The IMO Legal Committee (LEG) held its 113th session from 13-17 April 2026, progressing a wide range of legal issues of direct relevance to shipowners, operators, insurers and charterers. Key discussions focused on liability and compensation regimes, the continued rise in seafarer abandonment cases, fraudulent ship registration and emerging legal gaps linked to alternative fuels.
Entry into force of the 2010 HNS Protocol now within reach
Significant progress was made towards the entry into force of the 2010 HNS Protocol, which establishes an international liability and compensation regime for damage arising from the carriage of hazardous and noxious substances (HNS) by sea.
The joint ratification by Belgium, Germany, the Kingdom of the Netherlands and Sweden on 14 April 2026 means that the Protocol has now met the first entry‑into‑force condition. Subject to remaining requirements being fulfilled, the Convention is expected to enter into force in November 2027.
For information of BIMCO members involved in the carriage of HNS cargoes, discussions highlighted the practical implications of implementation, including the anticipated administrative burden linked to insurance certification. Once in force, an estimated 65,000 vessels will require HNS insurance certificates, raising concerns about capacity, timing and coordination among States issuing certificates, including for ships flagged in non‑contracting States.
The Committee encouraged contracting states to adopt a coordinated approach to certification to ensure continuity of trade and avoid bottlenecks ahead of entry into force.
Growing urgency around seafarer abandonment
Seafarer abandonment remained a central concern at IMO LEG 113, with data showing a continued and unprecedented increase in reported cases. In 2025 alone, 310 new abandonment cases were recorded, with early 2026 figures indicating a further escalation.
The discussions reinforced the importance of effective financial security arrangements under the Maritime Labour Convention (MLC 2006). The Committee stressed that the presence of compliant financial guarantees demonstrably improves outcomes for seafarers and supports faster resolution of cases, reducing operational disruption and reputational risks for shipping companies.
Flag and port states were urged to strengthen enforcement, including through port state control, while industry stakeholders were encouraged to ensure robust compliance across ownership and management structures.
The Committee also agreed to pursue the development of a model standard operating procedure (SOP) to support faster and more coordinated responses in abandonment cases, which could offer greater predictability for owners, managers and insurers dealing with complex multi‑jurisdictional situations.
BIMCO will continue to follow and engage in this work, including through participation in relevant IMO/ILO joint working group addressing seafarer abandonment and fair treatment, where industry input remains essential to ensuring that measures are practical and effective.
Criminalisation of seafarers and the need for fair treatment
The Committee also revisited the issue of criminalisation and detention of seafarers, emphasising the need to promote and implement the 2024 IMO/ILO Guidelines on fair treatment of seafarers detained in connection with alleged crimes.
Delegations highlighted the impact that prolonged detention and unclear legal processes can have not only on individual seafarers, particularly masters, but also on ship operations and crewing. The discussions underlined the continued importance of clear procedures, consular support and cross‑state cooperation when incidents occur in foreign jurisdictions.
Tackling fraudulent registration and false flags
IMO LEG 113 made further progress on addressing fraudulent ship registration and fraudulent registries, issues that continue to undermine the integrity of international shipping and create legal uncertainty for owners, charterers and financiers.
At this session a new set of guidelines were approved to improve transparency and due diligence in ship registration, as well as prevent fraudulent registrations and misuse of flags. Thsee non‑binding guidelines on due diligence in ship registration, cover, for example, verification of ownership, classification, insurance and registry documentation. To avoid duplication, related work streams were consolidated under a single working group tasked with developing one coherent set of guidelines.
These guidelines aim to support states, particularly developing administrations, while strengthening confidence in registry practices and reducing exposure to substandard operations.
Addressing liability gaps for alternative fuels
The Committee acknowledged that existing international liability regimes do not currently address incidents involving alternative fuels used for ship propulsion, such as ammonia or hydrogen. To reflect this, the relevant output was renamed to allow for either the development of a new regime or amendments to existing conventions, including the Bunkers Convention.
