Since 1 January 2016 the IMO Instruments Implementation Code (III Code) has been mandatory, and audits under the IMO Member State Audit Scheme (IMSAS) assess how States meet their obligations as flag, port and coastal States.
Many administrations meet the Code for the first time when preparing for an audit. That is late. The Code is more useful as a design tool for how an administration is organised to implement any convention.
Three questions to ask early
- Is each obligation assigned? Every applicable instrument should have a responsible unit, a legal basis and a process for amendments.
- Is there a feedback loop? Records, reviews and corrective actions show whether implementation actually works.
- Can delegated functions be overseen? Where recognised organisations act on the State’s behalf, oversight must be real, not only contractual.
A practical approach
A structured gap assessment against the Code, followed by a prioritised roadmap with owners and timelines, turns audit preparation into lasting institutional improvement.