What the MCA proposes to change
The consultation document lists the changes the new Regulations would introduce in place of the 2001 Regulations:
- Powers so the safety management system requirements apply and can be updated fully in future.
- An updated framework for the audit of operators and their ships, and for issuing documents of compliance to operators and certificates to their ships. The document says this is to regulate safety management systems on ships more effectively and to remove anomalies, and that it more closely reflects the ISM framework.
- Amendment of the Safety Code for Passenger Ships operating solely within UK categorised waters in MSN 1823(M) and MSN 1823(M) Edition 2 Amendment 1, so safety management system requirements come out of those documents. Those ships would instead follow the standards in the new Regulations and MSN 1869(M) Amendment 2.
- An operator-level Document of Compliance, which the document says has the potential to reduce burdens for some operators and for MCA surveyors.
On that Document of Compliance, the document says it formalises the outcome of the existing office audit, without changing the underlying audit regime. Previously, the office audit date was reflected indirectly by re-issuing Domestic Safety Management Certificates (DSMCs) for each vessel, so one office audit could mean several certificates being reissued. Under the proposal, the Document of Compliance is issued at operator level to demonstrate compliance of the safety management system. The document says the overall requirements stay the same, and that operators would no longer need several DSMCs reissued after a single office audit.
The document says it is believed there will be no additional burden for ships in scope, because they already comply with the updated DSM system.
It also says “do nothing” is not a viable option, that publishing a Marine Information Note or advice without amending the regulations is unsuitable, and that amending the statutory instrument is the preferred option.
The consultation page publishes these drafts and forms with the consultation:
- Consultation document
- DSM Annex A — draft regulations (PDF)
- DSM Annex B — draft MSN 1869(M) Amendment 2 (PDF)
- DSM Annex B — draft appendix, MSN certificate (PDF)
- DSM Annex C — draft MGN 536 Amendment 6 (PDF)
- DSM Annex C — draft appendix, MGN 536 self-assessment (PDF)
- DSM Annex D — de minimis options assessment (PDF)
- DSM consultation response form (ODT)
- DSM consultation feedback form (ODT)
When it closes, and how to respond
The consultation page says this consultation closes at 11:59pm on 17 November 2026.
The consultation document says responses are welcomed from 21 October 2026 to 17 November 2026, that the consultation is open for four weeks from 21 October, and that the deadline for responses is 17 November. It says anyone may respond, and that the MCA will be particularly interested to hear from operators of passenger ships affected by the regulations.
The consultation page says you can email HQ_ISMISO@mcga.gov.uk or write to:
Maritime and Coastguard Agency, Spring Place, (Maritime Safety Management Operations Team, Bay 2/20), 105 Commercial Road, Southampton, SO15 1EG.
The consultation document says the preference is to email responses to the same address, and that questions should go there too. It also gives a postal address naming James Naidoo, Maritime Safety Management Operations Team, at Spring Place, 105 Commercial Road, Southampton SO15 1EG.
The response form asks you to return a scanned copy of the completed form to HQ_ISMISO@mcga.gov.uk, or by post to the Maritime and Coastguard Agency (Attention: James Naidoo, Maritime Safety Management Operations Team, UK Maritime Technical Services), 105 Commercial Road, Southampton SO15 1EG.
The form asks you to say whether you are responding as an individual or for an organisation, and what sort of respondent you are. Its questions, in short, ask whether you agree that:
- the new Regulations should keep broadly the same application of the DSM Code as the 2001 Regulations;
- the scope of the existing exemption provision in the 2001 Regulations should be retained;
- vessels under both editions of MSN 1823(M) are already compliant with the latest safety management system requirements in MSN 1869(M).
It also asks whether the current initial certification process is effective. The form describes that process as an initial audit before a short-term Domestic Safety Management Certificate, then an additional audit within three months before a full-term certificate. If you say that process is not effective, it asks whether extending the additional audit from three months to six months would help, or which other period you would support. There is space for any other comments.
The consultation document says comments on how the consultation was run go to consultation.coordinator@mcga.gov.uk, using the separate feedback form. Those comments are not affected by the 17 November deadline.
What the MCA says happens next
The consultation document says that after the consultation closes the MCA will review responses, with more weight given to organisations and individuals with specialist knowledge. It says analysis will be during late autumn 2026 and early 2027, and that the aim is to publish an overview of responses and the MCA’s comments within at most three months of the end of the consultation, on the same GOV.UK page.
It says the aim is for the new Regulations to come into force in the spring of 2027, to be published on legislation.gov.uk, and for MSN 1869(M) Amendment 2 to be published with the Regulations. Those are the MCA’s stated aims. They are not dates that have been fixed in law.
How WaterTightVM fits this work
WaterTightVM does not implement the DSM Code for you, and it does not issue a Document of Compliance. If you are preparing for an office audit or a ship audit, WaterTightVM can hold records you already keep:
- safety management system documents, with a file and an acknowledgement that a crew member has read a document;
- drill records and incident reports;
- crew certificates and vessel certificate documents, including issue and expiry dates;
- planned maintenance jobs.
Electronic MARPOL, ballast water and ISPS record books, and cargo checks, are under development. They are not available to use for this consultation response.
Keep the records an office audit asks for in one place, visible from shore.