An Overview of IMO MSAS Program

The IMO Member State Audit Scheme (IMSAS) (sometimes seen as MSAS) is a program by the International Maritime Organization (IMO) for periodic, mandatory audits of its Member States to ensure they effectively implement and enforce international maritime laws, using the IMO Instruments Implementation Code (III Code) as the standard to enhance global maritime safety and security. Launched voluntarily in 2006, it became a treaty obligation in 2016, requiring states to undergo audits every seven years to assess their compliance with conventions like SOLAS and MARPOL.

Key Milestones in IMSAS History

• 2003: The IMO Assembly endorsed developing a Voluntary IMO Member State Audit Scheme (VIMSAS).
• 2006: The scheme officially launched as a voluntary initiative.
• 2010s: Development of the III Code provided the audit standard.
• 2016: IMSAS became mandatory, incorporated into key IMO treaties, requiring all member states to undergo audits.
• 2023: 100 member states had been audited under the mandatory scheme.
• Ongoing: The scheme involves regular, seven-year audits, identifying recurring issues and root causes of non-compliance through Consolidated Audit Summary Reports (CASRs).

Scope

The audit scheme, which became mandatory in 2016, evaluates a Member State's performance across nine core areas:

• Jurisdiction.
• Institutional structure and authority.
• Legislation, rules, and regulations, with particular reference to the process for incorporating new amendments into national law.
• Promulgation of IMO instruments, ensuring that relevant parties are informed of requirements.
• Enforcement arrangements.
• Control, survey, inspection, audit, verification, approval, and certification functions.
• Selection, recognition, authorization, empowerment, and oversight of recognized organizations (like classification societies) and nominated surveyors.
• Investigations of marine casualties and incidents, with reporting to the IMO.
• Reporting to the IMO and other administrations, including the communication of information as required by mandatory instruments.

How does it work?

The IMO Member State Audit Scheme (IMSAS) framework involves periodic, mandatory audits where trained teams assess how well countries implement IMO treaties, using the Global Integrated Shipping Information System (GISIS) for planning, execution (interviews, document review), and reporting (Executive Summary, Corrective Action Plans), all aimed at ensuring effective, safe, and environmentally sound shipping through continuous improvement and sharing best practices among nations.

The Procedure involves 4 key Stages:

Preparation & Planning (Before the Audit)

• Framework: The International Maritime Organization (IMO) sets the framework, objectives, and procedures for audits.
• Auditor Training: Auditors are nominated by Member States and undergo specific training (e.g., ISM Code, IMSAS) to gain necessary skills and knowledge.
• National Preparation: The audited Member State prepares its administration, legislation, and documentation to demonstrate compliance.

The Audit (On-Site/Remote)

• Audit Team: A team of trained auditors, often from other Member States, conducts the audit.
• Scope: They verify the State's capacity in legislation, implementation, and enforcement of its obligations under IMO instruments (SOLAS, MARPOL, STCW, etc.).
• Activities: This involves extensive interviews, reviewing records, and assessing operational standards.

Reporting & Follow-Up

• Findings: The audit team identifies areas of non-compliance or areas needing improvement, preparing an audit report.
• Executive Summary Report (ESR): A principle report summarizing audit outcomes is agreed upon with the Member State and submitted.
• Corrective Action Plan (CAP): The Member State develops a plan with timelines to address deficiencies, submitted via GISIS.
• Monitoring: Progress on CAP implementation is tracked, with reports shared among Member States.

Continuous Improvement

• Objective: The core aim is to strengthen overall maritime safety and environmental protection, supported by initiatives such as maritime training courses in Dubai.
• Sharing Knowledge: The process facilitates sharing lessons learned and best practices, often through anonymous summaries (CASR).
• Regular Cycle: Audits are periodic, encouraging ongoing self-assessment and enhancement of national maritime administrations.
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Why MSAS and How is it Leading Change? 

The IMO MSAS (IMSAS) leads change through several primary mechanisms:

Promoting Implementation & Compliance: 

The primary goal is to ensure all Member States meet their obligations as flag, port, and coastal States under applicable IMO instruments. By auditing how effectively a State implements laws, it encourages a global, level playing field for compliance.

Identifying & Addressing Gaps: 

The audit process provides a comprehensive and objective assessment, identifying areas where a Member State can improve its performance. This helps States pinpoint weaknesses in their national legislation or administration.

Driving Corrective Actions: 

Following an audit, States are required to develop and implement corrective action plans to address any non-conformities found. These plans have specific completion dates, ensuring tangible improvements are made to the State's maritime administration and enforcement.

Facilitating Knowledge Sharing: 

The scheme provides valuable feedback and insights that can be shared with all Member States. This collective insight helps the IMO identify broader areas that may require future regulatory or technical assistance work, thus improving the overall global framework.

Enhancing Accountability: 

IMSAS promotes institutional responsibility and transparency within Member States' maritime administrations, pushing them to move from a reactive approach to regulation toward a proactive one based on risk evaluation and management.

IMO MSAS in Numbers - as of early 2025

Total Audits Conducted (mandatory): 

Over 144 audits have been conducted since the scheme became mandatory in January 2016.

Member States Audited: 

By the end of 2023, 116 of the IMO's 176 Member States had been audited.

Audit Cycle: 

All Member States are required to undergo a mandatory audit within a seven-year cycle, with up to 25 audits expected annually. The first cycle is due to be completed at the end of 2025.

Reporting: 

The outcomes of audits are consolidated into Consolidated Audit Summary Reports (CASRs). As of October 2024, seven CASRs had been issued, covering the outcomes of 82 audits conducted between 2016 and 2023.

Major trends and focus areas include:

The primary trends for the IMO Member State Audit Scheme (IMSAS) are the integration of environmental goals (GHG reductions), the incorporation of new technologies like autonomous shipping, E-navigation,  and digitalization, and the use of audit data to drive targeted technical cooperation. The first full audit cycle is scheduled for completion at the end of 2025.

In conclusion, 

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