Belgium - Specific requirements by the Belgian Administration
Flag instructions relating to statutory surveys
Flag procedural requirements
| Standing requirements | Action by |
|---|---|
| 1- Reporting on entry into class | MOC |
| 2- Reporting on requests for exemptions or interpretations | MOC |
| 3- Reporting on cases of major deficiencies, as per IACS Recommendation No. 98 (Duties of surveyors under statutory conventions and codes) | MOC |
| 4- Pre-authorisation prior to extending statutory certificates | MOC |
| 5- Pre-authorisation prior to issuing conditional certificates | MOC |
| 6- Reporting on detentions | DO-FM |
| 7- Submission of copies of statutory certificates | DO-FM |
| 8- Reporting on class suspension or class modification | MOC |
| 9- Reporting on class withdrawal | DO-FM |
| 10- Single contact point | B&L_CSC(Belgium & Luxembourg Customer Support Center: b&l_csc@bureauveritas.com) |
| 11- Navicert access request | B&L_CSC is to be contacted |
General policy
Single contact point
All correspondence between the Administration (Belgian Maritime Inspectorate / BMI) and Recognised Organisation (RO) is to be channelled through the following single contact point: B&L_CSC.
In particular, with reference to paragraph 4.8.3 of the IMO HSSC guidelines, the Administration’s position is as follows:
In case of a statutory recommendation or observation (PII subject to verification I or II), the Administration is to be consulted through B&L_CSC for such statutory recommendations / observations related to statutory certificates and which cannot be dealt with before the ship departure.
The BMI doesn’t accept that a statutory condition is being dealt with as a class recommendation. The BMI has to be consulted, not notified afterwards, so they can give their agreement or not.
General requirements
(Minutes of “Meeting Class BMI - 24/11/2016 - Antwerp” and Work Matrix)
The general inspection policy by the Belgian Maritime Administration is based on the principle of Corporate Governance. The principles are that every ship-owner flying the Belgian flag is subject to the basic inspection package.
Basic inspection package
The basic inspection package is applicable to all ships flying the Belgian flag. Ships are required to be inspected by the flag state at least once during the validity of the statutory certificates (once in a cycle of 5 years).
In the basic inspection package the ship owner or manager decides when and where the vessel will be submitted to the flag state inspection. When the flag state is performing inspections, audits or surveys, the scope will be that of the statutory certificates, for which the issue has not been delegated to class, within its appropriate time window.
The basic inspection package is incorporated in the delegations, mentioned in the Work Matrix (see The Work Matrix). When the flag state is performing its inspections, audits or surveys, the delegations to class, mentioned in this working agreement, corresponding with the statutory certificates issued by the flag state, will cease to be applicable. This is mentioned for each statutory certificate issued by the flag state, under BMI additional requirements.
As a consequence, when the flag State is attending, Recognised Organisation (RO) automatically loss the delegation of certain surveys (the following delegations are partly suspended but not necessary all of them: surveys for CVD, ISM/ISPS/MLC, safety equipment, safety radio, IOPP, Fitness Gas). The ship owner is responsible to inform Recognised Organisation (RO) about the attendance of the flag or the delegation to Recognised Organisation (RO).
For ISM/ISPS/MLC, when Recognised Organisation (RO) has performed the intermediate audit, it is no longer authorised to perform the renewal audit, unless expressly authorised by the delegated official of the BMI.
When Recognised Organisation (RO) has performed the intermediate survey, it is no longer authorised to perform the renewal survey, unless expressly authorised by the delegated official of the BMI.
Additional inspection package (risk based package)
Additional inspections, audits or surveys, may be imposed by the flag state, to a single ship or a serie of ships, based on the quality and safety performance of a ship owner, ship manager or (a) particular ship(s). The additional inspections, audits or surveys are forming part of control measures, aiming to ensure an increase in quality and safety standards of ships, ship owners or ship managers. The scope of the inspections is decided by the flag state based on the most efficient and effective means to improve the performance. The delegations to class for the additional inspections, audits or surveys are not incorporated in this working matrix (only the basic inspection package is considered in the table of delegation). The additional inspections, audits and surveys are in principle carried out by the flag state, however delegations to class may be granted on a case by case basis, in accordance with the article 4.5 of the Working agreement.
It is the responsibility of the owner or company to ensure compliance with the general inspection policy by the Belgian Maritime Administration as applicable and published. It is also the responsibility of the owner or company to decide the involvement of any concerned party, flag state or RO, in accordance with the principles of the inspection policy.
Electronic Certificates issued by Recognised Organisation (RO)
(BMI Circular 2019/001)
Recognised Organisation (RO) is authorized to issue statutory and class certificates under the authority of the Kingdom of Belgium for the Belgian flagged vessels electronically, in compliance with the requirements of IMO Circular FAL.5/Circ.39/Rev.2 “‘Guidelines for the use of electronic certificates”, as amended.
The requirement that the full term regulatory certificates must be (counter)signed by the Local M&O Manager remains unchanged.
For further information, refer to attached file “2019-001 Use of Electronic certificates issued by the RO on board Belgian flagged vessels - Rev.1”.
Certificates issued by BMI in electronic format (refer to Annex I of Navicert - Manual recognised organisations v1.4 in attached files) shall be endorsed directly into the Navicert system:
https://navicert.mobilit.fgov.be
In order to obtain access, B&L_CSC (+32 3 247 9446) shall be contacted prior attendance on board to create/activate the relevant login for concerned vessel. Full name and e-mail address of the user to be created must be provided in that request, together with Register number and Name of the concerned vessel. This access is personal, in case of change of surveyor a new request for access should be sent.
For further information, refer to attached file “Navicert - Guidelines for endorsements v1.3”.
The full term Load Line certificates normally must be countersigned by BMI. It is no longer a requirement for an electronic full term Load Line certificate to be countersigned by BMI. It must be ensured however that BMI is notified each time a full term Load Line certificate for a Belgian Flagged vessel is issued. In case there is no remark raised by the delegated official of the BMI within 1 month after the notification is sent, the certificate can be considered as countersigned by the delegated official of the BMI. For the paper certificates, the requirement remains unchanged (see also Loadline certificate).
Ships which are destined to be recycled, require, amongst others, a Ready for Recycling Certificate. When this certificate is issued in an electronic format, the above-mentioned requirements related to electronic full term Load Line certificate are valid. For the paper certificates, the requirement remains unchanged (see also Ship Recycling (Regulation (EU) No 1257/2013 and Hong Kong Convention)).
Refer also to below §Issuance of certificates.
Surveys and issuance of certificates
Issuance of certificates
Where Recognised Organisation (RO) has been authorized to issue the certificate, the attending Recognised Organisation (RO) surveyor issues the Interim certificate on completion of the satisfactory survey. Recognised Organisation (RO) Antwerp will then prepare the full term certificate for signature by the Local M&O Manager in Belgium.
The following regulatory certificates are issued only by the designated official of the BMI:
| Statutory certificate |
|---|
| Certificate of registry |
| Certificate of seaworthiness |
| Cargo Ship Safety Equipment Certificate (+ Form E) (1) |
| Cargo Ship Safety Radio Certificate (+ Form R) (1) |
| International Oil Pollution Prevention Certificate (+ Supplement) (1) |
| International Certificate for the carriage of liquefied gases in bulk (GC or IGC) (1) |
| (Inter-)national Tonnage Certificate |
| Minimum safe manning certificate |
| Continuous Synopsis Record (CSR) |
| ISM Safety Management Certificate (SMC) |
| International Ship Security Certificate (ISSC) |
| Maritime Labour Certificate (MLC) (+DMLC Part I) |
| Exemption Certificates |
| Liability certificates and insurances |
| ISM Document of Compliance |
(1) From 1st January 2026, Recognised Organisation (RO) is authorized to issue full term certificates for conventional ships. The transitional measures can be found in Transitional measures for the issuance of full term certificates. |
These certificates are issued only by the BMI. Recognised Organisation (RO) can be authorized to endorse the applicable certificates when a regulatory inspection or audit is carried out by Recognised Organisation (RO) and is executed positively.In the case the designated official of the BMI has carried out the regulatory survey or audit, the relevant certificates will be endorsed by the designated official of the BMI.Recognised Organisation (RO) can only issue a certificate with limited validity of one of these above mentioned certificates when explicitly authorised by the designated official of the BMI. Annex 2 to the Work Matrix provides instructions if this is the case for the referenced certificates and documents.Recognised Organisation (RO) can only extend one of the above mentioned certificates when explicitly authorised by the designated official of the BMI.In principle, all regulatory certificates are issued in English. The Certificate of Seaworthiness and the International Tonnage Certificate are issued in Dutch-English or upon request in French-English.
The Certificate of Seaworthiness is issued when a Belgian ship complies with all the obligations laid down by Belgian, European and international law. It loses its validity if the ship is not considered to be in a safe condition and/or if one of the mandatory (international) certificates contained in the Work Matrix is no longer valid, for whatever reason. Annex 1 and 2 to the Work Matrix set out what is expected of the Recognised Organisation (RO) in terms of delegation and the more specific requirements that Recognised Organisation (RO) should monitor.
Full term of regulatory certificates issued or renewed by Recognised Organisation (RO) and for which Recognised Organisation (RO) is authorized, must be countersigned by the Local M&O Manager.
Recognised Organisation (RO) shall have the right and obligation, if deemed necessary, to suspend and/or withdraw any certificate issued by Recognised Organisation (RO) (see also Withdrawal of certificates). The delegated official of the BMI and the owner and operator of the ship in question shall be informed immediately if any regulatory or class certificates are suspended or withdrawn
National certificates
The CVD (Certitificaat Van Deugdelijkheid) is a paramount national certificate and is issued in a Dutch version (CVD) and in a French version (Certificat de Navigabilité). Both certificates have the same meaning and shall be treated equally. Both certificates shall be endorsed at the same time.
The CVD (Dutch and French version) can only be endorsed when all other statutory certificates have been endorsed following positive surveys. The CVDA survey code has to be selected when the CVD will be endorsed.
If one or more annual surveys are still outstanding, the CVD shall not be endorsed. The surveyor (flagstate or Recognised Organisation (RO)) who carries out the last outstanding annual survey shall endorse the CVD.
As some surveys may have been carried out by the Administration upon owner’s request, the Recognised Organisation (RO) surveyor must, before endorsing the CVD, also verify if any pending surveys have in fact been carried out by the Administration.
Prior the endorsement of the CVD by Recognised Organisation (RO), Recognised Organisation (RO) shall inspect the expiry dates of the “Certificate of insurance or other financial security in respect of civil liability for oil pollution damage” and the “Certificate of insurance or other financial security in respect of civil liability for bunker oil pollution damage”. During the inspections following should be verified: Compliance with the EU Directive 2009/20. This should include the verification of documentary evidence on board of a financial P&I insurance cover. In addition to this the limitations of insurance, in accordance with the article 4.3 of the Directive should be verified.
Prior the endorsement of the CVD by Recognised Organisation (RO), Recognised Organisation (RO) shall ensure that control measures for materials identified as hazardous materials are in place and complied with. And Recognised Organisation (RO) shall also check whether any equipment or structural components containing hazardous materials have been installed since the IHM was prepared.
When the expiry dates are overdue, the BMI shall be informed immediately.
The ASMS survey items BLG001A, BLG001B and BLG001C have been created according to the above and are in the check-list for the CVDA and for BLG001A in all the annual surveys carried out on behalf of BMI.
Exemptions
Exemptions to the applicable instruments shall only be granted by the Flag Administration.
All requests for exemptions / authorisations shall be sent to B&L_CSC, who will forward the requests to the Administration.
The Flag Administration does the first issue of an “exemption certificate”.
If, under special circumstances, the provisions of the applicable instruments or the class rules temporarily cannot be fully met by a ship prior a voyage, but where there is no danger to the ship, the passengers and crew or third parties or there is no danger to the marine environment, the surveyor of Recognised Organisation (RO) shall specify to the Flag Administration, through B&L_CSC, those measures or additional equipment that is available so that the ship can sail to an appropriate port where permanent repairs or rectifications can be made, or where replacement equipment can be fitted. The Flag Administration must approve these measures before they are implemented.
Overdue surveys
If the surveys are not carried out within a time window of 3 months before or after the expiry date, the endorsement of the certificate is not allowed.
Instructions should be requested from the Flag Administration in order to restore the validity of the certificates. In most cases, the necessary inspection will have the scope of a renewal survey.
After satisfactory survey, the relevant certificate is to be endorsed with the comment: “Extensive survey on request by the Administration - Validity restored”.
Withdrawal of certificates
Should the Recognised Organisation (RO) surveyor find that the condition of the ship or its equipment does not correspond with the particulars of any of the certificates or its condition is found to be such that the ship is not fit to proceed to sea without danger to the ship, persons on board or a third party or presents an unreasonable threat to the marine environment, the Recognised Organisation (RO) surveyor shall immediately recommend repairs or corrective actions to rectify the deficiencies.
If the recommended repairs or the corrective actions are not implemented prior departure of the ship, the certificate(s) concerned must be withdrawn pursuant to but not necessarily confined to SOLAS regulation I/6(c) and regulation I/11, MARPOL 73/78 Annex I regulation 4(d), to Load Lines Article 19(3), IMO resolution A.1053(27) §4.7, IMO resolution A.1052(27) §3.7.3, as appropriate. In case a certificate is withdrawn, the flag state shall be consulted, who may decide to detain the ship.
Recognised Organisation (RO) shall advise the master in writing that the certificate(s) is (are) invalid from the date of signature of the letter, and that the surrender of the certificate(s) is requested. The Flag Administration shall be immediately informed and a copy of the letter shall be forwarded to them.
In those cases where deficiencies are identified which cannot be rectified at the port of survey and the ship is found fit to sail under special provisions without danger to the ship, persons on board or a third party or an unreasonable threat to the marine environment to an appropriate repair yard, the surveyor of Recognised Organisation (RO) shall give the master of the ship a letter stating that the certificate(s) is (are) being withdrawn with effect from the date of signature of the letter.
A conditional certificate shall be issued, valid only long enough to permit the ship to proceed to the port where the correction will be made: the maximum validity is two months, except for special instructions by the Flag Administration. The Flag Administration must approve the conditional certificate.
The withdrawn certificate should either be removed from the ship or be placed on board in a closed, sealed envelope in custody and under the responsibility of the master. Only the next attending surveyor who is to carry out the resurvey is authorized to open the sealed envelope.
Notification in case of deficiencies
Detainable deficiencies
When, during the survey, the surveyor found a detainable deficiency, Flag Administration should be informed immediately and relevant instructions from the Flag Administration should be obtained before acting.
The following are considered as detainable deficiencies:
poor condition of important parts of / on the hull, of the drive mechanism or of other important mechanical parts where the strength of the ships, its water-tighness or the drive system are no longer considered adequate to make the journey planned;
rescue equipment, firefighting equipment or radio equipment are missing, broken or unserviceable or function unadequatly;
the ship is overloaded;
the cargo is not sufficiently safely secured;
the lack of the necessary licenses for the crew, as required by the Minimum Safe Maning document;
vessel's no longer meeting the requirements;
other detainable deficiencies as stated in IMO Resolution A.787(19).
Deficiencies
A deficiency is a shortcoming or omission that has not been rectified, and which may be harmful for the safety of the ship. It is to be reported to the Flag Administration. A time window will be set by the (class) inspector or the Flag Administration, within which the deficiency must be rectified.
Accidental damage
Accidental damage should be reported to Flag Administration.
Notification in case of dry dock survey
As soon as Recognised Organisation (RO) is aware of dry dock visits and associated work, repairs and inspections, Recognised Organisation (RO) shall timely inform the Flag Administration, so that he can make the necessary arrangements for organizing his own inspections and surveys.
Validity of certificates
Any certificate with a limited validity, issued following an initial survey or audit and pending the issue of a full term certificate by the BMI, is valid for 5 months. A full term Certificate replaces the certificate with limited validity after 5 months.
Any Interim Certificate for ISM, ISPS or MLC has a period of validity of 6 months after which a full term certificate is issued.
In case of a required or requested extension of the certificate, Recognised Organisation (RO) may extend the period of validity of certificates within the limits given in the relevant conventions or other instruments after having informed and received approval from the designated official of the Belgian Maritime Inspectorate.
The planned surveys (e.g. annual, periodic, interim) must be carried out within a time window as foreseen in the applicable Conventions.
If the required surveys are not carried out during the time window, the endorsement of these certificates shall not be allowed and the validity of the certificate shall cease.
The designated official of BMI must be informed immediately and shall lay down the necessary guidelines in order to restore the validity of the certificate. In most cases, the necessary inspection will have the scope of a renewal survey and will result in the reissue of the appropriate certificate(s).
Remote surveys and audits
A remote survey is a means of survey that enables examination of a ship's hull structure, machinery components and systems, and ship's equipment and/or gathering information and evidence of compliance with applicable requirements without the physical attendance on board of the surveyor. A remote survey must be carried out in accordance with the requirements set out in the latest version of the Assembly Resolution Survey guidelines under the harmonized system of survey and certification (HSSC), more specific paragraph 5.14.
A remote audit must be carried out in accordance with the requirements set out in IMO Resolution A.1188(33) 2023 Guidelines on implementation of the international safety management (ISM) Code by administrations, more specific paragraph 4.8.
In principle, a statutory survey or audit cannot be performed entirely remotely. Only parts of a survey or an audit can be carried out remotely, such as certain verifications of documents.
Remote surveys or audits are in principle only permitted on a case-by-case basis, unless the BMI has issued explicit instructions for specific items authorizing remote verification:
It is only permitted with the express agreement of the BMI,
It can only be accepted for specific additional surveys or audits or for the verification of specific outstanding items.
IMO guidelines are currently being developed. Once these guidelines are adopted, they will have to be taken into account when a remote survey is authorized by the BMI in a specific case.
Transitional measures for the issuance of full term certificates
(Work Matrix see The Work Matrix)
Starting 1 January 2026, Recognised Organisation (RO) is authorized to issue the following full-term certificates for conventional ships:
International Oil Pollution Prevention Certificate,
Cargo Ship Safety Equipment Certificate,
Cargo Ship Safety Radio Certificate,
GC Code International Certificate of Fitness for the Carriage of Liquefied Gases in Bulk,
IGC Code International Certificate of Fitness for the Carriage of Liquefied Gases in Bulk.
The authorization is given in the following cases:
When issuing the first full term certificate after the vessel has been registered under the Belgian flag.
Upon successful completion of the renewal survey.
Existing certificates issued by the BMI remain valid until their expiry dates.
If Recognised Organisation (RO) carries out an intermediate or annual survey relating to such certificate, Recognised Organisation (RO) must endorse the certificate through the Navicert platform upon successful completion of the survey.
Detention / Notification of Incidents
If a ship flying the Belgian flag and classed by Recognised Organisation (RO) is detained in a foreign port by the port State control or any other competent authority, Recognised Organisation (RO), when advised of the detention, shall immediately notify the Flag Administration.
If a ship flying the Belgian flag is inspected in a foreign port by the appropriate port State control and the latter makes remarks about the certificates or class certificates, without resulting in detention, Recognised Organisation (RO), when advised of the remarks, shall immediately inform the Flag Administration.
The company shall notify BMI without delay and as soon as practically possible through the 24-hour available telephone line: +32 473 70 03 53.
Additionally an initial notification in writing shall be sent to:
For further information, refer to attached file “2008-002_notification_of_incidents_to_the_flagstate_-_version_3.0”.
Plan approval
Apart from the work matrix, in case of new buildings, Recognised Organisation (RO) is also authorized to approve on a case-by-case basis plans, drawings and specifications, materials and equipment, calculations, procedures, handbooks, manuals and specific documents. The list is drawn up in cooperation with BMI.
Transfer of class
In cases of transfer of class by a ship flying the Belgian flag from Recognised Organisation (RO) to another recognized organization, Recognised Organisation (RO) shall inform the gaining organization of all overdue inspections, overdue recommendations, conditions of class, operating conditions or operating restrictions issued against the ship. On transfer, Recognised Organisation (RO) shall provide the gaining organization with the complete history file of the ship.
If Recognised Organisation (RO) gains a ship from another losing organization, it can issue or renew the certificates of the ship only after all overdue surveys have been satisfactorily completed and all overdue recommendations or conditions of class previously issued against the ship have been completed as specified by the losing organization.
Prior to the issuance or the renewal of the certificates, Recognised Organisation (RO), as the gaining organization, must advise the losing organization and the designated official of the date of issue or renewal of the certificates and confirm the date, location and action taken to satisfy each overdue survey, each overdue recommendation and overdue condition of class.
The Flag Administration can carry out a control of the manner of the transfer. The way in which the control should be carried out will be determined in consultation with the gaining RO.
The procedures drawn up by the International Association of Classification Societies (IACS) concerning the transfer of class are acceptable for the BMI provided there is no conflict with the requirements above and on condition that the Flag Administration is informed promptly and retains control.
If a ship is not classified by a recognized organization, Recognised Organisation (RO) shall consider this ship as a non-classed ship. Recognised Organisation (RO) shall assemble a complete history file. Before finally issuing the certificates, a joint inspection can be carried out by Recognised Organisation (RO) and the Flag Administration.
Specific requirements for existing ships flying a foreign flag and considering to be registered in the Belgian registry
Any ship flying or intending to fly the Belgian flag must be in full compliance with all international, European and Belgian legislation.
If a ship owner wants to confirm the request of a ship flying another flag to register in the Belgian registry, the ship owner or managing company is obliged to fill in the “Application form for Certificate of Seaworthiness”.
The BMI and Recognised Organisation (RO) shall on a case by case basis and in close consultation decide on procedures and requirements, taking into account IACS Procedural Requirement 28.
The BMI and Recognised Organisation (RO) shall carry out simultaneously the registry survey. All documents regarding liability obligations shall be inspected by the BMI.
Additionally compliance with the Belgian Maritime Legislation is required. A list of Belgian specific requirements can be found in list “Additional requirements for ships flying Belgian flag” (see Vessels below convention size (<500GT) and pontoons).
When a cargo vessel of less than convention size changes to Belgian flag, the equipment must be in compliance with IACS N° 99 Recommendations for the Safety of Cargo Vessels of less than Convention Size, as amended, which are supplemented (or replaced where mentioned explicitly) by the Belgian specific requirements and interpretations set out in “IACS 99 – Belgian specific requirements and interpretations” (see Vessels below convention size (<500GT) and pontoons). Structural items must be in compliance as much as possible. Derogation is only allowed after evaluation by the designated official of the BMI.
All equipment must be in compliance with the Marine Equipment Directive EU 2014/90 as amended and its implementing acts (see European Marine Equipment Directive 2014/90/EC - MED).
For further information, please refer to the Work Matrix which is the Annex to the Agreement (displayed in The Work Matrix).
(Administration email dated 01/03/2024)
Refer to the Belgian specific requirements (in attached file “Belgian specific requirements v. 1.1”) which are valid for all vessels, regardless if they are SOLAS, non-SOLAS or fishing vessels.
New building or extensive modification
(Administration email dated 01/03/2024 and Work Matrix in The Work Matrix)
In case of newbuildings or an extensive modification of an existing vessel, a specific procedure will be provided by the designated official of the BMI. This procedure will define on a case-by-case basis the authorizations of the Recognised Organisation. If Recognised Organisation (RO) becomes aware of any alteration or modification of a major character to a vessel, the Recognised Organisation must notify the BMI as soon as possible.
Refer to the Belgian specific requirements (in attached file “Belgian specific requirements v. 1.1”) which are valid for all vessels, regardless if they are SOLAS, non-SOLAS or fishing vessels.
Ships to be “broken up”
BMI shall be informed through B&L_CSC when Belgian flag ships are destined for breaker’s yard.
BMI circulars
Refer to the summary of valid circulars BMI in the attached file “Summary of current and deleted BMI and CMB circulars.pdf” and to the Administration’s website through:
Legislation - Satisfaction of the Administration - IACS interpretations
The main legislation applicable to Belgian seagoing vessels with a gross tonnage of 500 or more, mainly certified under international conventions, relating to safety, security and the prevention of marine pollution, as well as relating to the seafarers of these vessels can be found in Annex 2 of attached file BMI Circular 2025/002
Most legislation mentioned in this document is also applicable on Belgian seagoing vessels with a gross tonnage of less than 500 and their seafarers.
The list of legislation is not exhaustive.
Instructions and guidance on arrangements that should be “to the satisfaction of the Administration”, are given in Annex 1 of attached file BMI Circular 2025/002. The requirements of this BMI circular must be applied to Belgian ships to which the specific legislation applies and within the framework of the statutory survey and certification.
This BMI Circular explains how the Administration fulfils the “Satisfaction of the Administration” requirement set out in mandatory instruments. Additionally, specific Belgian requirements, which are supplementary to those of the IMO, ILO and EU, are enlisted. This BMI Circular is also used to provide clarification or additional interpretation of legislation in the survey and certification of Belgian ships, and to provide an overview of the specific supplementary Belgian requirements.
While BMI Circular 2025/002 contains requirements applicable to Recognised Organisations, these will not be copied into the Work Matrix (see The Work Matrix). Instead, key obligations are referenced to ensure alignment and clarity.
IACS interpretations must be taken into account, unless otherwise instructed by the delegated official of BMI (e.g. through BMI Circulars or the work matrix) and to the extent that the interpretations are consistent with the international, European and Belgian regulations.
Electronic ship certificates by BMI - Navicert
(Circular 2021/002)
The Belgian Maritime Inspectorate issues as well certificates in electronic format, which is done through the Navicert platform. Those vessels not yet transferred to certificates in electronic format, will still be provided with paper certificates.Where electronic certificates have been issued to a vessel, Recognised Organisation (RO) has to endorse the electronic certificates through the Navicert platform upon successful completion of a survey or audit. Only in a matter of urgency and where it is not possible to add the endorsement electronically in time, the attending surveyor is allowed to print the certificate and sign by hand. At first opportunity, the surveyor has to add the endorsement as well electronically through the Navicert platform.
For further information refer to Circular 2021/002 in attached files.
Lay-up, idle and recommissioning of a seagoing commercial vessel
(Circular 2022/002)
Lay-up and idle
In case of lay-up, a lay-up maintenance plan must be submitted to Recognised Organisation (RO) for approval. A copy of the approved plan must be forwarded to BMI.
The Company must also notify BMI and Recognised Organisation (RO) regarding any changes in the conditions of the idle or lay-up period, such as, but not limited to, location, number of persons on board, changes to the layup maintenance plan, additional requirements from local authorities,…Failure to notify BMI and/or Recognised Organisation (RO) and failure to maintain a safe and secure idle or lay-up period, will be regarded as a major non-conformity for ISM and/or ISPS.
Upon successful completion of an initial lay-up survey by Recognised Organisation (RO) and/or BMI, the vessel’s status is changed to “laid-up”. If this initial lay-up survey is done by Recognised Organisation (RO) on behalf of BMI, a full report has to be submitted to BMI.
BMI requires vessels to remain classed with Recognised Organisation (RO) (i.e. not class suspended) and comply with all applicable Class Rules throughout the entire lay-up period.
If the Company decides to suspend the statutory certificates, the vessel is still subject to an annual lay-up condition survey by Recognised Organisation (RO) and/or BMI. This annual lay-up condition survey must be done during the window which opens 3 months before and closes 3 months after the anniversary date of the statutory certificates.
If the annual lay-up condition survey is done by Recognised Organisation (RO) on behalf of BMI, a full report of this survey must be submitted to BMI together with the request for issuance of a new lay-up Certificate of Seaworthiness (CoS).
(See also specific requirements in Lay-up, idle and recommissioning of a seagoing commercial vessel for ISM and in Lay-up, idle and recommissioning of a seagoing commercial vessel for ISPS)
Recommissioning
The Company must inform BMI and the RO in due time about its intention to bring the vessel back into operation. The Company must propose an action plan for the recommissioning of the vessel, in consultation with the RO and BMI. This action plan must be based on for example, but not limited to, guidance from equipment manufacturers, records of the preservation of the vessel’s machinery, records of the lay-up maintenance plan, reports of the annual lay-up condition surveys,…
If the MLC certificate was cancelled, suspended or expired during the lay-up period, an interim MLC inspection (including an inspection of the accommodation, life-saving appliances, fire detection and fire extinguishing systems,…) must be completed and an interim MLC certificate must be issued by BMI or Recognised Organisation (RO) before seafarers are allowed to be accommodated on board.
In order to get the vessel fully certified, below procedures are to be followed. All mentioned surveys will be performed by BMI and/or Recognised Organisation (RO). BMI’s attendance will be considered on a case-by-case basis, also taking into account the working agreement between BMI and Recognised Organisation (RO):
When all statutory certificates have remained valid throughout the entire lay-up period and all periodical surveys and audits have been carried out within the required window, no additional surveys or audits are required.
When (some of) the statutory certificates have lost their validity or have been suspended, a restoration procedure is to be applied. The extent of this procedure depends on how long the certificates’ validity has been expired or how long the certificates have been suspended. Reference is made to the latest version of the IMO resolution on Survey Guidelines under the Harmonized System of Survey and Certification (HSSC), more specifically ‘5.6 Revalidation of certificates’.
If the recommissioning cannot be completed on the lay-up site, e.g. when dry-docking and/or extensive repairs are required, the Company must contact BMI to apply for an authorisation of departure for a single direct voyage in ballast condition to a suitable repair yard. This authorisation of departure will only be granted upon successful completion of a survey by Recognised Organisation (RO), based on the provisions of IACS Procedural Requirement PR 1C, A.1.8, as amended.
Dry dock
Inspections of the outside of the ship’s bottom in drydock/ afloat of conventional vessels shall be performed according to the applicable paragraphs of the IMO Assembly Resolution “Survey guidelines under the harmonized system of survey and certification (HSSC)”, in its latest version. Where special consideration should be given to ships 15 years of age or over, the BMI shall be consulted for agreement.
Extended drydocking can be taken into consideration, but can only be applied after a ship-specific authorization from BMI.
Cargo ships of less than convention size (< 500 GT) and pontoons registered with Recognised Organisation (RO) in the highest class of their category, require a minimum of two inspections of the outside of the ship's bottom each five-year period of the classification certificate. One such examination is to be carried out in conjunction with the Class Renewal Survey. Reference is made to IACS UR Z3 Periodical Survey of the Outside of the Ship’s Bottom and Related Items. In all cases the interval between any two such inspections should not exceed 36 months. Inspections of the outside of the ship's bottom should normally be carried out with the ship in dry dock. However, consideration may be given to alternate inspections being carried out with the ship afloat. Where special consideration should be given to ships 15 years of age or over, the BMI shall be consulted for agreement.
Alternative design or arrangement and alternative fuels
(Work Matrix in The Work Matrix, Circular 2025/001, Circular 2026/002)
In the case of a newbuilding or an extensive modification involving an alternative design or arrangement, including alternative fuels, the instructions and authorizations for the Recognised Organisation are set out in BMI Circular 2026/002 (attached file).
In the event of a change of flag, the Company shall immediately notify the BMI when an alternative design or arrangement, is included in the certification of the vessel, including alternative fuels.
Following this notification, the BMI will issue specific instructions detailing the actions and documentation required by the shipowner, the operator and the Recognised Organisation.
The BMI will subsequently conduct an evaluation of the vessel and the provided documents. The shipowner and the Company shall take due account of the fact that the BMI requires an adequate amount of time to complete this evaluation. The change of flag may only proceed once the BMI has finalized its assessment and has formally granted its acceptance. It is therefore the responsibility of the shipowner or the Company to initiate the notification process sufficiently in advance to ensure that the evaluation can be completed without causing undue delay to the flag change procedure.
LL 66
Loadline certificate
Exemption Loadline Certificates are issued by the Administration who also approves the stability information.
The full term Load Line Certificate issued in paper version has to be sent to BMI for countersigning (for electronic version see Electronic Certificates issued by Recognised Organisation (RO)).
Multiple load lines
(Circular 2005/005 extracts)
The Load Line marks for the intended voyage must be exhibited and all others painted over before loading cargo.
The stability booklet shall contain information relating to all the freeboards assigned for which a Load Line Certificate has been issued.
The surveyor is to witness each change of marks, verify the correct certificate is exhibited and seal the envelope containing the other certificates. He will carry out an examination of the ship to satisfy himself as to its condition and countersign the official logbook entry.
Master should be advised as follow:
The master must ensure that only one set of Load Line marks and the corresponding Load Line certificate are visible / on display at any one time. The remaining Load Line marks are to be effectively painted out, and the Load Line Certificates, not being used, are to be kept in a sealed envelope under lock and key by the master, who is accountable for the proper use of such certificates
The master is to make an official entry in the ship’s deck log book on every occasion the Load Line marks are changed. Additionally the shipping company should inform the Belgian Maritime Inspectorate each time the Load Line has been changed
When a periodical Load Line inspection is held, the master is to ensure that each set of Load Line marks are verified and that all corresponding Load Line Certificates, including those not on display, are endorsed
Circular 2005/005 is displayed in Circular 2005/005 - Multiple load line assignment and should be handed over with the issued Load Line certificates.
Load line calculations
Calculation of the freeboard must be submitted to the Flag Administration.
Freeboard of dredgers
For a long time, the Administration has taken into account the provisions of Recognised Organisation (RO) Guidance Note NI 144 “Freeboard of dredgers and barges fitted with bottom dump doors”.
The Administration now considers provisions of document DR-67 “Guidelines for the construction and operation of dredgers assigned reduced freeboard” (IMO Circular Letter No. 2285 of 17 January 2001).
SOLAS 74
Cargo Ship Safety Construction Certificate
Endorsement of the certificate: after completion of the inspection with satisfactory results; no comments are allowed on the certificate or supplement.
Copies of the full term certificates must be forwarded to BMI.
Deadweight to be recorded in case multiple load line
(Circular 2005/005)
The Cargo Ship Safety Construction Certificate, issued by the recognized classification society, should show only the greatest deadweight. However a note should be added at the foot of the page, cross referenced by “*” to read “This is a multiple Load Line vessel”.
Doors
All doors that must be closed (SOLAS Chapter II-I, Regulation 25-10-4) must be marked “To be closed at sea”.
Means of escape
An emergency escape hatch from the engine room must lead to a location outside the engine room.
Lifting appliances
(Annex 1 to Circular 2025/002)
With reference to SOLAS II-1/3-13.1.3, the Administration has determined that the requirements of II-1/3-13.2.1 and II-1/3-13.2.4 are not applicable on lifting appliances with an SWL below 1000 kg.
Nevertheless, shipowners and operators are encouraged to apply these requirements on a voluntary basis.
In all cases, the following minimum safety measures shall be applicable:
Each appliance must be permanently and legibly marked with its SWL and documentary evidence of the SWL shall be retained on board.
Shipowners and operators should assess the appliances’ usage and associated risks, and incorporate procedures for inspection, maintenance, and training/familiarization within the Safety Management System (SMS).
Records shall, where applicable, be in compliance with the requirements of IMO Circular MSC.1/Circ.1663.
Furthermore, with regard to lifting appliances with an SWL below 1000kg installed on or after 1 January 2026, these shall be load tested and thoroughly examined by the manufacturer prior installation onboard and provided with a certificate of test.
All records shall be recorded in the Register of Ship's Lifting Appliances and Cargo Handling Gear. The format used shall comply with the requirements of IMO Circular MSC.1/Circ.1663. Formats of the Belgian Recognised Organisations are also acceptable.
Cargo Ship Safety Equipment Certificate
Surveys and issuance of the certificate
Safety equipment initial, renewal, intermediate and annual surveys and endorsement can be performed by Recognised Organisation (RO) surveyors, except when the Flag Administration is carrying out the survey.
Issuance of certificates are performed by the Flag Administration.
Any request for extension of the certificate in accordance with SOLAS Reg. I-14 should be submitted to the designated official for approval. Endorsement for an extension in accordance with SOLAS Reg I-14 may be delegated to Recognised Organisation (RO)
No comments or restrictions are allowed on the certificate or the supplement.
The sick bay and medical equipment and medicines on ships are to be checked as part of the annual inspection concerning the safety equipment (in accordance with ZIR, Appendix XVI and Directive EC 92/2 9)
Safety concerning navigation: emergency steering equipment: on tankers, chemical tankers, gas tankers must be inspected by the designated official.
Amendments related to GMDSS (MSC.496 & 497(105))
To comply with new regulations concerning Safety Equipment and Safety Radio (MSC.496 & 497(105)), a new CSSE with form E and a new CSSR with form R have to be created.
Although new certificates must only be issued after the current certificate is expired, all vessels have to comply fully with the new regulations from 01/01/2024.
In order for the Administration to issue these certificates, the form in attached file (Form CSSE & CSSR) should be completed by the attending Recognised Organisation (RO) surveyor (preferably electronically) during the first visit on or after 01/01/2024 and sent directly to B&L_CSC, for further transmission to the Administration.
Scope of authorization
The Flag Administration retains responsibility over the following inspections, unless stipulated otherwise:
all fire safety equipment
all rescue equipment, plans and arrangements
crew accommodation
passenger accommodation
navigation lights, compasses, navigation equipment and ancillary equipment
The functional testing of emergency control panels / points: locking devices, emergency remote controls, other remote controls (including valves of tanks containing fuel oil and lubricating oil), check of locations for the seawater intakes, discharge points and the inspection of bilges
railings, pilot ladders and gangway
access points, pilot hoisting equipment
drencher and sprinkler systems, mist applicator systems (normal and emergency supply sources)
the functional testing of emergency lighting
a functional test of the emergency pump
plans and specifications (related to stability in damaged condition) concerning the bilge system
certain aspects relating to the hull and the watertight compartments, openings in bulkheads and decks, including the penetration of pipe systems, closure systems of openings in watertight and weather resistant bulkheads, watertight rooms, watertight doors, intact stability and stability in damaged condition, damage limitation plans
Life Saving Appliances
Evaluation, testing and approval of life-saving appliances and arrangements
Service suppliers must be approved and certified by the Flag Administration or the RO according to IMO Resolution A.761(18) and IACS UR Z17.
(For requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear, refer to Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear (MSC 402(96)))
Immersion suits
Carriage
(BMI Circular 2006/001)
The number of immersion suits to be provided in compliance with SOLAS 74, Chapter III, Regulation 32.3 should correspond to the total number of persons indicated in section 2.1 (Total number of persons for which life-saving appliances are provided) of Form E (Record of Equipment for the Cargo Ship Safety Equipment Certificate) and in addition those mentioned under 3) and 4).
A ship shall continue to carry the number of lifejackets required by SOLAS 74, Chapter III, Regulation 7.2, even if the immersion suits onboard are classified as lifejackets.
A minimum of two immersion suits shall be carried for persons on watch for each of the following watch stations:
the navigation bridge
the engine control room
any other manned watch station
A minimum of two immersion suits shall be placed at each remote survival craft station, required in accordance with SOLAS 74, Chapter III, Regulation 31.1.4
The immersion suits shall be so placed to be readily accessible and their position shall locally be clearly indicated using the standard pictograms. The vessel’s safety plan must be updated accordingly as soon as the immersion suits are placed on board. It shall be endorsed only by a BMI-inspector during the first flag state survey after 01/07/2006
The immersion suits should be in compliance with the EU Directive 96/98 on marine equipment, as amended by EU Directive 2002/75, Table A.1, section 1.5 and 1.6
BMI will not grant exemption on Regulation 32.3.2 for ships which are constantly engaged on voyages in warm climates
Inspection / test
No specific national requirements.
Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear (MSC 402(96))
(Circular 2020/001)
This BMI circular provides requirements of the Belgian Maritime Inspectorate (BMI) on the use of Authorized service providers.
A. Original equipment manufacturers
Manufacturers
When acting as service provider for their own equipment, original equipment manufacturers (OEM) are not required to be authorized. However, their personnel need to be certified.
When acting as a service provider for servicing equipment that is not its own, a manufacturer is to be considered as a service provider which must be authorized for the specific mark and type of this equipment.
Original equipment manufacturers no longer in business
In cases where an OEM is no longer in business or no longer provides technical support the Administration may issue, on case by case basis, authorization for a service provider based on their prior authorization for the equipment and/or long-term experience and demonstrated expertise as an authorized service provider.
For such cases only, the Administration must be informed in writing and the Administration’s consent must be obtained prior to the performance of either the annual thorough examinations and operational tests or the five-yearly thorough examinations, overhauls, overload operational tests and repairs. This can be done through the BMI specific email address: Ship.BelFlag@mobilit.fgov.be.
Applications for a case by case authorization, accompanied by the supporting documentation, will be examined only if they are received from the managing company of the ship.
B. Authorized service provider (ASP)
BMI authorized service provider
In case there is no OEM available within a reasonable time frame or reasonable distance, the examination and/or tests have to be done by a service provider authorized by the delegated official of the BMI in accordance with the requirements given in Resolution MSC.402(96).
The updated list with BMI recognised service providers can be found via the following link: https://mobilit.belgium.be/nl/scheepvaart/erkenning_instellingen/service_providers
No BMI authorized service provider available
In case there is no OEM or BMI authorized service provider available within a reasonable time frame or reasonable distance, the examination and/or tests can be carried out by a service provider: a. Which has an authorization directly by another EU member State, and not by their RO, or b. Which has been authorized by a Belgian Recognised Organisation (RO).
No authorized service provider available
In the exceptional circumstances where no authorized service provider is available for the specific make and type of the equipment, the Administration must be contacted: Ship.BelFlag@mobilit.fgov.be.
C. Certificate of Authorization
It is the responsibility of the managing company to ensure that servicing, testing and repairs of the equipment listed above, is carried out only by authorized service providers holding a valid Certificate of Authorization. Authorization is limited to each make and type of equipment to be serviced.The Administration considers an Approval of Service Supplier (AoSS) certificate referring to IACS UR Z17 as amended / Rev.14 as equivalent if it is supplied by a Belgian Recognised Organisation as IACS UR Z17 Rev.14 corresponds to IMO Resolution MSC.402(96).
Evidence of authorizations shall be made available on board to surveyors.
D. Service personnel
The certification process and programme of service personnel shall comply with requirements of the IMO Resolution MSC.402(96) for each make and type of the equipment for which service is to be provided.
Service personnel shall be individually certified by the OEM or by an Authorized Service Provider for each make and type of the equipment to be worked on, as well as for the specific work activities to be carried out, such as annual or five-yearly inspections. Completion of relevant education and training, including a competence assessment using the equipment for which the personnel are to be certified, is a prerequisite for certification.
E. Annual and five-year thorough examination and operational tests
The thorough examinations and operational test of lifeboats, launching appliances and on-load release gear shall be carried out at the annual surveys required by regulations I/7 or I/8, as applicable. Reference is made to SOLAS Ch III, Reg. 20.11.Five-yearly thorough examination, any overhaul, overload operational tests and repairs shall be conducted by certified personnel of the OEM or of an authorized service provider. This shall be done in the presence of an RO surveyor and/or a BMI inspector (MSC.1/Crc.1618).
For further information, refer to attached file “2020-001 Authorized Service Providers - Rev. 1.1”.
Communication
Sound levels in engine rooms must be measured during the test journey according to IMO Resolution A.468(XII).
An efficient communication system should be fitted between the bridge and the captain’s cabin.
A “dead man’s alarm” should be fitted for engine rooms manned by one person.
Fire fighting
A fire safety station (SOLAS Chapter II, Regulation 5.2.3.1) comprises the controls of the fire-extinguishing systems and the closing devices. Some closing devices must be duplicated in different locations depending on the judgment of the designated official.
The fuel supply systems for main engines and auxiliary engines must be fitted which separate quick-closing valves.
Operating handles for the safety and fire-extinguishing equipment must be painted in red colour.
Nautical equipment
(SOLAS Chapter V, Regulation 5)
The vessel must be equipped with the necessary instruments for the collection of meteorological data.
Approval of inflatable liferafts subject to extended service intervals not exceeding 30 months
(Circular 2015/002)
The purpose of this Circular 2015/002 is to inform all parties concerned that the Belgian Maritime Inspectorate has approved specific inflatable liferafts packed for extended service intervals according to SOLAS 74 Regulation III/20.8.3, to be installed on board of the Belgian flagged vessels. These approved liferafts and their manufacturers can be found in annex of this Circular.
Medical equipment
The sick bay and medical equipment and medicines on ships are to be checked as part of the annual inspection concerning the safety equipment (in accordance with ZIR, Appendix XVI and Directive EC 92/29).
Fire control and safety plans
(Work Matrix in The Work Matrix)
From 1 January 2026 Recognised Organisation (RO) is authorized to approve the fire control and safety plans of conventional ships for all new plans issued on or after that date, as well as for all amended plans that require approval.
Once Recognised Organisation (RO) approves a plan, Recognised Organisation (RO) must validate all its pages and send it to the BMI together with the letter of approval and (if any) any conditions.
The BMI reserves the right to fully review the submitted plan and to make comments which may result in changes to this plan.
Cargo Ship Safety Radio Certificate
Survey and issuance of the certificate
Safety Radio initial, renewal and annual surveys and endorsement can be performed by Recognised Organisation (RO) surveyors, except when the Flag Administration is carrying out the survey.
Any request for extension of the certificate in accordance with SOLAS Reg. I-14 shall be submitted to the designated official for approval. Endorsement for an extension in accordance with SOLAS Reg. I-14 may be delegated to Recognised Organisation (RO).
Issuance of certificates are performed by the Flag Administration.
The surveys always includes the verification of the validity of the “radio station license” certificate, the land-based contract (if appropriate), and the GOCs (Global Operating Certificates) that are required in connection with the radio certificate and the Minimum Safe Manning certificate.
The on-board equipment must comply with Directive 14/90/EC, as amended.
Amendments related to GMDSS (MSC.496 & 497(105))
Refer to Amendments related to GMDSS (MSC.496 & 497(105)).
(Annex 1 to Circular 2025/002)
For SOLAS ships constructed before 1 January 2024, provided that no new GMDSS radio equipment is installed on board after this date, the Administration accepts that ships operating only occasionally in sea area A4, which originally installed an MF/HF radio installation, may, instead of the additional MF/HF radio installation, be equipped with any recognised mobile satellite service ship earth station (SES), even without coverage of sea area A4, complying with the requirements of SOLAS regulation IV/10.1.1. In such cases, the provisions of IMO Resolution A.702(17), concerning radio maintenance guidelines for the Global Maritime Distress and Safety System applicable to sea areas A3 and A4, shall apply.
Where the above is applied, the following remark must be provided on the Cargo Ship Safety Radio Certificate:
“The vessel is operating in sea area A4 only occasionally. The provisions of Res. A.702(17) §2.1.2 have been applied for the duplication of equipment.”
Passenger Ship Safety Certificate
Reserved.
Others
Safety valves
Any steam boiler & steam generator must be fitted with two safety valves, which ensure that before overpressure of 5% is reached, every safety valve can release the steam.
IGC and IBC / BCH code
In case of new building, Recognised Organisation (RO) and the designated official should jointly set up a “specific new building procedure” specifying the extend of the delegation.
Any deviation from the list of products that may be transported must be submitted to the designated official for approval.
IGC Code - Surveys and Certificate
Initial, renewal, intermediate and annual surveys and endorsement can be performed by Recognised Organisation (RO) surveyors, except when the Flag Administration is carrying out the survey.
Issuance of certificates are performed by the Flag Administration.
Bulk carriers
Software & input of stability data of the loading computer should be approved by Recognised Organisation (RO) together with results of shear forces & bending moments.
Electronic and digital nautical publications
(Circular 2016/001)
Electronic versions of nautical publications are allowed on board of ships which sail under Belgian Flag if they comply with the requirements as specified in Circular 2016/001.
However hard copies of the “International Code of Signals” and the “IAMSAR Manual Volume III” are to be available on board at all times.
IP Code
(Refer to Annex 2 of Work Matrix in The Work Matrix)
Grandfathering provisions for obtaining IP certification are provided in SOLAS XV/3.2 and 3.3. The Administration will issue a formal Statement for the vessels which are eligible to make use of this grandfathering principle, confirming they are authorized to carry industrial personnel based on the recommendations developed by the organization (Res.MSC.418(97)) and meeting the provisions of the 2008 SPS Code. Only for those vessels the grandfathering provisions can be applied.
All applications for exemptions must be submitted to BMI. The shipowner or yard shall send all applications for exemption to BMI as soon as possible, together with all relevant information on the conditions for exemption and the advice from Recognised Organisation (RO). BMI will assess the applications for exemption and is the sole authority to decide whether or not the exemption can be granted.
During surveys, Recognised Organisation (RO) must check each time that the conditions and requirements for exemptions as stated on the certificate are still met.
For the initial and maintenance surveys pertaining to SOLAS chapter XV and the IP Code, IMO Circular MSC.1/Circ.1680 Unified interpretations of SOLAS Regulation XV/5.1 and paragraph 3.5 of part 1 of the international code of safety for ships carrying industrial personnel (IP CODE) on the harmonization of the industrial personnel safety certificate with SOLAS safety certificates must be taken into account.
MARPOL 73/78
Annex I - IOPP certificate
Surveys and issuance of the IOPP certificate
IOPP initial, renewal, intermediate and annual surveys and endorsement can be performed by Recognised Organisation (RO) surveyors, except when the Flag Administration is carrying out the survey.
Issuance of certificates are performed by the Flag Administration .
In addition, when a survey is carried out, the validity of the following certificates confirming financial security, shall be verified:
Certificate of insurance or other financial security in respect of civil liability for oil pollution damage (applicable to ships carrying 2000 T or more of oil as cargo)
Certificate of insurance or other financial security in respect of civil liability for bunker oil damage.
Annex II - NLS certificate
Any deviation from the list of products that may be transported must be submitted to the designated official for approval.The SMPEP should be approved by the Flag Administration.
Annex IV - ISPP certificate
Within the validity period of 5 years, one intermediate survey is required.
The intermediate survey should take place at the 2nd or 3rd anniversary date of the SAFCON.
Annex V
Regulations for the prevention of pollution by garbage from ships
Reserved.
Annex VI - IAPP, EIAPP and IEE certificates
IAPP and EIAPP certificates
Ships constructed before 19 May 2005 shall be issued with an IAPP certificate no later than the first scheduled drydocking after 27 May 2006 but in no case later than 27 May 2009
Ships constructed between 19 May 2005 and 27 May 2006 shall be issued with an IAPP certificate no later than 27 May 2009
Details on IAPP certificate: in compliance with MARPOL Annex VI, as amended
Copies of IAPP certificate: to be forwarded to BMI
Extension of IAPP certificate: any extension shall be requested to BMI and can only be granted by BMI. The endorsement of the extension may be granted to Recognised Organisation (RO).
Copies of “Supplement to IAPP certificate” : to be forwarded to BMI
VOC
(Email from the Administration dated 05/10/2012)
On request, BMI may consider granting delegation to Recognised Organisation (RO) on a case by case basis for the approval of VOC management plans.
IEE certificate
As per the Work Matrix, Recognised Organisation (RO) is fully delegated to carry out the initial survey and to issue the IEE certificate at this survey.
In the case when a conversion of the ship is planned (not necessary a major conversion of a new or existing ship), Recognised Organisation (RO) shall inform BMI. The BMI decides on a general or partial survey. (Reference: Resolution MEPC.203(62), Chapter 2, new paragraph 4.)
Recognised Organisation (RO) shall at all times inform the BMI regarding the time and place of the verification of the attained EEDI.
Each ship shall keep on board a ship specific SEEMP. This may form part of the ship’s Safety Management System (SMS). The SEEMP can be developed by the ship’s owner or on behalf of the ship’s owner;
The SEEMP must be on board ALL ships (existing and newbuildings);
Fixed and floating platforms (including floating production and / or storage units) and drilling rigs, regardless if self propelled or non-self propelled, are excluded from carrying a SEEMP on board;
SEEMPs are to be written in the working language understood by ship’s personnel AND in English if the working language is not English;
SEEMPs are required to be carried on board not later than the first intermediate or renewal survey of the IAPP certificate, whichever occurs first, on or after 1 January 2013; there is NO relation between the SEEMP and the IAPP certificate except to references of the dates of surveys.
Recognised Organisation (RO) shall check that the SEEMP is on board : not later than the first intermediate or renewal survey of the IAPP certificate, whichever occurs first, on or after 1 January 2013.
The lack of a SEEMP on board during the first intermediate / renewal survey of the IAPP certificate does not impact the validity of the IAPP certificate as there is no interrelation. The lack of a SEEMP shall be reported immediately to the BMI.
The lack of a SEEMP can give cause to detention by PSC.
Data Collection System for fuel oil consumption of ships
(Administration email dated 05/12/2018)
Recognised Organisation (RO) is authorized to perform the following statutory services:
Reviewing of SEEMP Part II and issuance of Confirmation of Compliance, (MARPOL Annex VI, Regulation 5, para. 4.5)
Verification of reported data, (MARPOL Annex VI, Regulation 22A) and Issuance of Statement of Compliance (MARPOL Annex VI, Regulation 6)
Submission of reported data to the IMO Ship Fuel Oil Consumption Database (MARPOL Annex VI, Regulation 22A, para. 9)
The Recognised Organisation performing the necessary tasks for DCS does not necessarily need to act as Recognised Organisation for the issuance of the regulatory certificates.
Additional information from the Administration (email dated 15/10/2020)
Reporting duties in case of change of flag and/or ISM Company
Change of flag + change of ISM Company
Fuel oil consumption data must be reported as soon as possible to the losing Administration (in case of Belgium, the data must be sent to the RO) for verification. BMI requests to do this within one month and to forward us the confirmation receipt of the RO. It is not specified whether this should be done by the previous or the new ISM Company.
Change of flag (without change of ISM Company)
Fuel oil consumption data must be reported as soon as possible to the losing Administration (in case of Belgium, the data must be sent to the RO) for verification. BMI requests to do this within one month and to forward us the confirmation receipt of the RO.
Change of ISM Company (without change of flag)
Fuel oil consumption data must be reported as soon as possible to the losing Administration (in case of Belgium, the data must be sent to the RO) for verification. BMI requests to do this within one month and to forward them the confirmation receipt of the RO. It is not specified whether this should be done by the previous or the new ISM Company.
Lay-up
MARPOL has no specific guidelines for vessels in lay-up. Therefore the Administration considers that the reporting period continues throughout the lay-up, meaning that submitting/verifying data and issuance of the Statement of Compliance continue as per standard procedures.
Use of EGCS (scrubbers)
(Meeting Class BMI – 28/11/2018)
Following the revised Annex VI of MARPOL and the revised NOx Technical Code imposing new limits for sulphur content in fuel oil, BMI accept the use of Exhaust Gas Cleaning System (EGCS) as an alternative compliance method.
The use of EGCS is subject to:
Approval under EU 2014/90 (MED)
The installation of EGCS must be notified to BMI
For ships where EGCS is fitted to main engine but not to auxiliary engines:
As from 01/01/2020, special attention is to be paid to the risk of using high sulphur fuel on high seas for auxiliary engines without possibility to detect
Special attention is to be paid to procedures and records during surveys
Any possible violation must be notified immediately to BMI
The BMI may consider not allowing scrubbers unless for full and entire power plant.
EEXI verification
(Administration email dated 15/09/2021)
BMI authorises Recognised Organisation (RO) to perform the necessary verifications, surveys and certification regarding EEXI on his behalf. BMI hereby refers to Res. MEPC.334(76) 2021 Guidelines on survey and certification of the Energy Efficiency Existing Ship Index (EEXI).BMI requires that the entire process is done by the RO that classes the vessel.BMI do not allow the involvement of another RO than the RO that classes the vessel as this may lead to misunderstandings and delays in certification.
Shaft / Engine Power Limitation System (EPL)
The requirements of paragraph 3 of IMO Resolution MEPC.335(76)14, as amended, must be applied. The amendments of IMO Resolution MEPC.335(76) can be found on the “Index of MEPC Resolutions and Guidelines related to MARPOL Annex VI” under Guidelines and guidance on the carbon intensity of international shipping.
Reference is made to IACS Recommendation No. 172 EEXI Implementation Guidelines to the extent that this Recommendation is consistent with the requirements of Resolution MEPC.335(76), as amended.
In case of having used a power reserve as defined in IMO Resolution MEPC.335(76), as amended, the ship should without delay notify Recognised Organisation (RO) and the competent authority of the relevant port of destination with the information recorded in accordance with paragraph 3.2 of the aforementioned resolution. When receiving this notification, Recognised Organisation (RO) must verify that the required notifications have been done in a timely manner and contain all required information.
The reactivation or replacement of the SHaPoLi / EPL system following the use of the power reserve in relation to scheduled engine maintenance and/or performance testing, must be confirmed and supported by documentary evidence such as OMM log extracts and photographic evidence, by the Master or operator of the vessel, to Recognised Organisation (RO) at the earliest opportunity. Recognised Organisation (RO) shall review all documentary evidence submitted, to verify the satisfactory reactivation or replacement of the SHaPoLi / EPL system. Such verification may, if so required, extend to an occasional survey, which may be undertaken via established remote survey means.
During each IAPP survey, Recognised Organisation (RO) shall physically verify whether the SHaPoLi/EPL system has been activated and ensure that the required notifications have been made. If this is the case, Recognised Organisation (RO) shall confirm that this event has been recorded in both the bridge and engine room logbooks, even if the override was pre-emptively activated but the power reserve was not subsequently used. Recognised Organisation (RO) shall also physically verify whether the SHaPoLi/EPL system has been reactivated or replaced. In the event that the power reserve has been used, Recognised Organisation (RO) shall verify the following:
Recognised Organisation (RO) and the competent authority of the relevant port of destination were notified without delay, with the information recorded in accordance with paragraph 3.2 of IMO Resolution MEPC.335(76), as amended.
Documentary evidence has been provided to Recognised Organisation (RO) to verify the satisfactory reactivation or replacement of the SHaPoLi/EPL system.
Recognised Organisation (RO) must on an annual basis by 30 June every year report to the IMO Secretariat, the uses of a power reserve over a 12-month period from 1 January to 31 December for the preceding calendar year, with the information recorded in accordance with the relevant guidance in the Guidelines. Format for reporting shall be according to IMO Circular MEPC.1/Circ.908 Format for reporting to the Organization uses of a power reserve.
The report shall cover vessels, with an IEE-certificate issued by Recognised Organisation (RO), having used power reserve in the mentioned period.
The report shall be sent toghg@imo.org with Ship.Belflag@mobilit.fgov.be in copy.
CII
BMI authorises Recognised Organisation (RO) to perform the necessary verifications of SEEMP for required information regarding CII and to issue the Confirmation of Compliance.
Full delegation is given to Recognised Organisation (RO) for transfer of data to the IMO regarding CII.
Recognised Organisation (RO) shall notify the Administration once all required actions related to a ship rated as E, or rated as D for three consecutive years, have been completed.
This single notification shall confirm that:
the ship has obtained an E rating or three consecutive D ratings; and
Recognised Organisation (RO) has reviewed and approved the revised SEEMP Part III, including the corrective actions addressing the rating.
No submission of the corrective action plan or the SEEMP Part III is required, unless explicitly requested by the Administration.
The Recognised Organisation performing the necessary tasks for CII does not necessarily need to act as Recognised Organisation for the issuance of the regulatory certificates.
SEEMP Part III - Company audit
(Work Matrix in The Work Matrix)
Recognised Organisation (RO) should, in accordance with MARPOL Annex VI Regulation 26.3.3, perform periodical company audits to:
verify that the SEEMP for which the Confirmation of Compliance has previously been issued complies with regulation 26.3.1 and, in the case of non-compliance, require remedial action.
confirm that the ship is being operated in accordance with SEEMP part III, regardless of its rating;
verify the progress made in the (corrective) actions to be taken in the execution of the three-year implementation plan and the plan of corrective actions;
verify self-assessment and improvement of actions taken; and
verify the assignment of responsibilities related to the implementation and monitoring of measures.
The periodical company audits may include audits of the company (company audits) and verifications on board the ship (shipboard audits). These company audits may be conducted remotely unless they are combined with an ISM audit.
A follow-up action may include additional company or shipboard audit(s), as appropriate, to verify that corrective actions have been properly implemented.
Each Company must undergo an audit at least once every three years. The three-year cycle is the SEEMP Part III revision cycle associated with the ship(s). The first cycle of which started on 1 January 2023 for ships delivered prior to 1 January 2023.
SEEMP audit and ISM audit are two distinct activities and date of conducting both audits may differ. General purpose of the SEEMP audits is to verify the implementation aspects: monitoring, self-evaluation and improvements, etc. The SEEMP audit and ISM audit may be carried out during the same visit as combined audit, when the Recognised Organisation is also authorized for the ISM audit and by suitably qualified persons for each activity.
Once a year, before 1 February, Recognised Organisation (RO) must send the BMI the reports of the company audits carried out during the previous year.
Electronic Record Books
(Circular 2022/003)
The Administration accepts the use of electronic record books on board of Belgian vessels for record keeping requirements related to the International Convention for the Preventions of Pollution from Ships (MARPOL Convention) and the NOx Technical Code 2008.
Where the approval of the above-mentioned electronic record books is to be carried out, it will consist of type approval of the software and a subsequent installation survey on board.The type approval of the software for these electronic record books needs to be approved based on the IMO guidelines, including additional optional specifications for improved non-repudiation:
by another EU member State, and not by their RO, or
by a RO. An RO can’t approve its own software application.
The list of RO can be found in annex of the Circular 2022/003.
During the installation survey on board, Recognised Organisation (RO) will assess the electronic record book against the IMO guidelines. On successful verification as meeting these guidelines when installed on board, Recognised Organisation (RO) issues a “Declaration of MARPOL Electronic Record Book” in accordance with the Appendix to MEPC.312(74). A copy of this declaration must be kept onboard the ship.
BWM Convention
Ballast Water Management Plan
The BWM plan shall be approved by Recognised Organisation (RO).
Challenging Water Quality (CWQ)
(Annex 1 to Circular 2025/002 and Work Matrix)
For ships conducting ballast operations in areas with Challenging Water Quality (CWQ), the BWM Plan must be approved by Recognised Organisation (RO) in accordance with IMO Res. MEPC.387(81), including amendments.
De-harmonisation of IOPP certificate
(Report Meeting Class BMI - 24/11/2016)
The Administration allows the ship-owners to disharmonise the IOPP prior their agreement on a case by case basis. The request shall be submitted by the manager/owner directly to the Administration with copy to Recognised Organisation (RO) Belgium & Luxembourg.
The only requirement is to maintain the anniversary dates since these cannot be changed.
The Administration only allows the renewal survey to be carried out in the next three months following the anniversary date (not the prior three months).
Re-harmonisation of IOPP certificate
(Email from the Administration dated 03/08/2017)
Upon request to BMI and on a case by case basis, the de-harmonization of the IOPP of any Belgian flagged vessel, can be undone and the IOPP can be reinstated in its original validity period, re-harmonized with the other statutory certificates. In that case, the IOPP renewal survey previously carried out, will be changed to an annual survey.
Such request for re-harmonization shall be sent by the shipping company to the central BMI contact ship.belflag@mobilit.fgov.be. BMI will take the appropriate actions to re-instate the original certificate and inform Recognised Organisation (RO).
For further information, refer to attached file “BMI_Re-Harmonisation_IOPP”.
Unmanned vessels that discharge ballast water to reception facility
An international BWM certificate is to be issued indicating:
in the field “Method of Ballast Water Management used”: discharge ballast water to a reception facility designed in accordance with MEPC.153(55)
the fields “In accordance with regulation D-1”, “In accordance with regulation D-2” and “In accordance with regulation D-4” shall remain empty
Non-applicability to the BWM Convention
(Email from the Administration dated 21/02/2022)
The regulations for non-applicability to the BWM Convention according to the Administration, for all vessels, is as follows:
All BW intakes must be blinded or sealed.
All BW discharges must be sealed (not blinded), pumping fixed ballast overboard must be possible in case of emergency. This sealing also includes all discharges on deck (cf. Bear)
An ISM procedures must be made up to assure proper traceability of the seal numbers of the seals used for sealing off the ballast valves. Follow up must include eventual change in volume of fixed ballast, during docking maintenance etc., eventual changes of seals including seal numbers and any other changes in the fixed ballast system. ISM procedure to be presented to the Administration.
Final drawing of the fixed ballast system, including the indication of seals/blanks to be presented to the Administration.
Recognised Organisation (RO) must perform a survey for checking implementation of the ISM procedure and the proper sealing of the valves according to the approved drawing.
A statement of non-applicability with the BWM Convention will be made up by the Administration, upon receiving the ISM procedure, the drawing of the fixed ballast system and the survey report from Recognised Organisation (RO).
Electronic Ballast Water Record Book
(Circular 2023/001)
The BMI accepts the use of electronic record books on board of Belgian vessels for record keeping requirements related to the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004 (BWMC).
Where the approval of the above-mentioned electronic record books is to be carried out, it will consist of type approval of the software and a subsequent installation survey on board.
The type approval of the software for these electronic record books needs to be approved based on the IMO guidelines, including additional optional specifications for improved non-repudiation:
by another EU Member State, and not by its Recognised Organisation, or
by a Belgian Recognised Organisation (RO). An RO can’t approve its own software application.
During the installation survey on board, Recognised Organisation (RO) assesses the electronic record book against the IMO Resolution MEPC.372(80) ‘Guidelines for the use of electronic record books under the BWM Convention’.
On successful verification as meeting these guidelines when installed on board, Recognised Organisation (RO) issues a “Declaration of BWM Convention Electronic Record Book” in accordance with the Appendix to IMO Resolution MEPC.372(80). A copy of this declaration must be kept on board the ship.
The management of these electronic record books must be documented in and controlled through the Safety Management System (SMS), as described in section 11 of the International Safety Management Code (ISM Code). For vessels which are not subject to the requirements of the ISM Code, the same principles of a controlled document system have to be applied for the use of these electronic record books.
AFS Convention
AFS Certificate & Record
A copy of the International Anti Fouling System Certificate and of the Record of AFS shall be forwarded to the Administration.
Tonnage 69
Untitled
Tonnage calculation in the event of a modification must be submitted to the Flag Administration.
The Administration in its email dated 15/10/2021 has confirmed that full delegation is granted to Recognised Organisation (RO) for calculation and issuance of Panama and Suez Canal Tonnage Certificates.
The limited authorisation for the National and International Tonnage Certificate remains, although in practice these certificates are always issued by the Administration.
ILO Conventions
Accommodation
Surveys according to ILO 92, 133 & 147.
ILO 32 and 152
(Work Matrix in The Work Matrix)
Belgium has strictly speaking only ratified ILO 32, but ILO 152 is applicable to Belgium flagged ships.
The Administration allows to have annual surveys to be performed within an annual survey window (between 3 months before and 3 months after each anniversary date of the documents), instead of one year after the date of last survey.
Ship lifting gear and appliances are subject to a full survey every 5 years. The full survey shall be carried out within the window period of the renewal of the “Cargo Ship Safety Construction Certificate”.
Miscellaneous technical requirements
Lifting gears and elevators
Recognised Organisation (RO) has the specific authorization to issue certificates and carry out the surveys concerning lifting appliances, loading equipment, elevators for personnel and cargo (cargo ships and passenger ships + inspection book).
Ship lifting gear and appliances are subject to a full survey every 5 years. It should be carried out within the window period of the safety construction renewal survey.
The certificates must clearly state, “use at sea” or “use in port”.
The “Certificate of fitness of lifting appliances and elevators of passenger and cargo ships” must be endorsed or reissued by Recognised Organisation (RO) surveyor after the annual survey has been carried out with satisfactory results.
The “Cargo Gear Book” must be signed by Recognised Organisation (RO) surveyor after the annual survey has been carried with satisfactory results.
European Marine Equipment Directive 2014/90/EC - MED
Refer to Statutory surveys - General, Section 7 & 8.
In case of new building, an extensive modification, or an existing ship to be registered in the Belgian registry, a specific instruction and authorization will be provided by the designated official of the BMI with the procedure to be followed by Recognised Organisation (RO) to verify compliance with the MED Directive.
When Recognised Organisation (RO) carries out an inspection on board a ship flying the Belgian flag to endorse or renew the certificates as required by the international conventions, Recognised Organisation (RO) shall ensure that the marine equipment on board the ship complies with the requirements of the MED Directive. The issuance or endorsement of the relevant certificates is considered as conformation that MED compliance is checked.
Recognised Organisation (RO) sees to it that the marine equipment falling under MED, bears the wheel mark and that the EC Document of Conformity for the specific MED equipment with the underlying certificates is onboard. These documents may be placed onboard in an electronic format.
Where it is proven or strongly suspected that MED equipment placed on board Belgian ships is not in compliance with MED Directive and/or the relevant IMO performance and test standards applicable, the delegated official of the BMI needs to be informed. Recognised Organisation (RO) is requested to include as many documented evidence as possible: failed test results, suspected fraudulent conformity documents/wheelmarks, photographs etc.
Special Purpose Ship (SPS) Code
Recognised Organisation (RO) may be authorized on a case-by-case basis (limited authorization) to carry out initial, annual and renewal survey and to issue, renew and endorse the certificate.
The requirements as per MSC 266 (13), SPS Code 2008, shall be applicable to new ships from 13 May 2008, and to existing ships, applying for SPS notation, 13 May 2010.
Ship Recycling (Regulation (EU) No 1257/2013 and Hong Kong Convention)
(Work Matrix in The Work Matrix)
Recognised Organisation (RO) is authorized for new buildings and during the lifetime of the vessel:
to verify the Inventory of Hazardous Materials (Part I)
to carry out all required surveys and to issue the Certificate on Inventory of Hazardous Materials
When a ship is intended to be recycled, Recognised Organisation (RO) is authorized on case-by-case basis:
to verify the Inventory of Hazardous Materials (Part II and III)
to carry out the required final survey and to issue the Ready for Recycling Certificate. The paper version of certificate must be countersigned by BMI (for electronic version see Electronic Certificates issued by Recognised Organisation (RO)).
The RO performing the necessary tasks for ship recycling does not necessarily need to act as RO for the issuance of the regulatory certificates.
Hong Kong Convention
Until the entry into force of the HK Ship Recycling Convention (26 June 2025), certificates issued in the framework of ship recycling will only refer to the EU Regulation 1257/2013 on ship recycling. A statement of compliance referring to the HK Ship Recycling Convention was allowed.
Since the HK Ship Recycling convention entered into force on 26 June 2025, new ships shall have on board a verified Inventory of Hazardous Materials. Ships in service shall comply with this requirement by 26 June 2030 or before going to recycling if this is earlier.
(Annex 1 to Circular 2025/002)
Existing vessels that have already received a Statement of Compliance based on the Ship Recycling Convention should be provided with an International Certificate on Inventory of Hazardous Materials during a survey on board. This allows for verification, amongst other requirements, that the IHM has been properly maintained and updated in accordance with the requirements of the Ship Recycling Convention before the certificate is issued.
As a consequence, there is two kinds of documents and certificates issued in the framework of ship recycling:
The formats of the documents and certificates based on the EU Regulation 1257/2013 shall be in compliance with the applicable EU Commission implementing regulations and therefore,
The formats of the documents and certificates based on the HK Ship Recycling Convention shall be in compliance with the HK Ship Recycling Convention.
However, the format of the certificate on the inventory of hazardous materials and the format of the ready for recycling certificate respectively issued under EU Regulation 2016/2325 as amended by EU Commission Implementing Decision 2026/121 and under EU Regulation 2016/2321 as amended by EU Commission Implementing Decision 2026/116, can be used under both the HK Ship Recycling Convention and EU Regulation 1257/2013 for legal certainty and administrative simplification.
Monitoring, Reporting and Verification of CO2 emissions Regulation (MRV)
(Meeting Class BMI – 28/11/2018)
For ships to which MRV regulation applies and starting from 1 July 2019, BMI requires that Recognised Organisation (RO) verifies during statutory surveys that a valid MRV Document of Compliance is provided on board.
Vessels below convention size (<500GT) and pontoons
Cargo vessels of less than 500GT
(IACS 99 – Belgian specific requirements and interpretations)
Cargo vessels of less than 500 GT when flying the Belgian flag (except non-propelled pontoons and fishing vessels), shall comply with recommendation number 99 issued by the international association of classification societies (IACS 99), as amended. These “Recommendations for the safety of cargo vessels of less than convention size” are supplemented (or replaced where mentioned explicitly) by the Belgian specific requirements and interpretations set out in this document.Additional mandatory Belgian requirements are listed in Chapter 9 of the attached file mentioned below.
The inspection regime is different from the inspection regime for ships of Convention Size
The delegated official of the BMI will inspect a cargo vessels of less than Convention Size with Class certificate:
When the ship is in Belgian, Dutch or French waters: yearly,
When the ship is outside these waters: at least twice every 5 years.
The drydock will be according to class rules: twice every 5 years.
In case a survey is performed by Recognised Organisation (RO) on behalf of the Belgian maritime inspectorate, the survey is to be performed according to the rules of the IACS 99 and the Belgian specific requirements and interpretations taking into account the derogations given by the BMI and listed in the exemption certificate. Reference to the exemption certificate can be found in the remarks section on the Certificate of Seaworthiness. The survey statement and/or report shall reflect this scope clearly.
Any request for exemptions is to be directed to the Administration. The decision to grant an exemption will be made on a case-by-case basis and will be documented in an official attestation. A reference to this attestation will be made on the certificate of seaworthiness.
For further information, refer to the attached file “IACS_99_-_Belgian_Specific_Requirements_v1.1.pdf”.
Fire control and safety plans
(Work Matrix in The Work Matrix)
From 1 January 2026 the fire control plans and the safety plans of vessels below convention size (<500GT) and pontoons must first be approved by Recognised Organisation (RO) and then submitted by Recognised Organisation (RO) for approval to the BMI.
This applies only to fire control plans and safety plans:
In case of a newbuilding or an extensive modification of an existing ship,
When an existing ship flying a foreign flag considers to be registered in the Belgian registry,
When changes are made to an existing plan.
Once Recognised Organisation (RO) approves a plan, Recognised Organisation (RO) will validate all its pages and send it to the BMI together with the letter of approval (if any) and any conditions.
The BMI reserves the right to fully review the submitted plan and to make comments which may result in changes to this plan.
ISM Code
Authorizations & instructions
| Ship type | PS | PH | PR | BC | OT | CT | GC | CH | CS | MO |
Document of Compliance | ||||||||||
| Interim | ||||||||||
| Initial | ||||||||||
| Periodical | ||||||||||
| Additional | ||||||||||
| Renewal | ||||||||||
Note(s): | The Administration mainly carries out DOC audits itself and issues the corresponding DOC certificate. In exceptional cases, Recognised Organisation (RO) can be authorized by the Administration to carry out an audit and/or issue the corresponding DOC certificate on behalf of the Administration. | |||||||||
Safety Management Certificate | ||||||||||
| Interim | x | x | x | x | x | x | x | x | x | x |
| Initial | x | x | x | x | x | x | x | x | x | x |
| Intermediate | x | x | x | x | x | x | x | x | x | x |
| Additional | ||||||||||
| Renewal | x | x | x | x | x | x | x | x | x | x |
Note(s): |
| |||||||||
| Requirements of the Administration | Action by CSQM from Recognised Organisation (RO) BEL |
|---|---|
| Item 11.4 of the agreement : “With regard to the ISM code and the ISPS code, all data and documents concerning the auditing and the follow-up of ships flying the Belgian flag must be centralized in Belgium. Also, all data and documents concerning the auditing and the follow-up of companies as stated in the ISM code and the ISPS code must be centralized in Belgium.” | CSQM from Recognised Organisation (RO) BEL |
| Audit reports to be forwarded to BMI without delay, validated by the CSOM from Recognised Organisation (RO) BEL. | CSQM from Recognised Organisation (RO) BEL |
. Recognised Organisation (RO) is authorized to perform Initial, Intermediate and Renewal audit + report; BMI shall issue the certificate on receipt of a positive audit report. The designated official may be present during the audit.· Reporting of non-conformities & follow up remains the responsibility of the RO: Recognised Organisation (RO) Antwerp shall forward the audit report to BMI. Recognised Organisation (RO) is not authorised to issue any definitive ISM certificate, with more than 5 months validity, obo BMI. Circular related to the new ISM requirements and new SMC format available on website. | Auditors |
| The Belgian Maritime Inspectorate finds that the CSR is sufficient evidence to comply with ISM-Code 3.1 for shipboard-audits (see BMI Circular on website) | Auditors |
Recognised Organisation (RO) does not have authorization to perform the interim audits and to issue the corresponding certificates, unless upon specific request of the Administration. Maximum validity of an interim certificate is 5 months, extensible 1 months by BMI. | Auditors / CM |
Agreement dated 27/06/2006. BMI circulars available in website: https://mobilit.belgium.be/en/shipping/maritime-shipping/ship-flying-belgian-flag/bmi-circulars Work Matrix - file attached BMI Circular 2005/003 - ISM Flagstate procedures (file attached) |
Specific requirements
Lay-up, idle and recommissioning of a seagoing commercial vessel
(Circular 2022/002)
BMI may accept the suspension of the Safety Management Certificate (SMC) of the vessel provided that:
all requirements of the port or coastal state are met;
all requirements of Recognised Organisation (RO) are met;
depending on the type of lay-up a minimum safe manning is agreed upon by the port or coastal state and BMI;
emergency procedures are in place for situations such as, but not limited to, fire, flooding, environmental pollution,… ; and
emergency procedures are in place for the minimum safe manning, crew or other watchmen remaining on board, if any.
The audit requirements upon recommissioning of the vessel will be considered on a case-by-case basis by BMI. Among other things, this consideration will depend on the duration of the lay-up period and will be based on IMO MSC-MEPC.7/Circ.9. In general, lay-up in excess of 6 months will require interim certification in accordance with ISM Code 14.4. An additional verification may be considered for shorter lay-up periods.
ISPS Code
Authorizations & Instructions
| SSP approval / review | Ship audit | ISSC issuance |
|---|---|---|
| Yes | Yes (see observation) | Yes (5 months max) |
Observation(s):
| ||
| Item | Specific requirements | Observation(s) |
|---|---|---|
| SSP approval / review | In the approval or re-approval letter of the SSP, Recognised Organisation (RO) must always explicitly state as minimum the following: “In approving the ship security plan, it was ensured that in accordance with ISPS Code A/9.4 the following requirements were applied: - Paragraphs 8 and 9 of Part B of the ISPS Code, made mandatory by articles 2.5.2.55 and 2.5.2.56 of the Belgian Shipping Code, - Paragraphs of Part B of the ISPS Code made mandatory by article 3.5 of EU Regulation 725/2004.” Recognised Organisation (RO) shall forward a copy of the SSP letter of approval to BMI. The letter of approval shall be put in the SSP on board the vessel. For ships with a restricted sailing area a new SSA must be performed in case the ship is getting repositioned to a location which is not covered within the SSA. See BMI circular on website | SSA - BMI request the SSA on board on vessels flying Belgian flag. A specific template is available (see Specific document) Note: SSP cannot be approved before the date of the registration of the ship. (Circular 2023/002) (Meeting BMI - RO - 31/10/2024) From the 1st of July 2024, the SSP approval letter must confirm that the Belgian requirements are met (SSA to comply with ISPS B/8 and SSP to comply with ISPS B/9). (Meeting Class BMI – 28/11/2018)When a ship changes flag/owner, a SSA shall be carried out and based upon the assessment a SSP plan is issued, which is submitted to Recognised Organisation (RO) for approval. The SSP plan shall be on board on the day of the change of flag, but it cannot be approved and it cannot be signed on that day. ( Administration email dated 06/06/2024)For ships already flying the Belgian flag before 01/07/2024, this must be implemented no later than first ISPS renewal audit on or after 01/07/2024. For ships joining the Belgian flag (newbuildings as well as existing vessels) on or after 01/07/2024 this must be done upon registration. |
| Part B mandatory | See observations above. | |
| SSP amendments | Any amendment of an approved procedure, SSP and / or security equipment shall be notified to Recognised Organisation (RO) who decides if a new audit is required | Refer to Circular 2023/002 in attached file. A specific template is available (see A4.2) |
| CSO / SSO training | Documentary evidence from a third party instructions to be produced for the CSO | |
| ISSC issuance / endorsement | Definitive by BMI, Recognised Organisation (RO) may issue an ISSC valid 5 months, when at the time of the audit: ISST, ISSI, ISSR, the ISSC issued by BMI is not available (see BMI website). Any interim ISSC shall be issued with a maximum validity of 5 months. (BMI may extend 1 month under exceptional circumstances) | Interim audits are authorised if complying with A/19.4.2. |
| ISPS audits | - Initial, intermediate and renewal audits can be performed by Recognised Organisation (RO) auditors, except when the Flag Administration is carrying out the audit.- Upon completion of a satisfactory renewal audit, Recognised Organisation (RO) is authorized to endorse the existing certificate through Navicert platform in accordance with ISPS section A.19.3.4, with a maximum validity of 5 months.The definitive ISSC certificate is issued by the Administration on receipt of the positive report. Recognised Organisation (RO) may only audit ships for which we had approved the SSP | (Circular 2023/002 - file attached) The RSO performing the verification must be the same RSO who has performed the review and approval of the SSP. |
| Document submission to Administration | The audit report shall be forwarded validated by Recognised Organisation (RO) BEL CSQM, without delay, to BMI by Recognised Organisation (RO) BEL. (Circ. 004/05 Rev 1) | |
| Minimum period for filing records | ISPS A/10: 3 years, DOS: 3 years. | |
| Ship Security Alert System (SSAS) | Resolution MSC 147(77) MSC/Circ.1072 without restrictions Silent alerts direct to company who shall set up internal procedures for receiving, investigating and handling silent alarm alerts. Upon receiving an alert, BMA shall be contacted. | Hardware subjected to radio Inspections RSO performs additional audit to confirm compliance of the SSAS after installation. Refer to Circular 2026/001 in attached file. |
| Document of reference | Fax BMI-A/PWO/E-4P-03 dated 23/04/04. Email from Recognised Organisation (RO) Antwerp dated 28/11/05 and 21/12/06 New agreement dated 27/06/2006 BMI circulars available in website: https://mobilit.belgium.be/en/shipping/maritime-shipping/ship-flying-belgian-flag/bmi-circulars Work Matrix - file attached | |
ISPS Security Code level
Belgium has increased its ISPS Security Code level for Belgian flagged ships in the waters of the port area of PEMBA (Mozambique), the Bay of PEMBA and the territorial waters around PEMBA, to Security Level 3 from 08/05/2020 (Refer to Circular 2020/003 in attached file “isps_level_3_pemba_20200508.pdf”)
Belgium has lowered its ISPS Security Code level for Belgian flagged ships in the waters of the Libyan coast to Security Level 1 (SL1) from 17/06/2020 (Refer to Circular 2020/004 in attached file “circulaire_libie_17062020.pdf”)
Specific requirements
Lay-up, idle and recommissioning of a seagoing commercial vessel
(Circular 2022/002)
Continuing the full implementation of the SSP and maintaining the International Ship Security Certificate (ISSC) is therefore recommended. If required by Recognised Organisation (RO), specific lay-up procedures must be added to the SSP. These additional procedures must be reviewed and approved by Recognised Organisation (RO).
BMI may however accept the suspension of the ship’s ISSC provided that:
all requirements of the port or coastal State are met;
all requirements of Recognised Organisation (RO) are met;
adequate procedures are in place to keep the ship secure throughout the lay-up period, to avoid security risks when the ship is recommissioned and to tackle any security related emergency, these procedures must be reviewed and approved by Recognised Organisation (RO); and
a sufficient number of crew or other watchmen remains on board to execute these procedures, unless specific arrangements, having the same effect, have been made with shore-based personnel.
Any such arrangements must be reviewed and approved by Recognised Organisation (RO).
The audit requirements upon recommissioning of the vessel will be considered on a case-by-case basis by BMI. Among other things, this will depend on the duration of the lay-up period and/or the suspension of the ISSC. In general, a suspension in excess of 6 months will require interim certification in accordance with ISPS Code 19.4. An additional verification may be considered for shorter lay-up periods.
Cyber security
(Circular 2023/002)
The SSA and SSP shall contain at least a reference to the SMS’ cyber security procedures:
SOLAS regulation XI-2/1.1.13
IMO Resolution MSC.428(98) Maritime cyber risk management in safety management systems,
IMO Circular MSC-FAL.1/Circ.3 Guidelines on maritime cyber risk management, as revised2,
EU Regulation 725/2004.
The Administration proposes that the Company Security Officer includes a cross reference to the Safety Management System’s cyber security policy in the SSP and subsequently issues a declaration to this effect. Subject declaration should be available on board.
The cross-reference in the SSP should then be verified by Recognised Organisation (RO) when ensuring that the SSP complies with the requirements of the entire paragraph 8 (SSA) and of the entire paragraph 9 (SSP) of Part B of the ISPS Code. The period within which this should be done is specified in section III. A.
MLC, 2006
Scope of authorisation
| Yes | No | Observation | |
|---|---|---|---|
| Approval of DMLC II | X | DMLC II issued by MLC shipowner will be reviewed and signed by the Administration mlc@mobilit.fgov.be. Recognised Organisation (RO) is not authorised to countersign the DMLC Part II following an on board inspection in relation to MLC. |
| Inspection | Certification | ||
|---|---|---|---|
| Yes | No | ||
| Partial recognition | X* | X* | |
* Recognised Organisation (RO) is authorized to perform Initial, Intermediate & Renewal MLC inspections. * Recognised Organisation (RO) is NOT authorized to perform the Interim inspections and to issue the corresponding certificates, unless upon specific request of the Administration (maximum validity of the interim certificate is 6 months). * Recognised Organisation (RO) is authorized to perform the Initial inspections and to issue the corresponding certificates, unless specific instructions have been given by the Administration to the shipowner or company that these initial inspections must be performed by the Administration.Upon completion of an initial inspection with a positive result, Recognised Organisation (RO) is authorized to issue a Maritime Labour Certificate, valid for up to 5 months, from the date of completion of the inspection. The certificate, together with a copy of the report, must be sent immediately to the Administration.The Administration shall issue the electronic full term certificate through Navicert on receipt of a positive audit report. * Intermediate endorsement of the existing certificate by Recognised Organisation (RO) is carried out via Navicert platform, if electronic certificates have been issued by the Administration, or on the original paper certificate if not. * Recognised Organisation (RO) is only authorized to perform the renewal inspection when the Administration has performed the intermediate inspection, unless explicitly authorized by the Administration. Upon successful completion of the renewal inspection, where electronic certificates have been issued by the administration, Recognised Organisation (RO) is authorized to endorse the existing certificates through Navicert platform in accordance with MLC Standard A5.1.3.4, with a maximum validity of 5 months. . Refer also to section 1.2.2.1 MoM Corporate Flag State Governance II (on a trial basis) . Reference Documents: Work Matrix - file attached | |||
Specific requirements
Ship’s cook
(Circular 2014/001 Rev.1)
Every seafarer in the function of ship’s cook on board of a Belgian sea-going vessel - with the exception of fishing vessels and military ships - shall hold a mandatory “Certificate of qualification as a ship's cook” or a Belgian “Official declaration of qualification as a ship's cook”.
Ships operating with a prescribed manning of less than ten are not required by the Administration to carry a fully qualified and certified cook. On these ships, anyone who processes food in the galley, must be trained or instructed in areas such as food and personal hygiene and the handling and storage of food on board the ship.
MLC 2006 Amendments 2022
(Circular 2024/001)
This Administration has made the guidelines regarding internet mandatory.The 2022 amendments will be incorporated in the DMLC Part I at the time of renewal of the Maritime Labour certificate.By using this method, uncertainty can be avoided regarding the dates of issuance of the DMLC Part I & II on the MLC-certificate.
In annex of this circular 2024/001 is a draft of the amended DMLC Part I as it will be issued by the Belgian Maritime Inspectorate (BMI), the new provisions are included and highlighted.
Every shipowner of a vessel who’s valid MLC-Certificate has not been renewed or reissued, is required to keep a copy of this circular 2024/001 and it’s annex with the valid MLC-Certificate, on board.
The shipowner shall also provide a written statement that the above mentioned 2022 amendments will be implemented and specifies the measures taken to give full effect to these amendments. The circular and statement should be shown to any concerned party, upon request.
When requesting the renewal of the MLC certificate, a new DMLC Part I must be submitted to BMI for approval prior the renewal verifications are carried out. The DMLC Part II should then include all the measures taken by the shipowner to give full effect to the provisions of the DMLC Part I as amended.
Appendix — Working Agreement governing the delegation of regulatory services associated with the issue and renewal of certificates
Agreement
See Agreement signed on 17/10/2022 in the attached file “Belgian Administration - Working agreement ENG version 2022”.
Appendix to the Agreement
The Work Matrix
See the attached file “2025 - Work Matrix version 11”.
Appendix — Circular 2005/005 - Multiple load line assignment
Untitled
See the attached file “BMI-2005-005”.
Appendix — Specific Certificates: National and Bilingual International Certificates
International Certificates
- International Load Line Certificate
Specific document
The following documents are available in National Certificates:
- SSP Plan Approval Letter - First approval letter
- SSP Plan Approval Letter - Amendments