The 2025 Regulatory Landscape
Ship owners entering 2025 face a complex web of international regulations that have tightened significantly over the past several years. From emissions standards to ballast water treatment, compliance requirements now touch nearly every aspect of vessel operation. Understanding these regulations—and their enforcement—is essential for anyone operating commercial vessels in international trade.
The International Maritime Organization (IMO) serves as the primary regulatory body for international shipping, but flag states and port state control regimes provide the enforcement mechanisms that give these rules teeth.
Energy Efficiency Requirements
The most significant regulatory changes affecting existing vessels involve energy efficiency. Two key measures now apply to the international fleet:
EEXI (Energy Efficiency Existing Ship Index)
As of January 2023, all cargo vessels of 400 gross tonnage and above must have an EEXI technical file demonstrating compliance with required efficiency standards. Ships that don’t meet the threshold must implement modifications to achieve compliance.
The most common approach involves engine power limitation (EPL), which restricts maximum engine output to reduce emissions. This solution is relatively inexpensive but affects vessel speed and may create challenges in adverse weather conditions.
Alternative compliance methods include:
- Installation of energy-saving devices (hull appendages, propeller modifications)
- Use of alternative fuels with lower carbon content
- Shaft power limitation systems
CII (Carbon Intensity Indicator)
Unlike EEXI, which is a one-time certification, CII creates ongoing operational requirements. Ships receive annual ratings from A (best) to E (worst) based on their carbon emissions relative to transport work performed.
Ships rated D for three consecutive years or E in any single year must submit corrective action plans to their flag state administration. While current regulations don’t mandate specific penalties, poor CII ratings increasingly affect commercial outcomes—charterers and cargo owners prefer vessels with strong environmental credentials.
Improving CII performance requires attention to:
- Speed optimization and voyage planning
- Hull and propeller maintenance
- Cargo operations efficiency
- Port turnaround times
MARPOL Annex VI: Air Emissions
The sulfur cap implemented in 2020 remains a defining feature of maritime environmental regulation. Ships must use fuel with sulfur content not exceeding 0.50 percent globally, or 0.10 percent in designated Emission Control Areas (ECAs).
Compliance options include:
Low-sulfur fuel oil (LSFO) is the most common approach, requiring no vessel modifications but carrying higher fuel costs than traditional high-sulfur bunkers.
Exhaust gas cleaning systems (scrubbers) allow continued use of high-sulfur fuel by removing sulfur compounds from exhaust. Open-loop scrubbers, which discharge wash water overboard, face restrictions in some ports and coastal waters.
LNG and other alternative fuels meet sulfur requirements while also reducing other emissions. The growing availability of LNG bunkering infrastructure makes this option increasingly practical for newbuilds and some conversions.
Ballast Water Management
The Ballast Water Management Convention requires ships to treat ballast water to prevent the spread of invasive species. Implementation has rolled out based on vessel survey schedules, with the entire international fleet now required to have approved treatment systems installed.
Treatment technologies include:
- UV disinfection systems
- Electrochlorination
- Filtration with chemical treatment
- Deoxygenation systems
Port state control increasingly verifies ballast water management compliance, and vessels without approved systems face detention. The investment required ranges from several hundred thousand to over a million dollars depending on vessel size and chosen technology.
Ship Recycling Requirements
The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships entered into force in 2025 after reaching the required ratifications. Ships must now maintain an Inventory of Hazardous Materials (IHM) documenting the location and quantity of materials that could pose risks during recycling.
The IHM must be updated throughout the ship’s life and presented to recycling facilities when the vessel reaches end of life. This documentation enables safer dismantling practices and proper disposal of hazardous substances.
Cyber Security
IMO Resolution MSC.428(98) requires ship operators to address cyber risks in their Safety Management Systems. This means documented procedures for:
- Identifying critical systems and their vulnerabilities
- Protecting against cyber attacks
- Detecting security incidents
- Responding to and recovering from attacks
Port state control now includes verification that companies have addressed cyber security in their ISM documentation, and increasingly sophisticated attacks on maritime systems make this more than a paperwork exercise.
Flag State Considerations
Not all flag states enforce regulations with equal rigor. Ships registered under quality flag states—those performing well in port state control statistics—may face more demanding oversight but benefit from smoother operations in international trade.
The Paris MOU, Tokyo MOU, and other port state control regimes publish annual statistics ranking flag state performance. Ships flying flags with poor records face more frequent inspections and greater detention risk.
Choosing a flag state involves balancing factors including:
- Enforcement reputation and port state control standing
- Registration costs and annual fees
- Survey and certification requirements
- Availability of flag state services worldwide
Preparing for Inspections
Port state control inspections verify compliance with international conventions. Preparing for these inspections requires attention to:
Documentation – All certificates must be current and readily available. This includes Safety Management Certificate, ISPS certificate, classification certificates, and pollution prevention certificates.
Equipment – Safety equipment, pollution prevention systems, and navigation instruments must be operational and properly maintained. Inspectors may test firefighting systems, lifeboat launching equipment, and navigation lights.
Crew competency – Officers must hold valid certificates of competency and demonstrate familiarity with ship systems and emergency procedures. Inspectors may conduct drills or question crew about their duties.
Commercial Implications
Regulatory compliance increasingly affects commercial outcomes beyond just avoiding detention. Major charterers and cargo owners now include environmental criteria in vessel vetting, and ships with strong compliance records command premium rates.
The Sea Cargo Charter and similar initiatives require participants to measure and report vessel emissions, creating transparency that favors efficient operators. Financial institutions are incorporating climate risk into lending decisions, potentially affecting access to capital for vessels that don’t meet emerging standards.
Looking Ahead
The regulatory trajectory points toward tighter requirements in coming years. Discussions at the IMO suggest additional measures may include:
- Carbon pricing mechanisms for international shipping
- Stricter CII thresholds requiring better performance
- Additional emissions control areas
- Lifecycle emissions accounting for marine fuels
Ship owners planning newbuilds or major modifications must consider not just current regulations but likely future requirements. Vessels ordered today will operate for 25 years or more, and the regulatory environment will continue evolving throughout their service lives.
Staying ahead of regulatory requirements—rather than scrambling to comply at deadlines—positions ship owners to operate efficiently while avoiding the penalties and commercial disadvantages that come with non-compliance.
