Beyond the horizon: The promises and challenges of autonomous shipping

Introduction

Autonomous vessels are set to revolutionise the shipping industry, whereby they will gradually and eventually transform global maritime trade through advances in artificial intelligence (“AI”), sensor technologies and remote operations. As traditional shipping faces ever-growing challenges – from aging fleets to rising safety concerns to ever-increasing environmental rules and regulations – autonomous ships offer a compelling solution that promises increased efficiency and safety whilst simultaneously reducing carbon emissions and operational costs.

Whereas fully unmanned ships remain on the horizon, 2025 marks a pivotal milestone as semi-autonomous ships enter practical commercial service, leveraging remote control centres and advanced AI-driven navigation to optimise routs, enhance situational awareness and mitigate human error. Supported by regulatory frameworks and rapid technological advancements, autonomous shipping is set to become a cornerstone of the maritime industry, ushering in a new era where intelligent machines and human oversight work cohesively to redefine how goods move across our oceans.

The IMO’s Involvement

For the past few years, the International Maritime Organization (“IMO”) has already been laying the groundwork for the eventual widespread introduction of autonomous ships into the shipping industry. The aim of the IMO is to regulate new and advancing technologies through its framework, whereby they seek to balance the benefits from said technologies against concerns of security and safety, the impact on the environment and on the facilitation of international trade, the potential costs to the shipping industry and their impact on personnel, both onboard and on shore. IMO wants to ensure the framework regulating Maritime Autonomous Surface Ships (“MASS”) keeps up the rapidly evolving technological developments.

Following the completion of the IMO’s scoping exercise on MASS back in 2021, the main goal of which was to assess which existing IMO instruments could apply to ships of varying degrees of automation, the Maritime Safety Committee (“MSC”), through its 109th session, agreed to a revised roadmap for the development of an official MASS Code. The scoping exercise covered four degrees of autonomy regarding MASS, these being:

1. Ships with automated processes and decision support systems. Seafarers are still present onboard to operate and control the ship’s systems and functions. Certain operations may be automated and at times unsupervised, with seafarers onboard ready to take control in case of malfunctions or errors.
2. Remote-controlled ships with seafarers on board. The ship is controlled and operated from another location whereby seafarers are available onboard to take and operate the ship’s systems and functions.
3. Remote-controlled ships without seafarers on board. The ship is controlled from another location without the presence of the human element onboard.
4. Fully autonomous ships. The operating system of these ships would be able to make decisions and determine specific actions by itself.

The outcome of this scoping exercise highlighted a number of critical issues which were present across several of the IMO’s instruments, whereby these involved the creation of MASS terminology and definitions, including an internationally agreed definition of MASS and clarification on the definitions of “master”, “crew” and “responsible person”, particularly in Degrees Three (remote-controlled ships) and Four (fully autonomous ships) as described earlier.

Other key issues identified included the need to address the functional and operational requirements of the remote-control station/centre and the possible designation of a remote operator as seafarer. Further potential gaps that were identified related to manual operations and alarms on the bridge, provisions related to actions by personnel such as firefighting, cargo stowage and securing, maintenance, search and rescue, watchkeeping and information required to be kept onboard for safe operation of the ship.

At the following session, at MSC 110, the abovementioned roadmap was fine-tuned and the committee agreed on the following milestones:

• MSC 111 (scheduled for May 2026) will aim to finalise and adopt the non-mandatory MASS Code;
• MSC 112 (scheduled for December 2026) will seek to develop a framework for the Experience-Building Phase (“EBP”) of MASS;
• The IMO plans to kickstart development of the mandatory MASS Code in 2028, based on the non-mandatory MASS Code and results from the EBP;
• By 1st July 2030 at the latest, the goal is to have widespread adoption of the mandatory MASS Code, whilst its entry into force is scheduled for 1st January 2032,
  at the earliest.

It is important to keep in mind that the non-mandatory MASS will merely act as a supplement to The International Convention on the Safety of Life At Sea (“SOLAS”) and that its entry into
force will not automatically relax any of the requirements as laid out under the latter. Exemptions from the requirements of SOLAS must be agreed upon by the flag State during the approval process of the non-mandatory MASS Code.

Key issues that are yet to be addressed are the roles and responsibilities of both the master and the remote operator, general questions surrounding liability and the onboard carriage of certificates. The IMO determined that its internal committees are to discuss these issues at future meetings before taking an official position on the way forward, seeing as this will affect the global shipping industry.

Benefits of Autonomous Ships

Autonomous ships offer significant operational advantages reducing human error, lowering crew-related costs and enhancing overall safety. One of the biggest achievements would be mitigation of human error, seeing as it is the cause behind 96% of all maritime incidents. The advanced AI and sensor systems onboard autonomous ships enable precise navigation and real-time hazard detection, which lead to fewer accidents, thus performing overall safer voyages.

Moreover, autonomous vessels optimise route planning and engine performance, ensuring improved fuel efficiency and reduced operating costs. The reduction, and eventual elimination
of onboard crew requirements not only cuts costs of labour but also allows ships to be designed with more cargo space, further enhancing economic viability.

On the environmental front, autonomous ships contribute to cleaner maritime operations by minimising fuel consumption through optimised navigation and the integration of alternative, low-emission fuels. These vessels are equipped with sophisticated monitoring systems that swiftly detect and mitigate environmental risks such as oil spills or leaks. By supporting smarter logistics and reducing unnecessary voyages, autonomous shipping plays a crucial role in meeting global decarbonisation goals, ultimately fostering a safer and more sustainable maritime industry.

Autonomous ships, by virtue of their advanced automation and optimised operation, are estimated to significantly reduce fuel consumption and greenhouse gas emissions, thereby aligning with European Union’s (“EU”) stringent emission reduction targets, one of these being the EU Emission Trading System (“EU ETS”).

EU ETS, which operates on a cap-and-trade principle, enables shipping companies buy and sell allowances for their emissions, meaning that autonomous vessels could benefit from lower allowance costs due to their cleaner operations. This creates an incentive for shipping operators to adopt MASS technologies, as the reduced emissions directly translate into fewer allowances needed and thus, lower compliance costs and aligning with the market-driven push towards a globally greener shipping sector.

Furthermore, the EU’s ongoing integration of carbon removal technologies highlights a broader policy environment where innovations like MASS can contribute significantly to achieving ambitious net-zero goals while benefiting from and contributing to a sustainable, market-based climate policy system.

The Pitfalls of Autonomy

Autonomous ships, whilst offering revolutionary benefits, come with significant challenges that must be addressed to ensure their safe and reliable integration into the maritime industry. One of the foremost concerns is cybersecurity. These vessels, being heavily dependent on digital communication and automated control systems, are vulnerable to sophisticated cyberattacks.

Such breaches could disrupt navigation, impair situational awareness or even hijack control of the ship, potentially leading to collisions, environmental disasters or theft of cargo. Given the complexity of integrating operational technology with information technology systems, the security framework for autonomous ships requires robust design, continuous monitoring, and real-time anomaly detection to effectively mitigate these risks.

Operationally, autonomous vessels face technical and regulatory pitfalls. The reliability of AI in interpreting complex and unpredictable maritime environments remains a challenge, especially under adverse weather or congested port conditions. Additionally, the legal landscape has yet to fully catch up, with ambiguities surrounding insurance coverage and compliance with international maritime conventions.

The human element also plays a major role as the transition to autonomous operations confronts resistance from seafarers concerned about job security and highlights the need for new training paradigms for remote operators and shore-based personnel. Lastly, the high upfront investment costs and the infrastructural changes required to accommodate autonomous ships add layers of financial and logistical complexity that may slow widespread adoption. Overall, these challenges call for a cautious, phased implementation strategy coupled with ongoing technological innovation and international regulatory cooperation.

Conclusion

The rise of autonomous vessels represents a transformative leap for the shipping industry, bringing with it promises to enhance safety, efficiency and environmental sustainability whilst simultaneously reshaping fundamental operational standards and principles. Central to this evolution is the proactive role of the IMO in developing a comprehensive regulatory framework tailored to MASS.

With the IMO’s ongoing efforts culminating in the forthcoming MASS Code, regulations are being crafted to address critical aspects such as navigation autonomy, safety management, liability and crew responsibilities both in remote and in fully autonomous operations. This regulatory progression not only facilitates innovation but also ensures that autonomous ships integrate seamlessly and safely into the global maritime ecosystem, setting the course for a future where autonomous shipping becomes the industry’s new standard.

Disclaimer: Ganado Advocates is responsible for contributing to this law report but was not in any way involved as legal advisor for the parties in the judgement being covered in this law report. This article was first published in ‘The Malta Independent’ on 10/12/2025.