The Tokyo Memorandum of Understanding (Tokyo MOU) will introduce a new method for calculating flag State and recognized organization (RO) performance, changing how these are assessed in its Annual Report and used to determine ship risk profiles under the New Inspection Regime (NIR).
Under the revised methodology, flags and ROs will be classified as high, medium or low performance according to their detention rates compared with the regional average. The classification will depend on whether each detention rate falls below the regional average, reaches or exceeds that average but remains below twice its level, or is equal to or greater than twice the regional average.
The Tokyo MOU’s planned changes follow a similar move by the Paris MOU, which is revising its recognized organization (RO) performance methodology ahead of the amended EU Port State Control Directive, due to take effect on 6 July 2027. Both approaches compare detention rates with a regional or overall average and link detainable deficiencies to the RO that issued or endorsed the relevant statutory certificate.
The International Association of Classification Societies (IACS) has raised concerns about the Paris MOU’s approach, warning that detention rates may not accurately reflect an RO’s actual involvement in deficiencies. It argues that operational, maintenance and crew-related issues can fall outside an RO’s direct control, potentially leading to misleading performance classifications and increased port State control (PSC) inspections for ships. IACS has called for further validation, appropriate statistical safeguards and open discussions with maritime stakeholders, while exploring possible appeal mechanisms and proposals to strengthen port State control officer training and oversight.
Three-year data period and smaller fleets
Performance calculations will generally use detention data from the latest three calendar years. However, transitional arrangements will apply to RO performance calculations:
- the first assessment will use data from 1 January to 31 December 2027,
- while the second will cover the period from 1 January 2027 to 31 December 2028.
Only one detention will be counted for each flag or RO per inspection, regardless of the number of detainable deficiencies attributed to it.
For flags and ROs with smaller fleets, where the number of inspections during the relevant period is below the calculated critical-inspection threshold, performance will be determined by the number of detentions.
Those with no detentions will be classified as high performance, those with one detention as medium, and those with more than one detention as low.
The critical-inspection threshold is calculated as 100 divided by the regional average detention rate.
Tokyo MOU to introduce a new RO attribution method
The Tokyo MOU will also replace the term responsible RO with related RO for the purposes of calculating RO performance.
A related RO will be identified when a detainable deficiency concerns a statutory certificate whose latest issuance or endorsement was carried out by an RO. The relevant certificate will be identified using the Tokyo MOU’s published Background Table for RO Relation.
Data on responsible ROs will continue to be collected for the Tokyo MOU’s internal use.
Implementation timeline
Collection of data on RO relations will begin on 1 January 2027. During initial inspections conducted on or after that date, port State control officers (PSCOs) will select the statutory certificate associated with a detainable deficiency using the Background Table. The collection of flag State data will remain unchanged.
The revised flag and RO performance assessments will be published in the Tokyo MOU Annual Report approximately every 1 May and applied to ship selection under the NIR from 1 July of the same year.
For the first assessment under the new methodology, the 2027 flag performance calculation will use data from 1 January 2025 to 31 December 2027, while the RO performance calculation will use data from 1 January to 31 December 2027.
The results are expected to be published in the Annual Report around 1 May 2028 and applied to ship selection under the NIR from 1 July 2028.
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