The Department for Transport has made the Merchant Shipping (Polar Code) (Safety) Regulations 2025, bringing the latest SOLAS Chapter XIV and Polar Code changes into UK law from 1 January 2026. The instrument revokes and replaces the 2021 regulations and confirms the UK timetable aligned with the IMO’s 2023 amendments.
Scope is broad. The rules apply to UK‑flagged ships operating, or intending to operate, in polar waters and to non‑UK ships that start or end a voyage at a UK port and will operate in polar waters. Exemptions cover, among others, ships of war, state non‑commercial service, vessels below stated tonnage or length thresholds, non‑mechanically propelled or primitive wooden ships, certain pleasure vessels, specified fishing vessels, and ships solely on the Great Lakes and St Lawrence to the stated demarcation.
Timelines are staged. All requirements commence on 1 January 2026. Vessels in the additional categories that were constructed before 1 January 2026 have until 1 January 2027 to meet the new navigation and voyage‑planning provisions inserted into the Polar Code as chapters 9‑1 and 11‑1.
For passenger ships and cargo ships of 500 GT and above, the regulations give direct effect to Polar Code part I‑A safety measures, including performance standards, operational assessment, PWOM carriage, ship structure, subdivision and stability, watertight integrity, machinery, fire safety, life‑saving appliances, safety of navigation, communications and voyage planning.
The instrument expands coverage to non‑SOLAS ship types in polar waters. Fishing vessels of 24 metres and above, pleasure vessels of 300 GT and above not engaged in trade, and cargo ships of at least 300 GT but under 500 GT must meet Polar Code chapters 9‑1 (safety of navigation) and 11‑1 (voyage planning) when operating in polar waters.
Certification is formalised through the Polar Ship Certificate. UK ships within scope require certification following an initial survey before first polar operation and at scheduled points thereafter; non‑UK ships departing from a UK port must carry either a Polar Ship Certificate (if from a SOLAS party) or equivalent evidence of compliance. Operators should expect the MCA to check the certificate is carried and valid.
The Polar Water Operational Manual (PWOM) becomes a day‑to‑day operating obligation. Companies and masters must run the ship in line with the PWOM, and all seafarers must be familiar with the manual’s procedures and equipment relevant to their duties. Failure to operate to the PWOM or to ensure familiarity is a criminal offence under the instrument.
Training duties mirror STCW V/4. Masters, chief mates and officers of the navigational watch must hold the appropriate Polar Code Certificates of Proficiency. Basic training is required for operations in open waters; advanced training is required for masters and chief mates in other waters. Limited replacement of unqualified officers is permitted only where strict conditions are met on certification, watchkeeping cover and hours of rest.
Design flexibility is possible but tightly controlled. Alternative designs or arrangements for structure, machinery, electrical systems, fire safety and life‑saving appliances may be approved where an engineering analysis demonstrates the goals and functional requirements are met and an equivalent level of safety is achieved. Approved deviations must be recorded in the Polar Ship Certificate and PWOM.
Enforcement combines criminal liability and port state control. Offences generally attach to the owner and master for technical non‑compliance, to the master for voyage‑planning failures, and to both the company and master for PWOM operation and familiarity breaches. Penalties include fines on summary conviction and, on indictment, imprisonment up to two years. Ships may be detained where there are clear grounds of non‑compliance.
Survey and certification processes in the Merchant Shipping (Survey and Certification) Regulations 2015 are updated to include polar surveys and the issue and endorsement of the Polar Ship Certificate. Transitional provisions allow a category C cargo ship to be certificated without an initial onboard survey if a documented operational assessment shows no additional equipment or structural changes are required, with the survey then carried out at the next scheduled opportunity.
The Maritime and Coastguard Agency has updated guidance. MGN 637 (M) (as revised) explains PWOM content, certification steps, training expectations, and course approval procedures for providers. Operators should align their safety management systems with the guidance and ensure any training partners hold MCA approval.
The 2025 instrument uses an ambulatory reference, so future SOLAS Chapter XIV or Polar Code changes will automatically flow into UK law when they enter into force internationally, limiting the need for repeated domestic amendments and keeping UK requirements aligned with the IMO timetable.
Context from the IMO is clear: MSC 107 adopted amendments MSC.532(107) to SOLAS Chapter XIV and MSC.538(107) to the Polar Code in June 2023, with an entry‑into‑force date of 1 January 2026. The UK has implemented these changes on the same date.
Operationally, shipowners, fishing companies and yacht operators planning polar voyages that start or end in the UK now face a short compliance window. Practical steps include confirming category and operating area, commissioning the operational assessment, scheduling surveys, updating the PWOM, booking STCW V/4 training, and checking that certificates will be on board and available for inspection from 1 January 2026.