UK updates Polar Code safety rules from 1 Jan 2026

From 1 January 2026, the United Kingdom will apply updated safety rules for ships operating in the Arctic and Antarctic. The Merchant Shipping (Polar Code) (Safety) Regulations 2025-S.I. 2025/1234-were made on 1 December 2025, laid before Parliament on 2 December 2025, and replace the 2021 regulations. This is our clear, student‑friendly guide to what changes and why.

If you are new to the topic: SOLAS is the International Convention for the Safety of Life at Sea, a global rulebook overseen by the International Maritime Organization. The Polar Code sits under SOLAS Chapter XIV and adds extra requirements for ships in polar waters, reflecting the risks of ice, cold and distance from help.

The 2025 Regulations implement recent IMO amendments: MSC.532(107) to SOLAS Chapter XIV and MSC.538(107) to the Polar Code. The headline change is that certain duties now reach smaller vessels. Cargo ships of at least 300 but under 500 gross tonnage, fishing vessels 24 metres or over in length overall, and pleasure vessels of 300 gross tonnage or more must meet new chapters on safety of navigation and voyage planning.

For passenger ships and cargo ships of 500 gross tonnage or more, the full suite of Polar Code part 1‑A safety measures continues to apply. That covers performance standards and operational assessment, the Polar Water Operational Manual, structure, stability, watertight integrity, machinery, fire protection, life‑saving appliances, navigation, communications and voyage planning. What it means: large ships remain under a comprehensive, chapter‑by‑chapter regime.

For the additional categories-cargo 300–499 GT, fishing vessels 24 m+, pleasure vessels 300 GT+-two new Polar Code chapters now bite: chapter 9‑1 on safety of navigation and chapter 11‑1 on voyage planning. They must also, so far as reasonably practicable, meet the general performance standards and conduct an operational assessment under chapter 1. What it means: smaller polar‑going craft must formalise planning and navigational safeguards.

Timing matters. All ships covered by the new rules must comply from 1 January 2026. If a ship in the additional categories was constructed before 1 January 2026, navigation and planning duties start on 1 January 2027. Constructed means the keel is laid or a similar stage where at least 50 tonnes or 1% of the estimated structural mass has been assembled. What it means: check your build date against your duty start date.

Jurisdiction is clear. The Regulations apply to UK ships that operate, or intend to operate, in polar waters, and to non‑UK ships that start or end a voyage in a UK port when that voyage includes polar waters. A non‑UK ship in the additional categories flying an Arctic coastal State’s flag and sailing only in that State’s internal waters and territorial sea while in Arctic waters is outside the UK duties in regulation 11. If a non‑Convention‑country ship enters a UK port solely due to weather or other unavoidable events, the duties do not apply for that call.

There are specific exclusions: ships of war and naval auxiliaries; state‑owned non‑commercial ships; cargo ships under 300 GT; non‑mechanically propelled or primitive wooden ships; pleasure vessels under 300 GT; fishing vessels under 24 metres; and ships sailing only on the Great Lakes and the St Lawrence up to a defined line. What it means: small local craft and government vessels are not within scope.

Documentation is central. A Polar Ship Certificate confirms compliance with the Polar Code safety measures that apply to the ship and must be carried by UK passenger ships and UK cargo ships of 500 GT or more before they proceed to sea for polar voyages. Non‑UK ships leaving a UK port must carry either a Polar Ship Certificate issued by a SOLAS party or, where their flag is not a party, a certificate proving compliance with the applicable Polar Code provisions. Every affected ship must carry and follow a Polar Water Operational Manual, and crews must be familiar with it for their duties.

Ships that require a Polar Ship Certificate face an initial survey before their first polar voyage and then surveys aligned with their regular SOLAS schedule. One useful carve‑out exists: a category C cargo ship may receive a Polar Ship Certificate without a pre‑issue survey if a written operational assessment shows no extra equipment or structural work is needed, although an onboard check is required at the next scheduled survey.

Seafarer training is tightened. Masters, chief mates and officers of the navigational watch on passenger ships and cargo ships of 500 GT or more need certificates of proficiency matched to conditions. Basic training under STCW V/4 is required for service in open waters, while advanced training is required for masters and chief mates in other waters where ice is present beyond the open‑water threshold. A temporary replacement is allowed only if the person holds the right competency and advanced polar training, enough trained crew remain on watch, rest rules are met, and stricter thresholds apply to tankers and passenger ships.

Design flexibility is possible, but only with proof. Owners may propose alternative designs or arrangements for structure, machinery, fire safety and life‑saving equipment if these deliver at least the same level of safety as the Polar Code requires. An engineering analysis is mandatory, the Secretary of State must approve it, and any approved deviation and its conditions must be recorded in both the Polar Ship Certificate and the Polar Water Operational Manual.

The Regulations allow exemptions. A ship that does not normally trade internationally may be exempted for a single exceptional international voyage that enters polar waters, and other exemptions may be given where strict compliance would be impracticable or unreasonable-so long as the result still fits with SOLAS Chapter XIV and the Polar Code. Approvals that the Polar Code assigns to a flag Administration, including sign‑off for means of removing ice, may be given by the Secretary of State or an authorised person.

Non‑compliance with core duties-performance standards, operational assessment, navigation and voyage planning, and following the Polar Water Operational Manual-is an offence. Owners and masters can face fines on summary conviction and, on indictment, up to two years’ imprisonment, a fine, or both. UK authorities may detain a ship where there are clear grounds to believe the Regulations are breached, with notice to the flag Administration. It is a defence to show all reasonable steps were taken to avoid the offence.

This is a lesson in how international standards become UK law. The instrument uses ambulatory references, so future IMO updates to SOLAS Chapter XIV or the Polar Code automatically flow into UK law once they take effect internationally. For study or practice, keep an eye on IMO resolutions, the Maritime and Coastguard Agency’s Marine Guidance Note 637 (M) Amendment 1, and Merchant Shipping Notice 1866 (M) Amendment 2. Day to day, the Polar Water Operational Manual is your playbook on board.

Key definitions matter in exams and in the wheelhouse. Polar waters mean Arctic waters and the Antarctic Area. Open waters have less than 10% sea‑ice and no ice of land origin; other waters are anything more severe, with bergy waters referring to low concentrations of icebergs. Category A and B ships are strengthened for first‑year ice; category C ships operate in open or lighter‑ice conditions. These terms decide the training, equipment and planning thresholds you must meet.

For transparency, the UK Department for Transport confirms these changes in S.I. 2025/1234, signed by the Parliamentary Under Secretary of State for Transport on 1 December 2025 with Treasury consent dated 25 November 2025, and laid before Parliament on 2 December 2025. Our sources are the UK government legislation site and the International Maritime Organization’s resolutions.