The Sport or Pleasure Vessel Code: what should operators do now?
Dr Elliott Berry, Marsurv
If a vessel carries paying passengers on a sightseeing trip, supports a sporting event or is chartered, which safety code governs it in 2026? The answer matters before a new vessel enters service, before an existing certificate comes up for renewal, and whenever an operator changes the way a boat is used.
The Maritime and Coastguard Agency (MCA) Sport or Pleasure Vessel Code came into force on 12 December 2025, together with the Merchant Shipping (Vessels in Commercial Use for Sport or Pleasure) Regulations 2025 (SI 2025/1195), which replaced the 1998 regulations. It brings several earlier small vessel codes together into a single framework for a defined category of commercial activity. It is a significant change, but it does not mean that every privately used yacht, inland passenger boat or workboat has moved to the same code. The starting point is always the vessel’s actual use, its operating waters and its current certification.
When does a vessel need to be coded at all?
A vessel used purely for the owner’s own pleasure is not coded. The question arises when the boat is operated for gain, whether skippered or chartered bareboat, or when the people aboard pay more than a reasonable contribution towards the cost of the trip. The Royal Yachting Association (RYA) draws exactly that line in its guidance on commercial coding. Friends sharing fuel and mooring costs is one thing; a trip sold by the seat, or a share of the profit to the owner, is another.
The facts of the operation decide the matter. Calling a boat a “pleasure craft”, or describing an activity as not for profit, does not of itself establish which regime applies.
Which vessels are in scope?
The MCA describes the code as applying to small vessels under 24 metres in commercial use for sport or pleasure, operating at sea, carrying no cargo and no more than 12 passengers. It applies to UK registered vessels in that use, and to certain vessels registered elsewhere while they operate from UK ports in UK waters. The MCA gives race support craft and high speed sightseeing vessels as examples.
Several kinds of vessel fall outside the code. The MCA lists underwater vessels, hovercraft and vessels carrying cargo among the exclusions. Vessels operating only on inland waters, and vessels carrying more than 12 passengers, are dealt with under other regimes. Workboats are not barred from sport or pleasure work, but the MCA explains that light duty workboat activity needs its own certification under the workboat regime. Where a vessel moves between activities, the operator should ask its Certifying Authority which certification is required for each intended use, rather than assume that one certificate covers everything.
Three further limits are worth knowing. A UK certificate may not be recognised outside UK waters, so an operator planning to work abroad should check the local requirements first. The code deals with the safety of the vessel, and a sporting body may impose its own additional requirements for an event. And the code states that compliance does not remove the need to comply with the byelaws of the local navigation authority or of the port or harbour authority.
What changed in December 2025?
The code replaces the Yellow, Blue and Red Codes, the Intended Pleasure Vessel Code and the related MGN 280 arrangements. The MCA says it consolidates the requirements and updates the provisions for construction, stability, equipment, hybrid and electric propulsion, examinations, certification, safety management and risk assessment.
Battery power is a good example of how far the code has moved. It now defines lithium-ion batteries, battery management systems and thermal runaway, sets out arrangements for battery electric and battery hybrid propulsion, and describes dedicated battery rooms and battery boxes of steel or equivalent material. An operator considering electric or hybrid propulsion should raise it with the Certifying Authority at the outset, not after the equipment has been bought.
Area categories
Operating areas are allocated in seven categories, set by the MCA as follows:
Category | Area of operation |
0 | Unrestricted service |
1 | Up to 150 miles from a safe haven |
2 | Up to 60 miles from a safe haven |
3 | Up to 20 miles from a safe haven |
4 | Up to 20 miles from a safe haven, in favourable weather and in daylight |
5 | Within 3 miles of land and not more than 3 miles radius from the point of departure to sea or the seaward boundary of categorised waters, in favourable weather |
6 | As Category 5, but in favourable weather and daylight |
The category a vessel can be given depends upon its stability and construction as well as its equipment. Some vessels must carry an approved stability information booklet, and the code sets simpler methods for open boats, inflatables and rigid inflatables. A vessel holding valid certification for a design category under the Recreational Craft Regulations will be considered suitable for the corresponding area category; Categories 0 and 1, for example, correspond to Design Category A, and Categories 4 to 6 require at least Design Category C. An operator should therefore not plan a route on the assumption that a higher category will follow.
Where a vessel works in categorised waters or a restricted service and full application of the code would be inappropriate, the owner may ask the Certifying Authority to apply to the MCA for alternative standards.
Examinations, certificates and risk assessment
A new vessel entering the regime undergoes a compliance examination, both out of the water and afloat, by a person authorised by the Certifying Authority. Certificates are issued for up to five years and remain valid only while the vessel is maintained, equipped and operated as documented, and only if the annual and intermediate examinations are completed within the periods specified. The hull, shell fittings and external steering and propulsion components are examined out of the water at intervals not exceeding five years, and the renewal examination is equivalent to the compliance examination.
The code also places a duty on the owner or operator to carry out a risk assessment appropriate to the intended operation, covering circumstances, local conditions or equipment that the code does not address. A new risk assessment is required whenever the area category changes, the vessel is converted for a different use, or an additional piece of equipment is fitted. Where people are employed aboard, the Merchant Shipping and Fishing Vessels (Health and Safety at Work) Regulations 1997 apply as well.
The MCA authorises a number of Certifying Authorities, among them Bureau Veritas, Lloyd’s Register, DNV, RINA, MECAL, Burness Corlett Three Quays, the International Institute of Marine Surveying, the Royal Yachting Association, the Society of Consulting Marine Engineers and Ship Surveyors, and the Yacht Designers and Surveyors Association. The MCA itself also acts as one.
For a new vessel, the code applies to vessels whose keels were laid, or which had reached a similar stage of construction, on or after 12 December 2025, and the published code explains how certain vessels begun before that date may be treated. Discovering late in a project that the intended operation demands different equipment, stability information or documentation is far harder to resolve than an early conversation with the Certifying Authority. Where the vessel is to be registered on Part 1 of the UK Ship Register, a tonnage measurement survey by an MCA approved measurer is also required for first registration, and is best arranged alongside the coding work.
Does an existing coded vessel have to change immediately?
Not necessarily. The published code states that vessels certified under the previous arrangements must meet the new code by their next renewal examination or three years after 12 December 2025, whichever is later, subject to specific provisions that allow earlier requirements to continue in certain sections. The MCA also identifies a change of operation or a modification as a reason to review compliance.
That is why the statement that “every vessel must comply by December 2028” is an oversimplification. The renewal date and the exact provision governing the vessel both matter.
The code also states that an existing vessel moving into the new regime must do so fully. It cannot meet a combination of the new code and the earlier codes. Operators should keep the current certificate, its expiry date and the examination records together, and ask their Certifying Authority to confirm a transition plan in writing.
Five questions to answer before the next examination
1. What is the boat actually used for?Describe the passengers, any payment or other consideration, the activities, any cargo and any occasional alternative use. Do not rely on the marketing name of the trip.
2. Where does it operate?Set the intended route against the category table above. An operator planning a longer route or a different departure point should raise the change before the season begins, and will need a new risk assessment if the category changes.
3. What certificate is held now, and when is it due for renewal?Check the issuing Certifying Authority, the code, the category, any conditions, the dates of the annual, intermediate and renewal examinations, and when the hull was last examined out of the water.
4. What has changed aboard?Record alterations to propulsion, batteries, layout, loading, equipment and operating arrangements. A new battery bank or an added deck structure can alter both the electrical risk and the stability, so ask the Certifying Authority which changes need assessment rather than assume that an earlier approval carries over.
5. What evidence is available?Assemble plans, stability information where applicable, design category documentation, equipment records, maintenance records and the operating risk assessment. What has to be submitted will depend upon the vessel and its category.
Condition survey and coding examination are different things
An independent condition survey establishes the observed condition of the vessel and identifies matters to be remedied. Coding is a defined examination and certification process under the code, carried out for the Certifying Authority. A condition survey should not be presented as a coding certificate, and a coding examination is not an assurance that every concealed or inaccessible defect has been found. Having the condition survey done first allows defects to be dealt with before the examination rather than discovered during it.
Plan the transition around the operation
The best time to settle the code is before the vessel is committed to a charter programme, an alteration or a purchase. Bring the proposed use, the current certificate, the vessel’s particulars and the timetable to a competent surveyor and to the relevant Certifying Authority. Between them they can identify the applicable route and the evidence the examination will require.
Planning a new commercial vessel, a change of use or a coding renewal?
Marsurv’s MCA compliance services set out the work we undertake, including tonnage measurement.
Tell us about the vessel, its current certificate, its operating area and its intended activity, so that the survey requirements can be discussed.
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About the author
Dr Elliott Berry, MSc., Dip.Mar.Sur., F.I.I.M.S., is Principal Surveyor and Director of Marsurv. He is an elected member of the Board of the International Institute of Marine Surveying, sits on the BSI GME/33 Small Craft Committee, and holds MCA approvals for Tonnage Measurement and SCV Code surveys.
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