Regulation update

Maritime Hull Inspection Code Cycle, 2026: What's In Force, What Just Changed, What's Coming

IACS, IMO, ASNT, ASTM, IMCA, and OSHA each moved on their own clock over the last two years. Here is the edition currently in force for each, what changed since mid-2024, what was adopted for 2028, and how a buyer verifies a vendor is citing the real, current document instead of the code's name.

By Inspection Vendor Index Editorial Team · Published 2026-07-11 · Updated 2026-07-11

Related category: Maritime Hull Inspection & NDT Services

The 2026 baseline: what is actually in force right now

Six bodies govern a hull inspection and NDT scope, and each publishes on a different cycle, so "current" means something different depending on which one a vendor is citing. IACS runs the Common Structural Rules for Bulk Carriers and Oil Tankers (CSR BC&OT), the harmonised rule set that has applied to newbuild oil tankers over 150 m and bulk carriers over 90 m contracted from 1 July 2015 onward. Sitting alongside CSR, the Unified Requirements that actually structure a survey are UR Z10.1 (oil tankers), UR Z10.2 (bulk carriers), UR Z10.4, and UR Z10.5, which define the Enhanced Survey Programme (ESP): an Annual Survey, an Intermediate Survey at 2 to 3 years, and a Special or Renewal Survey every 5 years, each with a progressively deeper hull-examination and thickness-measurement scope. IMO's companion document is the 2011 ESP Code, formally the International Code on the Enhanced Programme of Inspections During Surveys of Bulk Carriers and Oil Tankers, adopted by resolution A.1049(27). This is the instrument the IACS UR Z10 series is built to match, and it is the document a class surveyor is ultimately auditing against. ASNT's baseline is two parallel documents, not one: Recommended Practice No. SNT-TC-1A (2024 edition, with an addendum in effect from May 2025) is the long-standing employer-based framework most NDT shops build their written practice around, while ANSI/ASNT CP-189-2024 is the ANSI-approved standard some employers use instead for a more centrally defined qualification path. A vendor citing "ASNT certification" should be able to say which of the two, and which edition, backs their technicians. ASTM's operative documents for the core NDT methods used in hull work are E164-24 (ultrasonic testing of weldments, approved December 2024), E1417/E1417M-21e1 (liquid penetrant testing), and E3024/E3024M-22a (magnetic particle testing for general industry), all under ASTM Committee E07. That last one is a name buyers should check carefully: the older E1444/E1444M designation still exists and still gets cited from habit, but ASTM has narrowed its scope to aerospace applications only, so a vendor citing E1444/E1444M as the basis for a marine hull magnetic-particle scope is citing the wrong document. Marine-specific coating-inspection practices under Committee F25, including F1130 (inspecting a ship's coating system) and F941 (inspection of marine surface preparation and coating application), are separate documents with their own, generally slower, revision cadence. IMCA's current core diving document is the International Code of Practice for Offshore Diving, at Revision 3.3 (published March 2025), plus a growing library of supporting guidance covering diving-system design, auditing, and inspector qualification, relevant whenever a hull scope includes diver-based underwater survey rather than ROV or drydock work. OSHA's floor is 29 CFR 1910 Subpart T (Commercial Diving Operations) for any diving work, and 29 CFR 1915 Subpart B (Confined and Enclosed Spaces and Other Dangerous Atmospheres in Shipyard Employment) for entry into tanks, voids, and cofferdams during an NDT scope, both of which apply regardless of which classification society or private code a vendor also references.

What changed in the last two years (mid-2024 to mid-2026)

The most consequential shift landed on 1 July 2024: the IMO's amended 2011 ESP Code, carried by resolution MSC.525(106) (adopted November 2022), and the matching IACS UR Z10.1, Z10.2, Z10.4, and Z10.5 revisions, became applicable to any Special or Intermediate Survey commenced on or after that date. Two changes matter operationally: bulk carrier ballast tank coating examination criteria were tightened to match the stricter standard already used on oil tankers, triggering annual inspection once a coating is rated FAIR or POOR, and bulk carriers of 150 m or more with double-side skin void spaces must now undergo coating examinations starting at 20 years of age. Surveys that had already commenced before 1 July 2024 continue under the prior requirements through completion, which is a real source of confusion when a buyer is comparing two vendor quotes for what looks like the same survey type. On the personnel-certification side, ASNT's 2024 edition of SNT-TC-1A carried an addendum that took effect in May 2025, adding restrictions on vision-correcting eye drops before an exam, a requirement that employers actively assess whether third-party reference exams meet their program's requirements, and a requirement that anyone proctoring written exams be trained to do so. The companion CP-189-2024 edition, approved by ANSI in 2023 and published in 2024, added CR, DR, and CT image-interpreter requirements alongside similar clarifications. ASTM's most recently touched document in this set is E164-24, approved December 2024, superseding the 2019 edition of the ultrasonic weldment-testing practice. By contrast, the marine-specific coating standards under Committee F25 have moved far less: F1130 and F941 have gone multiple years between substantive revisions, with recent activity limited mostly to routine reapproval rather than technical change, a useful reminder that "current edition" does not always mean "recently changed." IMCA's diving-focused library turned over on a noticeably faster cycle: the International Code of Practice for Offshore Diving reached Revision 3.3 in March 2025, the Guidance on Auditing of Diving Systems moved to Revision 3.1 in January 2026, and the DESIGN guidance for surface-orientated air diving systems reached Revision 3 in June 2026. IMCA also introduced a new Accredited Diving System Inspector (ADSI) scheme during this window, with dedicated guidance documents covering trainee inspector course requirements and the inspector qualification pathway itself, relevant to buyers who need a diving system independently audited as part of a hull inspection contract.

What is scheduled to change next

The IMO's Maritime Safety Committee met for its 111th session (MSC 111) in May 2026 and adopted amendments to the 2011 ESP Code that introduce Remote Inspection Techniques (RIT) as a recognized survey method, alongside a companion MSC circular with guidelines on how RIT may be used in ESP Code surveys. An RIT is defined as a means of surveying any part of a ship's structure without the surveyor needing direct physical access, a distinct concept from a fully remote survey where the surveyor themselves is not present. The practical detail that matters for procurement timing: these amendments do not enter into force until 1 January 2028. That is close to a two-year runway between adoption and mandatory application, which gives buyers room to evaluate a vendor's remote-inspection capability, drone or crawler-based hull scanning, and ROV-delivered video documentation now, without either party needing to treat RIT as an immediate compliance requirement. Vendors already investing in that capability are positioning ahead of a dated framework rather than reacting to one that has already taken effect. Separately, IACS has a broader review of the Common Structural Rules underway, with an open consultation process for classification societies and industry stakeholders to weigh in on proposed changes. No fixed effective date for the outcome of that review was available at the time of writing, which is itself useful information for a buyer: it means CSR structural requirements for new construction are stable for now, but a vendor's newbuild survey scope references may need revisiting once that review concludes.

Reading a vendor's certification stack correctly

The single most common gap in a hull inspection RFP is treating a governing body's name as if it were a specific, current document. "ASNT-certified" is not a complete statement, because ASNT does not itself certify individuals under SNT-TC-1A; it publishes a recommended practice that an employer adopts into its own written practice, then certifies its own technicians against that written practice. A vendor should be able to state whether their written practice is built on SNT-TC-1A (2024, with the May 2025 addendum) or on CP-189-2024, since the two documents carry different exam-oversight and interpreter-qualification requirements. Where underwater or diver-based work is part of the scope, IMCA membership is only meaningful in combination with a specific, current revision number. "We follow IMCA guidelines" does not tell a buyer whether the diving contractor's system has been audited under the current Guidance on Auditing of Diving Systems (Rev 3.1, January 2026), or under an older revision that predates recent changes to auditor role definitions. OSHA's role is different in kind from the other five: it is the binding US legal floor rather than an industry code a vendor opts into. A vendor operating in US waters or a US shipyard needs a written confined-space entry and atmospheric-testing program under 29 CFR 1915 Subpart B for any technician entering a ballast tank, void, or cofferdam to run NDT, and a compliant diving-operations program under 29 CFR 1910 Subpart T if diving is involved, independent of which classification society's survey type is being supported.

A procurement checklist for staying current without running a compliance department

Buyers do not need to track six standards bodies continuously. A shorter, contractual approach works better than manual monitoring: First, ask for the edition and date behind each code a vendor cites in a proposal rather than the code's name alone, since "SNT-TC-1A" spans multiple editions with materially different exam-oversight rules. Second, if the scope includes an ESP survey (Annual, Intermediate, or Special/Renewal on a bulk carrier or tanker), ask the vendor to confirm explicitly whether the survey commenced before or after 1 July 2024, since that single date determines which ballast-tank coating criteria and void-space examination age triggers apply, and vendors comparing quotes against each other may be quietly assuming different baselines. Third, where diving is in scope, request the specific IMCA code and guidance revision numbers the diving contractor operates under, and confirm their diving-system audit status against the current Guidance on Auditing of Diving Systems revision rather than accepting membership alone as evidence of currency. Fourth, treat the 1 January 2028 Remote Inspection Techniques entry-into-force date as a forward planning marker worth raising with finalist vendors now, particularly if the buyer's fleet renewal or newbuild cycle will still be active past that date, since vendors differ meaningfully in how far along their ROV, crawler, and drone-based inspection capability already is. Fifth, write a code-currency clause into the RFP and the resulting contract that obligates the vendor to notify the buyer within a defined window if any code they cited as their basis of certification or survey methodology is superseded during the contract term. That shifts the ongoing monitoring burden onto the party best positioned to track it, the vendor operating under the code day to day, rather than leaving it with the buyer.

Key takeaways

The IMO's 2011 ESP Code as amended by resolution MSC.525(106), paired with IACS UR Z10.1, Z10.2, Z10.4, and Z10.5, became applicable to Special and Intermediate Surveys commenced on or after 1 July 2024, tightening ballast tank coating criteria for bulk carriers to match tanker standards.
MSC 111 (May 2026) adopted amendments introducing Remote Inspection Techniques into the ESP Code, but they do not enter into force until 1 January 2028, giving buyers a long runway to vet vendor ROV and remote-inspection capability before it becomes a compliance requirement.
ASNT operates two separate current documents, SNT-TC-1A (2024, with a May 2025 addendum) and ANSI/ASNT CP-189-2024, and a vendor's certificate is only as strong as knowing which one, and which edition, their written practice cites.
ASTM's E164-24 (ultrasonic weld testing) was updated in December 2024 and magnetic particle testing for marine work now runs under E3024/E3024M rather than the aerospace-only E1444/E1444M, while marine-specific coating-inspection practices under ASTM Committee F25 have gone years with only routine reapproval, so a current ASTM designation does not always mean a recently changed one.
IMCA's diving-focused code library turned over multiple editions between March 2025 and June 2026 and added a new Accredited Diving System Inspector scheme, relevant whenever a hull inspection scope includes diver-based underwater survey work.

FAQ

Does a hull inspection vendor need to hold certifications under all six of these bodies?

No. The six bodies have overlapping but distinct jurisdiction: IACS and IMO govern the survey framework and are the classification society's and flag state's concern, ASNT and ASTM govern individual NDT technician qualification and testing method, IMCA applies only when diving is part of the scope, and OSHA applies as the binding US legal floor for diving and confined-space work regardless of which private code is also in play. A vendor's relevant certifications depend on the specific scope being procured, not on collecting every credential available.

What is the practical deadline buyers should track for Remote Inspection Techniques (RIT)?

The amendments introducing RIT into the IMO's 2011 ESP Code were adopted at MSC 111 in May 2026 but enter into force on 1 January 2028. Nothing requires a vendor to offer RIT before then, but buyers with fleet or newbuild programs extending past that date have reason to start asking finalist vendors now about their ROV, crawler, or drone-based inspection capability, since vendor readiness varies well ahead of the mandatory date.

How do I verify an ASNT certification a vendor lists on a proposal is actually current?

Ask which document backs it, SNT-TC-1A (2024, with the May 2025 addendum) or ANSI/ASNT CP-189-2024, since these are two different current ASNT documents with different exam-oversight requirements. Then ask for the vendor's internal written practice reference and the technician's Level II or Level III certification record showing the edition it was issued under, rather than accepting "ASNT-certified" as a self-sufficient answer.

Editorial process Compiled from primary standards, codes, and regulatory sources, then adversarially fact-checked against those sources. Not written or reviewed by a licensed engineer or safety professional. Procurement education, not safety or legal advice.

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