UK maritime operators heading north or south next season have a new rulebook to work with. The Department for Transport has made the Merchant Shipping (Polar Code) (Safety) Regulations 2025, signed on 1 December 2025 by the Minister and laid before Parliament on 2 December 2025, with an in‑force date of 1 January 2026. The instrument replaces the 2021 rules and aligns the UK framework with recent International Maritime Organization changes.

According to legislation published on legislation.gov.uk and decisions from IMO’s MSC 107, the update extends Polar Code duties on safety of navigation and voyage planning to three additional groups: cargo ships of at least 300 but under 500 GT, fishing vessels of 24 metres or over in length overall, and pleasure vessels of 300 GT or more. Ships in these groups constructed before 1 January 2026 have until 1 January 2027 to meet the new requirements; all others must comply from day one.

For passenger ships and cargo ships of 500 GT or more, the core SOLAS Chapter XIV regime continues. Operators must comply with part 1‑A of the Polar Code, keep a Polar Water Operational Manual (PWOM) and hold a Polar Ship Certificate before entering polar waters. Surveys are required initially and thereafter alongside existing statutory surveys under the Merchant Shipping (Survey and Certification) Regulations 2015. A cargo ship in polar category C can avoid an extra pre‑issue survey if a written operational assessment confirms no additional equipment or structural changes are needed, but an onboard survey is still required at the next scheduled visit.

Training is now locked into the 2022 Standards of Training, Certification and Watchkeeping (STCW) Regulations as amended. For passenger ships and cargo ships of 500 GT or more, masters, chief mates and officers of the navigational watch require STCW Regulation V/4 polar training based on intended ice conditions. Basic training applies in open waters, with an exemption for non‑tanker cargo ships operating only in open waters; advanced training is required for masters and chief mates when operating in other waters where sea ice is present. Temporary replacement of a master, chief mate or watchkeeping officer is allowed only if strict conditions are met, including holding STCW II/2 and advanced V/4, adequate polar‑trained manning and compliant rest hours.

Fishing vessels and pleasure craft brought into scope by this instrument do not acquire STCW V/4 obligations via these amendments. Their new duties focus on the Polar Code’s added chapters 9‑1 (safety of navigation) and 11‑1 (voyage planning). Even so, skippers should consider polar familiarisation and drills as good practice, particularly where charterers or insurers expect evidence of competence.

There is clear enforcement muscle. Failure to meet performance standards, complete an operational assessment, comply with Polar Code chapters 2 to 10, or meet the new navigation and voyage planning provisions is an offence. Owners and masters can face fines on summary conviction and, on indictment, up to two years’ imprisonment or a fine. UK authorities may detain ships where there are clear grounds of non‑compliance, with a due‑diligence defence available but demanding to evidence.

Paperwork and onboard discipline will be tested. Companies and masters must operate to the PWOM and ensure every seafarer is familiar with the procedures and equipment relevant to their role. Alternative designs or arrangements are possible, but only after an engineering analysis approved by the Secretary of State; approvals and operational restrictions must then be recorded in both the Polar Ship Certificate and the PWOM.

The government has kept room for pragmatism. Exemptions may be granted for a one‑off international voyage into polar waters and, where compliance is impracticable or unreasonable, for a ship or class-provided outcomes remain compatible with Chapter XIV and the Polar Code. Equivalents can be accepted where they are at least as effective as the prescribed standard, and the Secretary of State can approve matters the Code leaves to the flag Administration.

From a cost perspective, the line items are predictable even if the official impact statement is de minimis. Expect spend on STCW V/4 courses and time off‑roster, development or refresh of a Polar Water Operational Manual, survey and certification work aligned to your next statutory window, and any equipment upgrades such as means for removing ice, survival systems suited to polar exposure and updates to navigation and communications for high latitudes. The Merchant Shipping (Fees) Regulations 2018 have been updated to reference the new instrument, but the schedule entry for these regulations shows no new fee line; core survey and certification charges still apply, so bundling visits with class and statutory work should reduce off‑hire.

Consider a small expedition cruise operator planning a Svalbard season in May 2026. Masters and chief mates will require advanced polar training; bridge watchkeepers will need basic certification where operations are in other waters. The ship will need a current Polar Ship Certificate, a tested plan for ice accretion removal, and crew drills aligned to the PWOM. Allow a full planning cycle to secure course places and complete the operational assessment before sailing.

A Shetland‑based trawler of 28 metres heading for the Barents Sea in early 2027 illustrates the fishing case. The vessel must comply with the navigation and voyage planning chapters by 1 January 2027 if constructed before 2026, with emphasis on ice information, routeing, search‑and‑rescue considerations and communications redundancy. STCW V/4 is not mandated here by these amendments, but insurers may ask for documented polar familiarisation and simulator time.

Next steps are practical rather than dramatic. Map each vessel to the correct category, confirm intended ice conditions, read across the Maritime and Coastguard Agency’s revised guidance in Marine Guidance Note 637 (M) and Merchant Shipping Notice 1866, and schedule surveys and training now. The rules are ambulatory, meaning future IMO changes will flow straight into UK law, so build an annual review point into the safety management system and keep voyage plans and bridge procedures current.