A Decision from the IMO to Reshape Global Shipping: The Era of Transparency in Ship Registration

The Legal Committee of the International Maritime Organization (IMO) has taken a historic step regarding the ship registration system, which forms the backbone of maritime trade, during its 113th Session held at its headquarters in London between April 13–17, 2026. The Committee has officially adopted the first international guidelines aimed at preventing maritime fraud and the misuse of flags.

As Esenyel Partners, we have carefully evaluated this development, which will have direct consequences for shipowners, ship managers, and financial institutions, with regard to our clients’ operational and legal risk management.

The Current Landscape: Regulatory Gap in Ship Registration

Until today, a binding framework regulating ship registration processes did not exist in international law. This gap has expanded the room for maneuver for organized crime structures and actors seeking to evade sanction regimes.

IMO data clearly reveals the seriousness of the situation:

• Approximately 40 IMO Member States have reported that their flags were used illegally by criminal organizations.
• Within the last year, it has been determined that 529 ships sailed under false flags without the knowledge and consent of the state whose flag they were carrying.
• These practices form the basis for activities such as the circumvention of international sanctions, illegal, unreported, and unregulated (IUU) fishing, human and drug trafficking, and sub-standard ship management.

These illegal practices threaten not only the safety of life and property but also the fair competition order, which is of vital importance for honest shipowners.

Key Elements of the New IMO Guidelines

In the words of IMO Secretary-General Mr. Arsenio Dominguez at the closing of the session, the guidelines represent “a positive step towards ensuring that due diligence is exercised in ship registration systems for safety, protection of the marine environment, and the welfare of seafarers.”

The guidelines are structured around five main pillars:

1. Eligibility Controls: A comprehensive obligation to review the ship’s eligibility for registration is introduced.
2. Quality Assurance in Registration Processes: Standardization and auditability are ensured in registration procedures.
3. Information Sources and International Data Sharing: Aiming to establish a global early warning system by facilitating rapid information flow between flag states and the IMO.
4. Ultimate Beneficial Owner (UBO) and Ship Identity Verification: Detailed due diligence regarding the ship’s true owner and the accuracy of ship identity information becomes mandatory prior to registration.
5. Legal Framework for Registry Authority: Individuals and institutions authorized to conduct ship registration processes are subjected to clear legislation and audit mechanisms; the goal is to prevent the emergence of “shell” registry offices.

Other Critical Topics on the Committee’s Agenda

During the same session, the Legal Committee made other significant decisions directly concerning the maritime sector.

• Substandard Shipping: The correspondence group conducting the Regulatory Scoping Exercise was re-established to prevent illegal operations.
• Liability and Compensation Regime for Alternative Fuels: The Committee determined that existing international liability regimes do not address the unique risks posed by alternative fuels and decided to continue work toward developing a new regime to close this gap.
• Right to Fair Treatment for Seafarers: In 2025, 410 new abandonment cases affecting more than 6,000 seafarers were recorded in the joint ILO/IMO database. The Committee invited Member States to ratify the Maritime Labour Convention, 2006 (MLC, 2006), including the 2014 amendments, and instructed the preparation of a Standard Operating Procedure (SOP) including binding timelines.
• Strait of Hormuz: The Committee condemned threats and attacks against ships in the Sea of Oman, the Arabian Sea, and the Gulf region. It declared the mine-laying threats, the implementation of a transit fee system, and discriminatory measures by the Islamic Republic of Iran around the Strait of Hormuz and the Traffic Separation Scheme (TSS) as violations of international law and the right of transit passage.

Reflections on the Industry: What is Changing for Shipowners?

The new guidelines signify an operational and legal paradigm shift for our clients operating both Turkish and foreign-flagged fleets:

• Ship registration processes will henceforth be subject to multi-layered legal reviews.
• Internal control and reporting processes must be updated within the scope of compliance programs.
• Sanctions against vessels suspected of carrying fraudulent flags are expected to become more severe under Port State Control (PSC).
• In ship sale and purchase (S&P) and financing transactions, more rigorous contractual safeguards will be demanded regarding Ultimate Beneficial Owner (UBO) identification and vessel identity verification.

Esenyel Partners’ Approach

Esenyel Partners, with its established expertise in international maritime law, ship finance, and compliance, ensures that its clients carry out all ship sales and purchases, mortgage registrations, flag changes, and registry transactions in full compliance with current IMO legislation and international regulations.

Our expert team is at your service to assess the impact of the new IMO guidelines on your operations, review your contracts, and structure your registration processes in a legally sound manner.