IACS has raised concerns over the Paris MoU’s forthcoming methodology for assessing Recognized Organization performance, warning that the new approach may not accurately reflect an RO’s actual involvement in deficiencies and could have unintended consequences for ships’ PSC risk profiles.
The Paris Memorandum of Understanding (Paris MoU) is set to overhaul the way the performance of Recognized Organisations (ROs) is assessed, with a new methodology coming into force on 6 July 2027.
The new system will introduce a fundamental change in how responsibility for detainable deficiencies is assigned. Rather than determining whether an RO caused, contributed to, or could reasonably have prevented a deficiency, the methodology will link the deficiency directly to the RO that issued the relevant statutory certificate.
Under the new deterministic approach, the statutory certificate associated with a detainable deficiency will become the key factor in determining which RO is held accountable.
Under the new methodology, RO performance will be assessed using a formula based on inspection and detention records over a three-year period, the same as that used for Flag State Administrations, which focuses on the number of inspections and detentions. Performance will be categorised as follows:
- High Performance: the detention rate is better than the overall average.
- Medium Performance: the detention rate is equal to or worse than the overall average.
- Low Performance: the detention rate is at least twice the overall detention average.
All recognised organisations (ROs) will be included in the performance lists, regardless of the number of inspections they undergo. The aim is to ensure that each RO can be categorised and that the resulting classification can be used to establish a Ship Risk Profile for targeting vessels for inspection.
For ROs with a limited number of inspections, performance will be assessed against specific criteria. This approach is designed to prevent a single detention from automatically placing an RO on the low-performance list.
As a preparatory step towards implementing the new RO performance methodology and aligning it with the amended EU Port State Control Directive, the Paris MoU began, on 1 January 2026, linking detainable deficiencies identified during inspections to the statutory certificates issued or endorsed by the relevant RO.
The new methodology will enter into force on 6 July 2027, initially based on inspection data from the 2026 calendar year. From 1 July 2028, the assessment will be based on data from two calendar years—2026 and 2027. From 1 July 2029 onwards, the methodology will incorporate data covering three full calendar years, providing a broader and more representative basis for assessing RO performance.
IACS warns new RO methodology could misrepresent performance
IACS supports the objective of improving transparency and consistency in PSC performance assessment; however, it is concerned about the new RO performance methodology, as the approach does not adequately reflect the level of involvement of ROs, thus generating misunderstandings about the role and responsibilities of ROs and exposing ships and Companies to misperceptions associated with published PSC data (which influence the Ship Risk Profile, used to target ships for inspection), as specified below:
- while PSC inspections can be conducted at any time in port, an RO generally undertakes surveys only once a year and SMC audits every 2.5 years, as required by the applicable regulatory instruments (for example, there may be cases where, at the time of a PSC inspection, the last RO survey was almost a year and a half ago);
- when a significant period of time has elapsed between the RO survey and the detention, the ship’s condition may have considerably changed, therefore the deficiency may be attributable more to onboard operations (i.e. lack of maintenance or failure to report a deficiency) than to the performance of the RO issuing the certificates.
IMO conventions and codes clearly assign primary responsibility for the safe operation and proper maintenance of a ship to the ISM Company and the Master, on a continuous basis, while class and statutory surveys are generally carried out at intervals of approximately 12 months.
Against this background, the role of an RO is one of periodic verification and certification rather than day-to-day supervision. It is therefore inconsistent with the RO surveillance framework to assess RO performance as though ROs exercised continuous operational control over ships.
This distinction is particularly important when RO performance is assessed on the basis of PSC detentions. Such detentions may result primarily from operational, maintenance or crew-related deficiencies, areas that fall outside the RO’s direct and continuous control. Assessing RO performance against these outcomes therefore risks conflating fundamentally different responsibilities and scopes of control.
The existing Paris MoU framework itself recognises this distinction by including Company Performance as a separate Ship Risk Profile parameter, based on the detention and deficiency history of ships while under the responsibility of the ISM Company.
This separation confirms that operational management and maintenance performance are distinct from RO certification activities and should not be indirectly transferred to ROs through the new RO performance methodology.
As a result, IACS considers that PSC performance data generated under the new methodology cannot be regarded as a reliable standalone indicator of RO performance.
Many detainable deficiencies are not related to the activities performed by the RO that issued the relevant statutory certificate, while PSC detention rates can be influenced by multiple factors beyond the RO’s control, including the ship’s operational and maintenance practices.
IACS also considers that the methodology used to assign High, Medium and Low performance categories to ROs, based on detention rates compared with the overall average, requires further validation.
Relatively small variations in the number of detentions could have a disproportionate impact on an RO’s classification, particularly for ROs with a limited number of inspections.
Moreover, factors such as fleet age, ship type, trading patterns and exposure to particular PSC regimes may significantly influence an RO’s performance category without necessarily reflecting any change in the quality of its services.
For these reasons, IACS considers that appropriate statistical safeguards should be incorporated into any published RO performance data to ensure that the results are representative, proportionate and do not create a misleading impression of actual RO performance.
The disconnection between future RO performance data based on PSC detentions (those resulting from the application of the new methodology) and the actual RO performance could lead to several potential negative impacts, including:
- ships could be subject to unjustifiably more frequent and extended scope PSC inspections, as the Ship Risk Profile would be determined using PSC performance data not reflecting the actual RO quality;
- ROs could be subject to unjustifiable administrative measures, as administrative sanctions – including fines and suspension/withdrawal of the recognition as an EU RO – could be imposed based on the Paris MoU PSC data which would be incorrectly considered as a source for the evaluation of RO performance;
- maritime industry stakeholders – who currently widely recognize the PSC performance data published by Paris and Tokyo MoU as “reliable information” provided by the public authority – may be led to misconceptions about the role and responsibilities of ROs because the published RO performance data would not realistically reflect the level of RO involvement. Furthermore, ships and companies may be also exposed to a wrong perception associated with the published data;
- Flag States can no longer rely on Paris and Tokyo MoU data on RO performance for selecting and authorizing ROs to act on their behalf, as the PSC performance data would no longer reflect the actual RO performance.
Therefore, until the methodology has been validated over a sufficiently representative period and appropriate review safeguards are in place, data generated under the new mechanism should not be used in decision making and performance assessment of ROs.
The new methodology could inadvertently lead to a shift in enforcement behaviour, as Flag States could require ROs to compensate for deficiencies that, by convention, are the responsibility of shipowners and crew.
Over time, this could alter the balance of the maritime safety regime, pushing ROs into a quasi-operational role that they are neither mandated nor structurally equipped to fulfil.
Such a development would not improve safety outcomes; rather, it would risk creating ambiguity, regulatory arbitrage, and misaligned incentives within the system.
The new RO performance methodology represents a significant regulatory change that could have a substantial impact on Flag States, shipowners and operators, as well as ROs; and its implementation will require all of them to adapt to the new system.
In this regard, IACS is internally discussing ways to address the challenges posed by the new methodology, including for example:
- exploring options available to ROs to initiate an appeal process under the Paris and Tokyo MoU;
- and submission of proposals to strengthen the PSCOs’ qualification (training, selection criteria, performance monitoring) with an objective of promoting consistency, transparency and harmonized implementation of PSC activities.
This would then allow for a more focused discussion of the needed improvements which could possibly lead to the need for a new output).
IACS is committed to supporting effective action against substandard shipping but considers that this cannot be achieved through measures confusing the respective responsibilities of ROs, Flag States, Companies and shipboard management.
"IACS therefore proposes to start an open discussion with all interested maritime stakeholders impacted by the new methodology to ensure that future PSC data remain reliable, proportionate and correctly understood."
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