One such gap is whether remote staff can perform watchkeeping duties. Where previous conventions (namely the 1978 STCW Convention) assume watchkeeping is performed by staff on board the vessel, the guidelines suggest flag states could allow remote staff to perform these duties.
Similarly, a flag state could treat a remote operations centre as a location on board a ship, just as the bridge would be.
Crucially, the code stipulates that if any crew or persons are present on board a vessel, then the master must also be present.
In addition, the code outlines fallback responses that autonomous ships must enter should there be faults either with the vessel itself or with the remote operations centre, including a possible cybersecurity attack.
The MASS Code is, however, not mandatory. A mandatory version is not expected to be adopted until 2032 following an “experience-building phase”.
Orca AI chief executive Yarden Gross, whose company produces autonomous lookout technology, said the guidelines send a relaxed message to the industry.
“When a regulatory body publishes a voluntary code, the message to shipowners is straightforward: this is where things are heading, but you don’t have to act yet.
“For conservative operators weighing investment decisions, that’s often enough to defer action.”
He argued that a human-only watchkeeping baseline means incidents involving AI-equipped vessels would be closely scrutinised, while those involving conventional ships would be treated more normally.
“That asymmetry distorts how the industry reads its own safety record.”
Those that already operating in this space will be the ones that provide data to the experience-building phase, he said.
“That’s not a minor thing — it’s the difference between writing the rules and being handed them.”

