Interferry’s regulatory priorities are established collaboratively with our membership, primarily through the guidance of the Board of Directors and the Operators Policy Committee (OPC.)
The Regulatory Affairs office works to ensure that the interests of ferry operators and users are adequately considered in the formulation of regulatory policy.
Explore our Regulatory Priorities for 2026 below.
Background
In the wake of the 2015 COP21 Paris Agreement on Climate Change, the International Maritime Organization (IMO) drafted a decarbonisation roadmap. Its greenhouse gas (GHG) strategy calls for an annual reduction of GHG emissions from international shipping by at least 20%, striving for 30% by 2030, with 2008 being the reference year. By 2040, the annual GHG emissions from international shipping should be reduced by at least 70%, striving for 80%, compared to 2008. The bottom line is to reach net-zero GHG by 2050.
Work to Date
In 2022, the IMO’s 78th session of the Marine Environment Protection Committee (MEPC 78) agreed on short-term measures to support IMO’s 2030 and 2050 goals on reduction of GHG. In July 2023, MEPC 80 adopted the IMO 2023 GHG Strategy, replacing the initial strategy adopted in 2018.
Key instruments for the short-term measures are the Energy Efficiency Existing Ship Index (EEXI), which affected many ships to such an extent that they had to find measures to match the corresponding Energy Efficiency Design Index (EEDI) criteria which are applied to new designs, in many cases through fitting power-limitation devices.
For ro-ro cargo and ro-pax ferries, the IMO has recognised the challenges with regard to the special correction factors for existing ships. For this reason, EEXI has had only negligible implications on Interferry members.
CII
In parallel with EEXI, the Carbon Intensity Indicator (CII) was adopted by MEPC 78. Meant to enter into force on 1 January 2023, from the outset it was made clear that CII was subject to a comprehensive review before 2026. CII is a mandatory IMO instrument, which (uniquely) currently holds no legal repercussions for non-compliance. This is a clear indicator that Member States are not satisfied with the instrument in its current form.
While CII could be a valuable complement to the Ship Energy Efficiency Management Plan (SEEMP), most segments in shipping take the view that forcing ships to meet an operational efficiency requirement is not realistic as many efficiency choices are beyond the operator’s commercial control or are negatively impacted by adverse weather conditions in certain parts of the world.
Interferry has forcefully argued that CII penalises short voyages and port visits, which is unacceptable as frequent port visits are intrinsic to ferry operations. Also, other segments have noted the CII is skewed in favour of long voyages.
Furthermore, most of the ro-pax ferries that fall under the IMO MEPC 82 in 2025, the CII was effectively put on hold until more work has been done on its foundation.
LCA
To comply with the various current and future GHG requirements on both national and international level, the adoption of renewable fuels of non-biological origin (RFNBO) and biofuels will be a prerequisite. This, in turn, calls for definitions of such fuels and a control mechanism to verify them.
The IMO has agreed an interim measure in line with the civil aviation’s ICAO model with Approved Sustainability Certification Schemes and the CORSIA Sustainability Criteria (Chapter 2) for CORSIA Eligible Fuels (MEPC.1/Circ. 905). In practice most administrations (especially those in the EU) will most likely accept fuels certified to the Renewable Energy Directive (RED) from International Sustainability & Carbon Certification (ISCC). Under this approach, a biofuel needs to provide a well-to-wake GHG emissions reduction of at least 65% compared to the well-to-wake emissions of fossil marine gasoil (MGO) of 94gCO2e/ MJ and meet a number of sustainability criteria (e.g. what type of biomass may be eligible).
This approach is similar but not exactly corresponding to the criteria and parameters established in the EU’s Renewable Energy Directive II (RED II). This means that a biofuel certified for CII improvement will not necessarily be recognised by the EU ETS and vice versa.
Current status
When the short-term-measured was developed, there was an idea to introduce a global market-based measure (MBM) coupled with technical requirements on carbon intensity. Several versions of MBMs have been on the IMO’s table and also several technical regulations have been debated.
In April 2025, IMO MEPC 82 agreed on the so-called Net-Zero Framework (NZF) and its supporting mechanism under the greenhouse gas fuel intensity (GFI) requirements. Notably though, this agreement was only reached after a vote, which is highly unusual in IMO, which always strives for consensus decisions.
In October 2025, the NZF was up for adoption – as per the IMO’s normal procedures – but this time there were so many dissenting voices in the Maritime Environment Protection Committee that deliberations were adjourned for 12 months until Oct/Nov 2026.
While described as a setback for global GHG regulations, Interferry believes that the decision to pause the discussion was necessary. It is not evident to Interferry that the money-collecting element of the NZF – to the tune of perhaps USD 10 billion per year – will generate the highest emission reduction per investment made. The IMO has a long and proud tradition of developing comprehensive, detailed and functional regulations for very complex matters. Adding money-collection to that mix risks undermining the technical relevance of the requirements.
Background
The comprehensive revision of SOLAS II-2 in relation to ro-pax ferry fire safety did not address training issues, despite both industry and member states recognising that training was a key element in fire safety.
Many Interferry operators have expressed a need to revise existing fire-fighting training for ro-ro deck crew. This has been discussed in the Interferry Fire Safety Work Group which has endorsed the need for improved training, considering both general ro-ro deck issues and new challenges relating to the proliferation of alternatively fuelled vehicles.
Work to date
Interferry’s Fire Safety Work Group agreed that it would not be in the industry’s interest to introduce revised training requirements which would trigger additional certification of crew working in an industry characterised by a shortage of qualified seafarers. Therefore, the challenge lies in advocating more targeted ro-ro deck training, while minimising administrative implications.
One way to address fire-fighting training would be to revise the IMO Model Course 2.03 (Advanced Training in Fire Fighting). The 9th session of the IMO’s Sub-Committee on Human Element, Training and Watchkeeping (HTW9) validated a revised course as late as February 2023, so it will take about five years before this Model Course can be revised again. Furthermore, members argued that it would be challenging to address explicit ro-ro issues in the more general advanced training course.
Current status
The IMO is currently underway with a comprehensive review of the STCW Convention and Code. Interferry is a member in the ongoing Correspondence Group. The revision shall be concluded by 2026/2027.
It is understood that the Correspondence Group will deal with 22 categories within a preliminary list of specific areas identified for review. This will likely include the implications of ‘New Energy Carriers’ and others, which are to be addressed from the 10th session of the IMO’s Sub-Committee on Ship Systems and Equipment (SSE10) onwards.
Background
In 2021, China suggested to the IMO to “evaluate the adequacy of fire protection, fire detection and fire extinction arrangements in vehicle, special category and ro-ro spaces in order to reduce the fire risk of ships carrying new energy vehicles (including electric vehicles and alternative fuel vehicles)”.
The 10th session of the IMO’s Sub-Committee on Ship Systems and Equipment (SSE10) took this on board in March 2024. In line with the Correspondence Group under CCC, the generic term ‘ro-ro’ prompts a lot of clarification to differentiate the ro-ro ship types.
The outcome of the comprehensive LASH FIRE research project was decisive in gaining acceptance for a ro-ro ship with a drencher system not having the same challenges as a ro-ro ship with a CO2 fire suppression system (something prohibited on a ro-pax ferry). This has warranted an exclusion of ro-pax from parts of the pending Correspondence Group review.
Current Status
During 2025 Interferry participated in a Correspondence Group under SSE which undertook extensive work on fire safety issues. Most of it pertained to container ships and pure car and truck carriers (PCTCs). For ro-ro/ro-pax it was recognised that the recent revision of SOLAS II-2 covered several current issues, e.g. carriage of electric vehicles.
We anticipate additional discussions on carriage of all types of alternatively powered vehicles during 2026 and remain focused on identifying the particularities within each of the ship types affected (ro-ro vehicle, ro-ro cargo and ro-ro passenger).
Background
The 1994 (2000) IMO High-Speed Craft Code (HSC Code) is based on the recognition that onboard ship safety measures can be complemented by shore-side infrastructure for regular services on coastal routes, whereas the conventional ship philosophy relies on the ship being entirely self-sustaining in case of an emergency.
The code has proven very successful since first introduced over 20 years ago. However, lightweight craft manufacturers and ferry operators alike have raised their voice regarding the speed element and wonder if there is there is any objective reason to retain the minimum speed threshold.
Work to Date
In 2019, Interferry’s Policy Committee decided that the organisation should push for a change in the HSC Code, allowing for lightweight craft of any design speed to operate under the special provisions in the Code. On account of COVID-19, work was shelved until March 2022 when Interferry presented the concept to the European Commission’s Passenger Ship Safety Expert Group.
While there was support in terms of the ambition to promote lower speed designs, Member States were cautious of the complexity of changing the scope. There were also concerns about the duration to get this through the IMO, noting that even the planned 2028 revision of the HSC Code may be too optimistic due to the pandemic backlog.
Current Status
The Danish Maritime Authority (DMA) has approved for light craft designs not meeting the speed threshold to still be compliant with the EU’s iteration of the High-Speed Craft Code, for voyages of max 5 nautical miles. Following that decision, DMA also informed the EU Commission with a view to initiate a pan-EU recognition of this approach.
If not objected by Member States, DMA will extend the permission to 20 nautical miles, which will thus open up for Interferry to approach the IMO asking for global acceptance of the approach.
Background
Initiated by the EU, the IMO is discussing the general provisions for discharge water from exhaust gas scrubbers. It is argued that here is growing scientific evidence of the harmful impact of exhaust gas cleaning system (EGCS) discharge water on the marine environment, justifying the application of the precautionary principle to regulate such discharges.
There are Member States arguing that the evidence of actual negative impact of EGCS discharge water on the marine environment is not clear and that more scientific research is necessary to analyse the risk before potentially amending the water discharge criteria set out in the 2021 EGCS Guidelines.
In parallel with the IMO, the European Commission initiated a revision of the Ship-Source Pollution Directive (EC 2005/35). This was finalised by the European Parliament and the Council in early 2024. The original Directive matches the IMO MARPOL definitions of pollutants, but the new proposal suggests to add NOx, SOx, and scrubber discharge waters as new pollutants.
Current status
There are concerns regarding the possible penalisation of ships whose owners/operators have in good faith and in accordance with regulations, installed EGCS as an alternative compliance method. Several organisations, including the International Chamber of Shipping, claim that a global ban on the use of EGCS would create a negative precedent, eventually leading to a significant negative impact on trade. Additionally, it would impair the credibility of the IMO and the trust of the shipping industry in global regulations.
Finland, Sweden and Denmark have all enacted legislation restricting Exhaust Gas Cleaning System (EGCS) wastewater discharge along their Baltic Sea coasts. The restrictions apply only within the countries’ territorial waters (12 nautical miles) in the Baltic Sea.
For closed-loop systems, the Finnish and Swedish bans will enter into force on 1 January 2029 and for Denmark from 1 July 2029.
The regional co-operation forum OSPAR has agreed to a staged ban on the release of EGCS discharge water in internal waters and port areas of the North-East Atlantic (OSPAR maritime area); for open-loop from July 2027 and discharges from closed-loop scrubbers will be prohibited by July 2029. A roadmap to examine a possible extension to territorial seas in 2027 was also agreed.
Next steps
Industry stakeholders, such as the International Chamber of Shipping, are increasingly challenging the proliferation of regulatory bodies, undermining the stability provided of having the IMO oversee all international regulations.
Furthermore, ICS and Interferry’s position is that any regional prohibition on EGCS discharges in territorial seas and/or internal waters, shall be supported by the IMO’s risk and impact assessment framework.
Background
In October 2024, the EU will implement its entry/exit system (EES – an automated IT system), which is much like the United States ESTA. Six months later, ETIAS (European Travel Information and Authorisation System – for visa-waiver countries) will enter into force. This could be very disruptive to operators between third countries and the EU (examples are UK-Continent and Spain-Morocco).
Work to Date
During the regulatory process, no consultation was held with passenger ship operators (cruise and ferry). The operators’ main concern is for long delays in processing passengers in the ports, as the system seems to be inspired from the aviation-style border control. When enforced, each third country citizen needs to provide biometric data on his/her first entrance to the EU. This entails taking finger-prints and facial photos of all passengers aged 12 or older, which for car and bus passengers will be very time consuming.
Another concern with the operators is the lack of information to passengers. How will the EU informng third countries of these changes and what do operators need to do with their booking systems?
Current Status
Interferry has set up a task force for EES/ETIAS, consisting of Brittany Ferries, DFDS, FRS, GNV, Irish Ferries and Stena Line.
Next Steps
Interferry will continue to oversee the introduction of ETIAS in April 2026, not expecting any dramatic implications for its members.
Background
Prompted by a court case against a member, Interferry has since 2019 had a small Working Group in place to seek members’ input on the EU Passenger Rights (PR) regulation (1177/2010). An overhaul of all PR regulations (aviation, train, maritime, bus) was announced in 2021, followed by public consultation in 2022. In 2023, the European Commission presented a package of proposals to ostensibly harmonise and improve the regulations. However, none of the issues that were contentious in the aforementioned maritime court case were addressed, and except for some potential linkage through multi-modal trips, nothing new has been presented for maritime.
Work to date
Interferry has worked closely with the European Community Shipowners’ Associations (ECSA) on this file with joint comments in February 2024.
In November 2023, the European Commission presented “a series of proposals designed to improve the experience of passengers and travellers by strengthening their rights”.
Interferry and ECSA welcome the discussion on clarification of passenger rights in the different transport modes but notes a lack of any proposal addressing the ferry industry’s concerns over the existing regulation 1077/2010.
Additionally, stressing the concept ‘multimodal journeys’ will inevitably address certain aspects of the existing Maritime Regulation. Such overlaps will not necessarily be managed in the same legislative process in the future, further complicating matters.
The aforementioned series of proposals from the European Commission do not address any of the serious concerns the ferry industry has over the Maritime Passenger Regulations as set out in EC 1177/2010.
Background
The International Association of Classification Societies (IACS) has established a Joint Industry Working Group (JIWG) on safe Decarbonisation with the main objective to discuss and develop a common understanding for safety aspects of decarbonising technologies and fuels, including the possible solutions to identified challenges and relevant regulatory needs.
The JIWG will have a role in identifying and reviewing various decarbonising and carbon abatement technologies and fuels currently being proposed by shipyards/technology providers, followed by a review of readiness of rules and regulations to accommodate these new technologies.
The JIWG will focus on safety risk analysis and regulatory gap analysis (as described in the deliverables). The JIWG on Technology Readiness Level (TRL) is considering aspects other than safety such as Technology Readiness Levels and commercial aspects (CAPEX, OPEX) of fuels/technologies.
The JIWG will discuss a range of technologies related to GHG emissions from ships. Objectives of the group will be: sharing of technical knowledge and experience on proposed solutions; alignment of safety principles between industry and IACS; advise IACS on the most important and urgent issues to be addressed in possible IACS resolutions and guidelines; discuss between industry and IACS on possible common submissions to the IMO.