Oceaneria Yacht Industry Report
By the Glen Smale

How the January 2026 requirements affect certification checks, onboarding and onboard reporting procedures

So, I’ve started working through the new STCW harassment training requirements that came into force on 1 January 2026.

And, to be honest, it takes a fair amount of digging to understand how all the different parts fit together.

You’ve got the STCW training requirements. You’ve got PSSR certificates. You’ve got different flag and certification administrations applying the change in slightly different ways.

And then you’ve got the much bigger operational question.

What is actually supposed to happen aboard a yacht when somebody reports harassment, bullying, violence or sexual misconduct?

That is where the whole subject starts becoming a bit of a mind-bender.

I’m by no means a maritime lawyer or regulatory expert. I’m simply working through the available information, trying to understand what has changed and then translating it into something practical that captains and yacht professionals can actually use.

The easiest way for me to understand this type of information is to break it into short, clear points.

So I’ll take each issue, explain what the regulation appears to say, and then explain how I understand it may affect a yacht, its crew and the people responsible for managing the process.

Hopefully, it makes sense to you too.

So, what has actually changed?

The first important point is that the new STCW harassment training requirement is already in force.

It came into effect on 1 January 2026 through IMO Resolution MSC.560(108).

Now, that sounds like another technical regulatory reference. But the practical change is quite important.

The resolution adds new mandatory training content covering violence and harassment at sea. This includes bullying, sexual harassment and sexual assault.

It also covers what crew should understand about prevention, intervention, reporting and trauma-informed response.

So this is not simply a case of telling crew that harassment is unacceptable.

My understanding is that the training now needs to help crew recognise what harmful behaviour looks like, understand how it can develop, know what action they can take and understand how to respond when somebody else raises a concern.

That is quite a significant shift.

Because once crew are formally being trained to identify and report this behaviour, vessels also need to make sure there is a proper process waiting for them when they do.

The new training sits inside PSSR

The next point that confused me slightly at first was where this new training actually sits.

It is not necessarily a completely separate STCW harassment certificate.

The new content has been added to Personal Safety and Social Responsibilities training, normally referred to as PSSR.

PSSR already forms part of STCW basic safety training.

So, as I understand it, somebody completing an approved PSSR course under the new requirements should now receive this violence, harassment and reporting training as part of that course.

That distinction matters.

Because you may start hearing people ask whether a crew member has a separate harassment certificate.

But that may not be the correct question.

The more accurate question is whether their PSSR training included the amended requirements introduced from January 2026, and whether the certificate or course evidence is accepted by the relevant administration.

And this is where the situation becomes slightly more complicated.

Because not every older PSSR certificate suddenly became invalid on 1 January 2026.

Older PSSR certificates are not automatically invalid

This is probably one of the most important points for captains, crew managers and recruitment teams.

The amendment does not automatically cancel every PSSR certificate issued before January 2026.

So a crew member should not simply be rejected because their certificate was issued before the new training came into force.

What appears to be happening is that each administration is determining how it will deal with existing certificates, new courses, renewals and any additional evidence it may require.

So captains cannot assume that one rule applies to every crew member.

You need to know who issued the certificate, when the training was completed, whether the certificate remains valid and what the yacht’s flag administration accepts.

And even where an older certificate remains legally valid, there may still be a practical gap.

That crew member may never have received the new training on harassment, intervention, reporting and trauma-informed response.

So the certificate may remain valid, but the company or vessel may still need to provide additional familiarisation.

That is an important difference.

The certificate question is one issue.

Whether the crew member understands the yacht’s actual reporting process is another.

The UK position on older PSSR certificates

The UK Maritime and Coastguard Agency has taken a reasonably clear position.

It says that seafarers who completed PSSR before 1 January 2026 do not automatically need to repeat the course.

Existing certificates issued by MCA-approved training providers do not need to be reissued, and the MCA regards them as continuing to remain valid.

But the MCA also strongly recommends that companies provide existing seafarers with training and guidance covering the new content.

It also warns that a company or another flag administration may take a different approach.

So, what I understand this to mean is that an older UK PSSR certificate may still be valid, but that does not necessarily mean the yacht should do nothing.

The yacht should still ask whether the crew member has received the new information and understands how the vessel’s own procedure works.

The Malta position is slightly different

Malta has also confirmed that training delivered from 1 January 2026 must include the amended content.

For new Maltese Basic Safety Training certification, the course documentation must include wording confirming that the course was amended by IMO Resolution MSC.560(108).

However, certificates issued by Malta before 1 January 2026 remain valid until the expiry date shown on the certificate.

So again, older certificates are not simply cancelled.

But Malta expects the new wording and amended content to appear in documentation connected to training completed from January 2026.

And this gives us a useful example of why captains cannot just look for one universal certificate format.

Different administrations may record compliance differently.

So, what should captains check on the certificate?

For me, this comes down to six basic checks.

Check when the training was completed.

Check when the certificate was issued.

Check which administration or approved provider issued it.

Check whether it has an expiry date.

Check whether the yacht’s flag accepts it.

And check whether the crew member has received the new violence and harassment content.

So I would not reject an older PSSR certificate simply because it does not mention MSC.560(108).

But I also would not assume that a valid certificate means the crew member understands the new requirements.

Those are two different checks.

Crew must understand the continuum of harm

So, this next phrase is a bit of a mouthful.

The amended training refers to the continuum of harm.

What I understand that to mean is that serious misconduct does not always begin with an obvious assault or a major incident.

It can start with smaller behaviours.

Intimidation.

Repeated humiliation.

Sexual comments.

Unwanted attention.

Discriminatory treatment.

Isolation.

Or somebody using their rank or authority to pressure another crew member.

Individually, some of these behaviours may initially be dismissed as joking, personality clashes or part of the pressure of working onboard.

But when they are repeated, tolerated or allowed to escalate, they can form part of a much more serious pattern.

The amended STCW content specifically requires crew to understand violence and harassment, the continuum of harm and the consequences for victims, alleged perpetrators, bystanders and the wider safety and wellbeing of those aboard.

And I think this is particularly relevant aboard yachts.

Crew do not simply work together and then go home at the end of the day.

They work together, live together, eat together and often depend on the same people for their income, references and future employment.

So when there is an abuse of rank or authority, the person affected may feel that speaking up could cost them their position or damage their career.

That seems to be exactly why the new training goes beyond simply identifying physical violence.

It asks crew to recognise the earlier behaviour as well.

Because the earlier it is recognised and addressed, the less chance there is of it developing into something more serious.

Abuse of power is now specifically recognised

This is another point that stood out to me.

The amended training specifically refers to abuse of power relations, discrimination, stress, isolation, fatigue, drugs and alcohol as factors that may contribute to violence and harassment.

Now, if you look at the yachting environment, quite a few of those factors may already be present.

You have a strict hierarchy.

You have long working hours.

You have fatigue.

You have confined living arrangements.

You sometimes have alcohol.

And you may have crew who are completely dependent on a captain, head of department, manager or owner’s representative for their future reference.

So, to me, the abuse-of-power point is not a small detail in the regulation.

It is probably one of the central issues.

Someone may technically have access to a complaint procedure, but still feel unable to use it because the person involved controls their employment, rotation, reference or future career prospects.

That is why the procedure cannot simply exist on paper.

The crew member must have a realistic way to use it without being forced to report through the person they are complaining about.

The training is about response, not only recognition

The new requirement does not stop at recognising harassment.

Crew must also have basic knowledge of what action to take when intervening in and reporting violence and harassment.

They must also understand the basic principles of trauma-informed response and how to support a victim, bystanders and themselves.

So, what does trauma-informed response actually mean in practice?

My understanding is that the first response should not feel like an interrogation.

The person receiving the report should listen.

They should establish whether anybody is in immediate danger.

They should avoid blaming the person raising the concern.

They should explain what is going to happen next.

And they should be careful about forcing somebody to repeat a traumatic account to multiple people unnecessarily.

It does not mean accepting every allegation as proven.

It means receiving the report in a way that does not cause further harm while the facts are being established.

The yacht’s reporting procedure now becomes extremely important

An approved training provider can explain the general principles of reporting.

But it cannot tell a new crew member exactly who to contact aboard a particular yacht.

It cannot tell them who the shoreside manager is.

It cannot tell them how to contact the DPA.

And it cannot explain what to do when the complaint concerns the captain.

That information has to come from the yacht.

So, for me, this is where onboarding becomes extremely important.

A crew member should not simply be given a long policy document, asked to sign the last page and then be expected to understand the process six months later when something goes wrong.

The procedure should be explained.

Who do you speak to first?

Who do you contact ashore?

What if your head of department is involved?

What if the captain is involved?

What happens after you make the complaint?

Who sees the information?

And how do you report retaliation?

Those questions should be answered before an incident occurs.

The captain cannot be the only reporting route

This is probably one of the most important operational points in the whole process.

The captain can be a reporting route.

But the captain cannot be the only reporting route.

For vessels covered by the MLC complaint requirements, seafarers must be able to complain directly to the master and appropriate external authorities.

They must also have the right to be accompanied or represented, and they must not suffer detriment for making a complaint.

Now, this makes complete sense.

Because what happens if the complaint is about the captain?

What happens if the captain is closely connected to the person involved?

What happens if the crew member believes the captain has already taken sides?

Or what happens if the complaint has already been raised aboard and nothing has happened?

The process must allow the crew member to move outside the normal chain of command.

That could mean contacting yacht management, the shipowner, the DPA, the employer, the owner’s representative, the flag administration or an appropriate port-state authority.

For smaller vessels, it may be difficult to find somebody aboard who can provide genuinely impartial advice.

UK guidance recognises this and allows alternative arrangements to be identified in the complaint procedure.

So, for me, the practical rule is quite simple.

The procedure has to work even when the most senior person aboard is part of the problem.

Crew must receive a copy of the procedure

This may sound obvious, but the MLC complaint framework requires seafarers to receive a copy of the onboard complaint procedure.

The procedure should also include relevant contact details and identify the person or people who can offer confidential and impartial assistance.

So, again, this should not be buried somewhere inside a management system that ordinary crew cannot easily access.

A crew member should know where the procedure is.

They should know who the contacts are.

And those contact details should still be current.

Because a procedure containing an old manager’s email address is not really a working procedure.

Protection against retaliation must mean something

The MLC requires protection against victimisation for filing a complaint.

UK rules describe this as protection against suffering any detriment for making a complaint that is not manifestly vexatious or malicious.

The UK procedure also refers to protecting the seafarer and their representative from adverse treatment connected to the complaint.

So, what could retaliation look like?

It could be dismissal.

It could be demotion.

It could be losing a rotation.

It could be a reduction in income.

It could be isolation from the rest of the crew.

It could be pressure to withdraw the complaint.

It could be an adverse reference.

Or it could be somebody suddenly being labelled as difficult after supporting another crew member.

Now, this does not mean that nobody involved in a complaint can ever be dismissed or disciplined again.

An employer may still have a legitimate and independent reason for taking action.

But the closer the action occurs to the complaint, the more important it becomes for the company to show a clear, documented and genuine reason for its decision.

Otherwise, the situation may quite reasonably raise a concern about retaliation.

A complaint that cannot be proven is not automatically malicious

This is another important distinction.

A complaint may be genuine, but difficult to prove.

There may be no witnesses.

There may be no CCTV.

The conduct may have happened inside a cabin or during a private conversation.

Or the available evidence may simply be insufficient to reach a firm conclusion.

That does not automatically mean that the person made a malicious complaint.

A malicious complaint is something quite different.

It suggests that the person knowingly made a false complaint or used the process dishonestly.

So captains and managers need to be very careful about treating an unsubstantiated complaint as proof that the complainant lied.

“Not substantiated” and “false” are not the same finding.

What people often call an IMO complaint

This is another area where the terminology can become confusing.

People may refer to making an “IMO complaint.”

But, as I understand it, the IMO normally creates the international rules and frameworks.

It does not usually act as the employment tribunal or investigation body deciding an individual crew dispute.

An individual complaint would normally move through the yacht’s onboard procedure, the shipowner or management company, the flag administration, a port-state authority, a national court, an employment tribunal or law enforcement, depending on what happened.

So what people describe as an IMO complaint may actually be an MLC complaint, a flag-state complaint or a report made under a national maritime process.

That distinction matters because the person making the complaint needs to know which body can actually investigate the issue and provide a remedy.

There is no single global complaint-handling process

This is where I need to be careful.

There is no one identical complaint procedure that applies to every yacht in every jurisdiction.

The exact process will depend on the vessel’s flag, whether the MLC applies, whether the yacht is commercial or private, the crew member’s employment contract, the company procedure and the law in the place where the incident occurred.

But when I work through the MLC requirements and the flag-state guidance, there is a fairly clear practical process that I would expect to see.

So this is not a substitute for flag or legal advice.

It is my understanding of what a sensible working process should look like.

Step 1: Make the immediate situation safe

The first priority is not to decide whether the allegation is true.

The first priority is to determine whether anyone is currently unsafe.

Does anybody need medical assistance?

Is the alleged behaviour continuing?

Do the people involved need to be separated?

Could other crew members be at risk?

Is there a risk of intimidation or retaliation?

And could the conduct amount to a criminal offence?

The captain’s first responsibility is to stabilise the situation.

The detailed investigation comes afterwards.

Step 2: Identify the correct reporting route

The next step is to work out who should receive the report.

Normally, that may be a head of department, senior officer or the captain.

But where one of those people is involved, the process should bypass them.

The crew member should not be told to report the complaint through the person they are complaining about.

If the issue cannot be handled impartially aboard, it should move ashore.

Cayman guidance for ships, including yachts, follows a similar structure. It starts with a responsible person aboard, then moves to shoreside management and finally to the flag administration where the complaint is not properly addressed or the crew member does not feel safe using the normal route.

Step 3: Receive the report properly

The person receiving the report should listen and establish the immediate facts.

They should not begin with aggressive questioning.

They should not blame the person raising the concern.

And they should not make promises that cannot be kept.

For example, it may not be possible to promise complete confidentiality.

Some information may need to be shared with shoreside management, medical professionals, the flag administration, legal advisers or law enforcement.

So the better approach is to explain that the information will be restricted to the people who genuinely need it in order to respond.

Step 4: Record what was actually reported

The initial record should be factual and neutral.

It should distinguish between:

• what the person says happened;

• what the person receiving the report directly observed;

• when and where the incident allegedly occurred;

• who may have witnessed it;

• what evidence may exist;

• what immediate action was taken;

• who has been informed.

The record should state that an allegation has been made.

It should not record the allegation as an established fact before the matter has been properly investigated.

For UK MLC-covered vessels, complaints and the associated decisions must be recorded, and copies must be provided to the seafarer.

Step 5: Allow the person to have support or representation

The MLC complaint process includes the right for a seafarer to be accompanied or represented.

UK requirements state that a seafarer must have the right to be accompanied or represented by another seafarer of their choice.

That is important because the person may feel overwhelmed, intimidated or uncertain about the process.

Depending on the seriousness of the matter, they may also need access to medical, psychological, legal, union or welfare support.

Step 6: Notify the correct people ashore

A serious complaint should not be left for the captain to manage alone.

Depending on the yacht’s structure, the relevant shoreside people may include:

• the DPA;

• yacht management;

• the shipowner;

• the employing company;

• HR;

• the owner’s representative;

• legal advisers;

• insurers;

• the flag administration.

The procedure should say who needs to be notified and who is responsible for making that notification.

Otherwise, there is a real risk that everybody assumes somebody else is handling it.

Step 7: Preserve the evidence

Potential evidence may include messages, emails, photographs, CCTV, access records, watch schedules, cabin allocations, medical records, witness details and notes made at the time.

The important point is to preserve the evidence without interfering with it.

A captain or yacht manager should not try to become an amateur criminal investigator.

Where serious violence or sexual assault is alleged, law enforcement or another competent authority may need to control the investigation.

Cayman guidance, for example, treats sexual assault as a criminal matter that should be reported to the relevant authorities without delay, partly so evidence can be properly preserved.

Step 8: Put temporary safeguards in place

While the matter is being assessed, temporary measures may be necessary.

That could mean separating people.

Changing watches.

Changing accommodation.

Restricting contact.

Protecting witnesses.

Arranging medical support.

Or temporarily removing someone from duty.

But these are interim safeguards.

They are not a final finding of guilt.

And the yacht should also be careful not to punish the complainant by automatically removing them from the vessel, reducing their pay or damaging their rotation while leaving the other person unaffected.

Step 9: Appoint somebody impartial to investigate

The person investigating the complaint should not be the person complained about.

They should not have a personal or financial conflict.

And they should not be somebody who has already decided what the outcome should be.

The investigator’s role is to establish the facts.

The employer or authorised management body can then make the relevant employment or disciplinary decision.

Where possible criminal conduct is involved, the internal investigation should not interfere with a police or flag-state investigation.

Step 10: Keep the people involved informed

The person making the complaint should know that the report has been received.

They should know who is handling it.

They should understand what immediate safeguards have been introduced.

They should know what the next stage is.

And they should know how to report retaliation.

The person complained about should also be treated fairly and given a proper opportunity to respond, subject to any safety or evidence-preservation concerns.

A fair process protects everybody involved.

Step 11: Record the outcome

The final record should explain what was investigated, what evidence was considered and what conclusion was reached.

The findings may be substantiated.

They may be unsubstantiated.

Or they may be inconclusive.

The record should also explain what action was taken, whether an outside authority was informed and whether there is any right of appeal or review.

On UK MLC-covered vessels, if a complaint cannot be resolved aboard within the agreed timeframe, it must be referred ashore to the shipowner. The shipowner must also provide a right of appeal where the seafarer remains dissatisfied.

Step 12: Monitor for retaliation afterwards

This is the point that can easily be missed.

The process does not end when the complaint is closed.

Management should continue watching for dismissal, non-renewal, demotion, lost rotations, exclusion, hostile references or pressure from colleagues.

Any later employment decision affecting the complainant, their representative or an important witness should have a clear and independently documented reason.

Because otherwise, even where the original complaint was handled correctly, the company may still create a second problem through retaliation.

Sexual harassment and sexual assault should not be treated as the same process

Sexual harassment may initially be handled through an employment, disciplinary or civil complaint process.

Sexual assault may be a criminal offence.

That means it may need to be reported immediately to law enforcement, the flag administration or the relevant authorities in the jurisdiction where the incident occurred.

Cayman guidance makes this distinction very clearly.

It describes sexual assault as a criminal matter and states that the relevant authorities should handle it. Where the incident occurs at sea, the flag State will normally have an important jurisdictional role.

So a yacht should not treat every serious allegation as nothing more than an internal HR matter.

Who is responsible when something is reported?

This is where the question of liability often comes up.

And the honest answer is that liability cannot be determined from the STCW amendment alone.

It will depend on the flag, the applicable employment law, whether the MLC applies, the vessel’s status, the location of the incident and what each person actually did or failed to do.

But the operational responsibilities are easier to understand.

The captain is responsible for immediate safety aboard, activating the correct process, protecting evidence and escalating the matter.

The shipowner or employer is generally responsible for providing the procedure, training, shoreside support and a safe working environment.

Yacht management or the DPA should provide a route beyond the vessel and help ensure the complaint is handled independently.

The flag administration may inspect, investigate or take regulatory action.

And law enforcement determines whether criminal offences have occurred.

A captain is not automatically personally liable because misconduct happened aboard.

But the situation could change if the captain participated in the conduct, suppressed the complaint, retaliated, destroyed evidence or deliberately failed to carry out a legal duty.

What happens if the complaint concerns the captain?

If the complaint concerns the captain, the captain should not control the investigation.

The procedure should direct the crew member to an alternative contact.

That may be the DPA, yacht manager, shipowner, employer, owner’s representative or flag administration.

And this is why the alternative route must be created before a complaint occurs.

It is too late to design an impartial process after the captain has already become part of the dispute.

What about private yachts that are not covered by the MLC?

This is another area where the answer can vary.

The MLC framework is mainly aimed at commercial vessels and seafarers within its scope.

A private pleasure yacht may not be subject to the same MLC certification and complaint requirements.

But that does not mean crew aboard a private yacht have no protection.

Flag-state law, criminal law, employment law, contract terms and general safety obligations may still apply.

Cayman’s guidance specifically says that the absence of MLC compliance should not be treated as a barrier to obtaining a remedy aboard a private yacht. It also strongly encourages private yachts to implement harassment policies even where the MLC does not strictly require them.

So the practical advice is still the same.

Check the yacht’s exact flag and operational status.

Do not assume that “private” means there are no reporting or safeguarding obligations.

The captain’s certification checklist

Check each crew member’s PSSR or Basic Safety Training documentation.

Record when the training was completed.

Confirm who issued it.

Check its validity and expiry date.

Confirm that it is accepted by the yacht’s flag administration.

And determine whether the crew member still needs familiarisation with the January 2026 content.

The captain’s onboarding checklist

Explain what behaviour is prohibited.

Show crew where the complaint procedure is located.

Identify the onboard and shoreside reporting contacts.

Explain how to bypass the normal chain of command.

Explain the limits of confidentiality.

Explain the right to support or representation.

And explain how retaliation can be reported.

The captain’s reporting checklist

Make the immediate situation safe.

Identify the correct reporting route.

Receive the report without blame or aggressive questioning.

Record the allegation accurately.

Preserve evidence.

Notify the correct people ashore.

Put temporary safeguards in place.

Use an impartial investigator.

Keep the parties informed.

Record the outcome.

And monitor for retaliation afterwards.

The point I keep coming back to

The January 2026 amendment is a training change.

It does not create one universal complaint form.

It does not establish one identical investigation process for every yacht.

And it does not automatically invalidate every older PSSR certificate.

But it does change the position in a very practical way.

Crew are now being formally trained to identify, intervene in and report violence and harassment.

So yachts need to make sure that when a crew member does report something, there is a process capable of receiving it, protecting the people involved and handling it properly.

The certificate is only one part of that process.

The real test is whether the system works when somebody actually needs to use it.

This article reflects my understanding of the current STCW, MLC and flag-state guidance. It provides general operational information and should not be treated as legal advice. Yacht-specific requirements should be confirmed with the vessel’s flag administration, management company and qualified maritime or employment advisers.