Autonomous and remotely operated vessel technology is rapidly advancing the scale and scope of unmanned missions. These new vessels are entering the waterways and presenting novel issues to mariners. Until recently, maritime autonomy faced a largely incompatible regulatory regime. However, new guidelines from the U.S. Coast Guard (USCG) and the International Maritime Organization (IMO) provide our first look at maritime autonomy policies.<\/p>\n\n\n\n
Many autonomous developers located across Rhode Island and Southern New England are already operating in and around Narragansett Bay. They, together with the USCG, are on the cutting edge of autonomous vessel development and policy. The recently issued policies provide important insight for autonomous developers, operators, and investors by establishing a regulatory framework for the emerging industry.<\/p>\n\n\n\n
The USCG work instruction, issued in June 2026, encourages the promotion of emerging autonomous technologies by calling on the USCG to proactively engage with unmanned vessel developers.[1]<\/a> The guidance calls for partnership between autonomous vessel operators and the USCG, and is largely modeled on practices developed in the waters of Southern New England and Narragansett Bay.<\/p>\n\n\n\n The USCG retains oversight of autonomous vessels and requires compliance with all applicable maritime regulations. U.S. maritime law establishes minimum crewing requirements based on vessel use and tonnage.[2]<\/a> These requirements include watchstanders and lookouts but anticipate the use of automated systems that can reduce overall crew requirements.[3]<\/a> With proper planning and coordination, an unmanned vessel may have a path to for demonstrating an equivalent level of safety.[4]<\/a><\/p>\n\n\n\n The work instruction provides guidelines for coordinating with the USCG to allow remote and autonomous operation on a trial basis under human supervision and notes that special or unique vessels can develop a manning scheme that places watchstanders and lookouts somewhere other than traditional control stations on the vessel.[5]<\/a><\/p>\n\n\n\n To facilitate engagement with the USCG, the work instruction recommends that autonomous vessel operators develop a Concept of Operations (CONOPS) that provides: <\/p>\n\n\n\n A comprehensive CONOPS can streamline the deployment of autonomous vessels by demonstrating an equivalent level of safety to the Coast Guard and others in the maritime community.<\/p>\n\n\n\n The IMO adopted its new International Code of Safety for Maritime Autonomous Surface Ships (MASS Code) in May 2026.[6]<\/a> The non-mandatory code took effect on July 1, 2026, and the IMO anticipates that the code will become mandatory in 2032. The code currently applies to autonomous cargo vessels over 500 gross tons, though the IMO recommends the guidelines be applied to smaller autonomous vessels. The code seeks to safely integrate remotely operated and autonomous commercial ships into global shipping by establishing guidelines for the design, operation, and certification of autonomous surface ships that satisfy current standards for safety and environmental protection.<\/p>\n\n\n\n Similar to the USCG work instruction, the MASS Code encourages autonomous vessel operators to demonstrate their ability to identify risks and that autonomous platforms can manage those risks. The MASS Code focuses on critical autonomous systems, including navigation and connectivity, remote operations and human oversight, vessel and fire safety, and search and rescue responsibilities. <\/p>\n\n\n\n While the MASS Code emphasizes risk-assessment, it also reinforces the human element. Under the MASS Code, a human master retains responsibility for the ship, even if that individual is not on board. As a result, the IMO expects that autonomous developers will develop human-centric designs that consider the ability of individuals responsible for the vessel and the cybersecurity and connectivity requirements necessary to ensure that appropriately trained humans-in-the-loop can monitor and control an autonomous vessel from another location.<\/p>\n\n\n\n Rhode Island is home to numerous active maritime industries and autonomous vessels deployed in and around Rhode Island waters face active commercial and recreational traffic along with significant research and development activity. Autonomous developers should adhere to the USCG guidance and focus on these practical takeaways to ensure safe seas for all:<\/p>\n\n\n\n These early guidelines provide a foundation upon which a generation of autonomous development is yet to occur. <\/a>A winning strategy for autonomous developers is to engage stakeholders early, use the collaborative and regional resources already available, and design vessels capable of coexisting with the human-centric maritime system.<\/p>\n\n\n\n At AP&S, we help clients navigate complex maritime and technology issues, providing the legal and strategic guidance needed to manage the shifting regulatory landscape.<\/p>\n\n\n\n [1]<\/a> United States Coast Guard, Work Instruction 5P-WI-002(1), Oversight of Unmanned, Autonomous, and Remote-Control Operations<\/em>, June 5, 2026 [hereinafter USCG Work Instruction<\/em>]. https:\/\/www.news.uscg.mil\/maritime-commons\/Article\/4509546\/coast-guard-assistant-commandant-for-prevention-policy-cg-5p-publishes-guidance\/<\/strong><\/a><\/p>\n\n\n\n [2]<\/a> 46 U.S.C. \u00a7 8301.<\/p>\n\n\n\n [3]<\/a> 46 C.F.R. \u00a7 15.715.<\/p>\n\n\n\n [4]<\/a> USCG Work Instruction<\/em> \u00a7 E.<\/p>\n\n\n\n [5]<\/a> Id.<\/em> at \u00a7 E(3).<\/p>\n\n\n\n [6]<\/a>International Code of Safety for Maritime Autonomous Surface Ships (MASS Code), Maritime Safety Committee Resolution MSC.595(111). https:\/\/www.imo.org\/en\/ourwork\/safety\/pages\/autonomous-shipping-(mass).aspx<\/strong><\/a><\/p>\n","protected":false},"excerpt":{"rendered":" Autonomous and remotely operated vessel technology is rapidly advancing the scale and scope of unmanned missions. These new vessels are entering the waterways and presenting novel issues to mariners. Until recently, maritime autonomy faced a largely incompatible regulatory regime. 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International Autonomous Regulation<\/h2>\n\n\n\n
Practical Takeaways for Autonomous Vessel Deployment<\/h2>\n\n\n\n
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How AP&S Can Help<\/strong><\/h2>\n\n\n\n
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