Regulation 23 – Pilot transfer arrangements
1 Ships on which pilots may be employed shall be provided with pilot transfer arrangements.
All ships that may require the services of a maritime pilot must be equipped with compliant pilot transfer arrangements — without exception. This is a mandatory SOLAS requirement and forms the legal foundation for all pilot transfer safety regulations.
Even ships that rarely take pilots, due to their trade patterns, must maintain readiness, as operational changes (e.g. route deviation, ownership change, shipyard visits) can require a pilot at any time. This rule ensures consistent safety standards, eliminates ambiguity, and supports the safe embarkation and disembarkation of maritime pilots under all conditions.
2 Pilot transfer arrangements shall enable pilots and other personnel to embark and disembark safely in all seagoing conditions of draught and trim.
This requirement is not limited to maritime pilots alone. It applies to any person who needs to board or leave the ship using the pilot transfer arrangement — including ship’s crew, inspectors, surveyors, port officials, or other personnel. The regulation ensures that everyone can transfer to and from the vessel in a safe and secure manner.
In this context, “safely” means that the transfer must be free of unnecessary risks — with equipment that is properly designed, rigged, and maintained, and with procedures that prevent falls, slips, or other hazards during boarding or disembarkation.
The phrase “all seagoing conditions of draught and trim” refers to the full range of floating conditions the ship may experience — from ballast condition (light draught) to fully laden condition (deep draught), including any forward or aft trim. This ensures the transfer arrangement remains safe regardless of how the ship is loaded or balanced during its voyage.
In short, the rule requires universal safety and readiness — for every person, in every operational condition.
3 Pilot transfer arrangements provided in accordance with paragraph 1 and installed on or after [1 January 2028] shall be designed, manufactured, constructed, secured and installed in accordance with the introduction and parts A, B and C of the performance standards adopted by the Maritime Safety Committee by resolution MSC.[…], as may be amended by the Organization, provided that such amendments are adopted, brought into force and take effect in accordance with the provisions of article VIII of the present Convention concerning the amendment procedures applicable to the annex other than chapter I.
Any pilot transfer arrangements that are installed on or after 1 January 2028 must follow the latest mandatory international standards set by the IMO Maritime Safety Committee (MSC). These standards are described in the performance standards document, specifically in the introduction and parts A, B and C.
- Design, materials, and construction
- Rigging and use of the equipment
- Installation requirements
This rule ensures that newly installed pilot transfer arrangements after 1 January 2028 are built and fitted in strict compliance with the most up-to-date IMO safety standards. Additionally, if these standards are updated in the future, ships must follow the officially adopted changes — once they become legally binding under the IMO’s amendment procedures.
4 Pilot transfer arrangements installed before [1 January 2028] on ships to which chapter I applies shall comply with the requirements provided in paragraph 3 not later than the first survey* on or after [1 January 2029]. ( Refer to Unified interpretation of the term ʺfirst surveyʺ referred to in SOLAS regulations (MSC.1/Circ.1290).)
If a ship already has pilot transfer arrangements installed before 1 January 2028, those arrangements must still be upgraded to meet the new IMO standards — but not immediately.
Instead, the upgrade must happen by the ship’s first scheduled safety survey that takes place on or after 1 January 2029.
This requirement applies to ships that fall under SOLAS Chapter I, which includes the vast majority of seagoing cargo ships of 500 gross tonnage and above and all passenger ships engaged on international voyages. These ships are subject to SOLAS safety certification and regular surveys.
5 Pilot transfer arrangements installed before [1 January 2028] on ships to which chapter I does not apply shall comply with the requirements provided in paragraph 3 no later than [1 January 2030].
Some ships are not covered by SOLAS Chapter I — for example:
- Smaller cargo ships under 500 gross tonnage
- Domestic or non-international vessels
- Certain government, fishing, or offshore support vessels
These ships are not subject to the SOLAS safety certification regime, but they are still required to comply with the new pilot transfer standards.
For these ships, there is a fixed deadline: They must upgrade their existing pilot transfer arrangements to meet the new standards (described in paragraph 3) no later than 1 January 2030.
6 Inspection, stowage, maintenance, replacement and familiarization of all pilot transfer arrangements, regardless of the installation date, shall comply with the introduction and parts D and E of the performance standards adopted by the Maritime Safety Committee by resolution MSC.[…], as may be amended by the Organization, provided that such amendments are adopted, brought into force and take effect in accordance with the provisions of article VIII of the present Convention concerning the amendment procedures applicable to the annex other than chapter I.
This paragraph applies to all pilot transfer arrangements, whether they were installed before or after 1 January 2028. It sets clear expectations for how these arrangements must be maintained and managed on board.
It refers specifically to Parts D and E of the IMO’s mandatory performance standards. These parts focus not on the construction or installation of the equipment, but on how the ship’s crew must care for and operate it on a day-to-day basis.
- Part D – Operational Readiness, Inspection, and Maintenance
- Part E – Familiarization and Training
In practice, the master and crew are responsible for ensuring that pilot transfer arrangements are always ready, safe, and compliant, existing onboard procedures may need to be reviewed and updated, especially checklists and training materials. Finally, ships must treat pilot transfer arrangements with the same level of care and attention as other critical safety systems
7 For the purpose of the present regulation, the expression “installed on or after [1 January 2028]” means a contractual delivery date for the pilot transfer arrangement or, in the absence of a contractual delivery date, the actual delivery date of the arrangement to the ship on or after [1 January 2028].
This paragraph defines what is meant by “installed on or after 1 January 2028.”
It refers to either:
- The contractual delivery date of the pilot transfer arrangement, or,
- If there’s no contract date, the actual date the equipment was delivered to the ship
This clarification is important for determining whether a ship must meet the new construction and installation standards described in paragraph 3.
8 Pilot transfer arrangements provided for in paragraph 3 shall be approved by the Administration in accordance with part F of the performance standards adopted by the Maritime Safety Committee by resolution MSC.[…], as may be amended by the Organization, provided that such amendments are adopted, brought into force and take effect in accordance with the provisions of article VIII of the present Convention concerning the amendment procedures applicable to the annex other than chapter I.
This paragraph provides the legal basis for Part F of the performance standards. It requires that all new pilot transfer arrangements installed on or after 1 January 2028 (as described in paragraph 3) must be formally approved by the flag State Administration — the maritime authority responsible for the ship’s compliance.
This approval must follow the procedures and criteria set out in Part F of the IMO performance standards.
Part F – Approval outlines the process for verifying that pilot transfer arrangements meet the required safety standards before being put into service
Responsibility: The Administration (usually the flag State) is responsible for: Reviewing documentation, Issuing approvals, Ensuring that the manufacturer and equipment meet the standards
The shipowner or operator is responsible for: Ensuring the correct equipment is installed, Using equipment that has been approved in accordance with Part F, Keeping documentation on board to demonstrate compliance.
9 Pilot transfer arrangements provided for in paragraph 3 on ships to which chapter I applies shall be inspected in accordance with regulations I/6 and I/7 or I/8. Pilot transfer arrangements on ships to which chapter I does not apply shall be inspected to the satisfaction of the Administration.
For ships covered by SOLAS Chapter I (e.g. cargo ships ≥ 500 GT and all international passenger ships):
- The inspection of pilot transfer arrangements must be carried out as part of the surveys required under SOLAS regulations I/6, I/7 or I/8.
- These are the initial, annual, intermediate, periodical, and renewal surveys performed by the flag State or a recognized organization (such as a classification society).
- It means pilot transfer arrangements are now formally included in the scope of SOLAS safety certification.
For ships not covered by SOLAS Chapter I (e.g. domestic vessels, smaller ships):
- These ships are not subject to SOLAS safety surveys, but their pilot transfer arrangements must still be inspected and accepted by the Administration (flag State authority).
- The standard and process may vary by country, but the end result must meet the same safety level.
This ensures uniform safety enforcement, regardless of ship size or trade.
10 Mechanical pilot hoists shall not be used.
11 Adequate means of illumination, either fixed or portable, shall be capable of illuminating all pilot transfer arrangements overside and the position on deck where pilots and other personnel embark or disembark. Portable lights, when used, shall have brackets to permit their positioning.
This rule requires that every part of the pilot transfer arrangement — including the ladder on the ship’s side and the deck area where people step on or off — must be properly lit.
Lighting can be fixed (permanent) or portable, but if portable lights are used, they must be securely mounted, not handheld or loosely placed.
This requirement is placed directly in the core SOLAS regulation (V/23) instead of only in the performance standards because:
- Poor lighting has repeatedly caused serious safety issues during pilot transfers, including near misses and accidents.
- Maritime pilots often report that they cannot see the ladder properly during night transfers or in bad weather.
- Inadequate lighting affects the pilot’s ability to judge the position, angle, or condition of the ladder — especially from a moving pilot boat.
The IMO and IMPA likely considered this issue serious enough to give it higher legal priority — by including it in the regulation itself, it becomes mandatory and enforceable.
12 Where a pilot or person suspects the pilot transfer arrangement provided is non-compliant, they should inform the master and refuse to use the arrangement until it is made compliant.
This clause empowers the maritime pilot — or any other person using the arrangement — to refuse to use a non-compliant pilot transfer arrangement (PTA) if they believe it is unsafe or not in line with regulations. They are expected to inform the master of the non-compliance and wait until the arrangement is corrected.
Although the word “should” is used — meaning it is not legally mandatory — this paragraph carries serious practical and legal weight because it is written directly into the SOLAS regulation itself, not just in the performance standards.
For the maritime pilot, this creates a clear duty of care: If a pilot accepts a non-compliant PTA and an incident occurs (e.g. a fall or injury), he or she will have to explain why the arrangement was used despite visible or suspected non-compliance.
Since the regulation now states that the pilot should refuse, it becomes part of best professional practice. Choosing to proceed anyway could expose the pilot — or pilot organization — to investigation, liability, or loss of credibility.
In essence, this regulation places shared responsibility on the user (not just the ship) to uphold safety.