Law Updates

Subject

Summary: India has notified the Merchant Shipping (Prevention of Air Pollution from Ships) Rules, 2026, marking a significant step towards strengthening environmental compliance across the maritime sector. Issued under the Merchant Shipping Act, 2025, the Rules align India's shipping regulations with the internationally accepted standards prescribed under MARPOL Annex VI while introducing a structured framework for controlling air pollution from ships. Unlike earlier environmental requirements that focused primarily on technical compliance, the new framework places greater emphasis on continuous environmental performance. Ship owners and operators will now need to integrate environmental compliance into regular operations through regular monitoring, reporting, vessel surveys and certification. Key Regulatory Highlights Establishes a comprehensive framework for preventing air pollution from ships. Aligns India's maritime regulations with MARPOL Annex VI. Introduces stricter requirements relating to air emissions, fuel quality, energy efficiency and carbon intensity monitoring. Expands mandatory ship surveys, environmental certification and compliance reporting. Encourages continuous environmental performance instead of one-time regulatory compliance. Supports India's commitment towards cleaner and more sustainable maritime operations. Who Will Be Affected? The Rules are likely to affect a broad spectrum of stakeholders in the maritime sector, including: Owners and operators of ships. Vessel managers and fleet management companies Floating production units, offshore platforms Fuel Suppliers/Bunker Service Providers Shipyards and known organisations Environmental, compliance and ESG teams of shipping companies Why This Matters for Maritime Businesses For businesses engaged in international shipping, regulatory alignment extends beyond legal compliance. Many overseas ports, charterers, cargo owners, insurers, and financial institutions increasingly consider a company's environmental performance when evaluating commercial relationships. A compliance framework that follows internationally recognised standards can help businesses: Business Area Potential Impact International Operations Greater consistency in meeting environmental compliance expectations across jurisdictions. Commercial Relationships Demonstrates commitment to globally accepted environmental practices. Operational Planning Supports standardised compliance procedures for domestic and international voyages. Long-Term Sustainability Encourages investments in cleaner technologies and energy-efficient fleet management. Why This Matters for Businesses The notification is more than an environmental regulation for maritime businesses. It can potentially affect fleet planning, fuel sourcing, maintenance plans, environmental reporting, and long-term investments. Early assessment of these requirements will enable organisations to better control compliance costs, minimise operational risk and prove that they are meeting changing international environmental standards. What Are the Merchant Shipping (Prevention of Air Pollution from Ships) Rules, 2026? The Merchant Shipping (Prevention of Air Pollution from Ships) Rules, 2026 are India's first comprehensive rules to prevent air pollution caused by ships. The Rules are notified under the Merchant Shipping Act, 2025 and align Indian maritime environmental laws with the internationally recognised standards under MARPOL Annex VI. The framework does not impose one single environmental requirement, but considers various aspects of the operation of the vessels, such as emissions, fuel quality, energy efficiency, environmental certification and carbon performance. The goal is to lower the environmental footprint of shipping, while establishing a structured compliance system to facilitate safer, cleaner and more sustainable shipping operations. The Rules introduce compliance requirements relating to: Air emissions from marine diesel engines. Fuel oil quality and sulphur limits. Restrictions on ozone-depleting substances used on board. Energy efficiency standards for new and existing ships. Carbon Intensity Indicator (CII) monitoring and reporting. Ship Energy Efficiency Management Plans (SEEMP). Mandatory environmental surveys, inspections, and certification. At a Glance Aspect What the Rules Cover Environmental Protection Prevention and control of air pollution from ships. Energy Efficiency EEDI, EEXI and operational efficiency requirements. Emission Control NOx, SOx and ozone-depleting substances. Operational Compliance Fuel monitoring, carbon reporting and recordkeeping. Regulatory Oversight Surveys, inspections and environmental certification. While many environmental regulations focus on a specific compliance obligation, these Rules adopt a lifecycle approach. Compliance is no longer assessed only when a vessel is built or inspected. Instead, ship owners and operators are expected to demonstrate continued environmental performance through regular monitoring, documented records, periodic surveys, and ongoing compliance reporting. Why Has India Introduced These New Air Pollution Rules for Ships? The shipping industry is undergoing one of its biggest environmental transformations in decades. As global trade continues to expand, regulators are placing greater emphasis on reducing the environmental impact of maritime transport without disrupting international commerce. India has introduced the Merchant Shipping (Prevention of Air Pollution from Ships) Rules, 2026 as part of this broader transition, ensuring that its maritime regulations remain aligned with internationally accepted environmental standards while supporting cleaner and more sustainable shipping practices. The Rules are mainly for controlling air pollution from ships, but they are not only about emission control. They create a structured compliance system that encourages responsible fuel consumption, better vessel efficiency, ongoing environmental monitoring and increased operational accountability throughout a vessel's lifecycle. What Is Driving This Regulatory Shift? Several international and domestic developments have contributed to the introduction of the new Rules. Regulatory Driver Business Significance Alignment with MARPOL Annex VI Brings India's maritime regulations closer to internationally accepted environmental standards, supporting smoother international shipping operations. Growing Focus on Decarbonisation Encourages the shipping industry to reduce emissions and improve environmental performance over the long term. Energy Efficiency Requirements Promotes better fuel management and efficient vessel operations to reduce operational emissions. Global ESG Expectations Supports increasing investor, customer, and stakeholder expectations around sustainable business practices. Strengthening Environmental Governance Creates a more structured compliance framework through surveys, certification, reporting, and ongoing monitoring. These developments signify that environmental compliance is becoming a vital part of maritime operations and not just a regulatory obligation. The requirement for businesses to comply with technical standards is growing, and they are also expected to maintain their environmental performance throughout a vessel's operational life. How Do the Rules Align with MARPOL Annex VI? When shipping internationally, vessels may be subject to several jurisdictions, making regulatory consistency crucial. The Rules also reflect the regulations of MARPOL Annex VI and have been incorporated into the domestic legislation of India to provide a common environmental standard for Indian flagged ships. For companies involved in international trade, this alignment is especially crucial because there is a growing focus by many overseas ports, charterers, cargo owners and financial institutions on environmental compliance as well as operational performance. A regulatory framework which is based on internationally accepted standards can mitigate compliance uncertainties and enable shipping companies in India to function more effectively in the international market. Key Compliance Changes under the Merchant Shipping Rules, 2026 The Merchant Shipping (Prevention of Air Pollution from Ships) Rules, 2026 introduce an extensive range of environmental compliance measures which are beyond emission control. The framework applies to the design, operation, monitoring, inspection and certification of ships during their operational life. For shipping businesses, compliance will be increasingly reliant on keeping technical standards and accurate documentation, environmental reporting and continuous operational monitoring. The following are some of the most significant compliance changes introduced under the new Rules. 1. Air Emission Standards A key objective of the Rules is to reduce emissions released from ships by prescribing standards for marine diesel engines and other emission sources. Instead of limiting compliance to the construction stage, the framework requires vessels to continue meeting prescribed emission requirements throughout their service life. Key requirements Adherence to emission limits for applicable marine diesel engines. Engine performance inspection and maintenance periodically. Documentation of engine modifications and repairs. Verification of compliance during prescribed surveys and inspections. 2. Fuel Oil Quality Requirements The quality of fuel used on board directly influences the level of pollutants released into the atmosphere. To address this, the Rules prescribe standards for fuel oil quality, including sulphur content, while strengthening documentation requirements relating to fuel procurement and usage. Shipping companies should review: Fuel procurement procedures. Bunker delivery documentation. Fuel quality verification processes. Internal recordkeeping practices. 3. Nitrogen Oxides (NOx) and Sulphur Oxides (SOx) Controls The Rules introduce specific controls for emissions of Nitrogen Oxides (NOx) and Sulphur Oxides (SOx), both of which contribute significantly to air pollution from ships. Compliance requirements may vary depending on factors such as engine type, vessel category and operational profile. Organisations operating existing fleets should periodically assess whether installed engines, emission control equipment and fuel management practices continue to satisfy the applicable standards. 4. Restrictions on Ozone-Depleting Substances The Rules also regulate equipment and systems containing ozone-depleting substances (ODS) with the objective of reducing emissions that contribute to ozone layer depletion. Businesses should pay attention to: Equipment containing regulated substances. Installation and replacement records. Servicing and maintenance activities. Recovery and disposal procedures. Documentation maintained for inspections. Effective inventory management will become increasingly important where ships continue to operate equipment containing regulated substances. 5. Energy Efficiency Standards (EEDI & EEXI) The Rules incorporate internationally recognised Energy Efficiency Design Index (EEDI) and Energy Efficiency Existing Ship Index (EEXI) requirements to improve the energy performance of ships. These standards encourage ship owners to enhance vessel efficiency through better design, technical upgrades, and operational improvements. Standard Purpose EEDI Promotes energy-efficient design for new ships by establishing minimum efficiency standards during construction. EEXI Assesses the energy efficiency of existing ships and may require technical or operational improvements where applicable. 6. Carbon Intensity Indicator (CII) One of the most significant operational changes introduced by the Rules is the adoption of the Carbon Intensity Indicator (CII) framework. Rather than measuring emissions alone, CII evaluates how efficiently a ship transports cargo in relation to the carbon emissions it generates during operation. This may involve: Monitoring annual carbon intensity performance. Maintaining operational data required for CII calculations. Identifying vessels with declining efficiency. Implementing corrective measures where required. 7. Ship Energy Efficiency Management Plan (SEEMP) The Rules require applicable ships to maintain a Ship Energy Efficiency Management Plan (SEEMP) that outlines how energy efficiency will be monitored and improved during vessel operations. An effective SEEMP typically includes: Energy efficiency objectives. Fuel consumption monitoring procedures. Operational improvement measures. Performance review mechanisms. Continuous improvement strategies. 8. Fuel Consumption Monitoring and Reporting Fuel consumption data plays an important role in demonstrating compliance with several environmental obligations introduced under the Rules. Maintaining reliable records helps support carbon intensity assessments, environmental reporting and regulatory inspections.  Businesses should establish systems for: Collecting fuel consumption data. Maintaining on-board records. Verifying reported information. Preserving documentation for inspections. 9. Mandatory Surveys The Rules introduce a structured survey framework to verify continued compliance throughout the operational life of a vessel. Survey Purpose Initial Survey Before the ship enters service. Renewal Survey Before certificate renewal. Intermediate Survey Conducted during the certificate validity period. Annual Survey Confirms continued compliance. Additional Survey Required after significant alterations or repairs, where applicable. 10. Environmental Certification Requirements Applicable ships must maintain valid environmental certificates issued after prescribed surveys to demonstrate compliance with the Rules. Certification may relate to: Air pollution prevention  Energy efficiency  Carbon performance  Other prescribed environmental requirements Who Must Comply with the Merchant Shipping Rules, 2026? The Merchant Shipping (Prevention of Air Pollution from Ships) Rules, 2026 apply to a broad range of ships and maritime stakeholders, depending on the type of vessel, its operation, and the specific compliance requirement. While many provisions are aligned with MARPOL Annex VI, businesses should carefully assess the applicability of individual requirements rather than assuming that every provision applies uniformly to all vessels. Understanding whether the Rules apply to your operations is the first step towards planning surveys, certification, reporting and environmental compliance. Businesses That May Be Affected The Rules are relevant to several stakeholders across the maritime ecosystem, including: Ship owners  Ship operators  Fleet management companies  Ship managers  Charterers with operational responsibilities  Offshore platforms and mobile offshore units (where applicable)  Floating storage and production units covered under the Rules  Recognised Organisations (ROs) authorised to conduct surveys and certification  Shipyards undertaking vessel construction, conversion or major modifications  Environmental, technical, and compliance teams within shipping companies  Applicability across Different Types of Ships Not all compliance requirements apply to all vessels. Specific provisions may be applicable depending on vessel size, type of engine, construction date, trading, operating profile, etc. Category Applicability Indian-flagged ships Subject to the applicable provisions of the Rules. Ships on international voyages Required to comply with applicable environmental standards and certification requirements. Existing ships May need to comply with operational, survey, reporting, and efficiency requirements based on applicability. New ships May be required to meet additional design and energy efficiency standards during construction. Offshore installations and floating units Certain provisions may apply depending on the type of unit and its operations. Businesses should review the specific provisions applicable to each vessel rather than adopting a fleet-wide assumption. Are Any Ships Exempt? Like most maritime regulations, the Rules include provisions where certain ships, vessel categories, or operational situations may be exempt from specific requirements. These exemptions are subject to the conditions prescribed under the Rules and should be evaluated carefully before relying on them. Examples may include: Vessel categories specifically excluded under the Rules.  Temporary exemptions permitted under defined circumstances.  Situations where alternative compliance measures are recognised.  Shipping companies should verify the scope of any exemption before assuming that a vessel is outside the regulatory framework. What Will Be the Commercial Impact on Maritime Businesses? The Merchant Shipping (Prevention of Air Pollution from Ships) Rules, 2026 will influence not only environmental compliance but also fleet operations, documentation, fuel management, and long-term business planning. The extent of the impact will depend on the type of vessels operated and the company's existing compliance readiness. Key Business Impacts Area Potential Impact Fleet Management Assessment of existing vessels for emission and energy efficiency compliance. Technical Upgrades Possible engine modifications or equipment upgrades for applicable ships. Fuel Management Greater focus on compliant fuel procurement and documentation. Compliance Reporting Increased monitoring, recordkeeping, and environmental reporting. Surveys & Certification Regular surveys and timely renewal of environmental certificates. Business Costs Additional investment in compliance systems, upgrades, and training. Shipping companies that assess these requirements early can plan technical upgrades, allocate budgets, and strengthen internal compliance processes before regulatory obligations become more demanding. Business Benefits of Early Compliance While the Rules introduce new environmental obligations, early compliance can also provide operational and commercial advantages. Businesses that proactively align their vessels and compliance systems with the new framework are likely to be better positioned for future regulatory changes. Potential benefits include: Reduced risk of delays during surveys and inspections. Better preparedness for environmental audits and certification. Improved operational efficiency through enhanced fuel and energy management. Stronger ESG and sustainability credentials. Greater confidence among customers, investors, and business partners. Better readiness for future IMO and environmental compliance requirements. Early planning also allows shipping companies to spread compliance costs over time, prioritise fleet upgrades, and avoid last-minute operational disruptions. Compliance Challenges Businesses Should Prepare For Implementing the new framework may present practical challenges, particularly for organisations operating older vessels or large fleets. Identifying these challenges early can help businesses plan resources, budgets and compliance activities more effectively. Common challenges include: Upgrading ageing vessels to meet applicable standards. Managing environmental documentation and reporting. Monitoring fuel consumption and carbon performance. Planning periodic surveys and certificate renewals. Training crew and operational teams on new compliance procedures. Coordinating technical, operational, and compliance functions across the fleet. The extent of these challenges will vary depending on fleet size, vessel type, and the organisation's existing compliance systems. Early assessment can help businesses prioritise actions and minimise operational disruptions. What Should Shipping Companies Do Next? With the Rules introducing new environmental and operational requirements, shipping companies should begin evaluating their compliance readiness. A structured approach can help minimise implementation challenges and ensure timely compliance. 1. Assess Applicability Determine which aspects of the Rules are relevant to your vessels, depending on their type, size, operating profile, and trading routes. 2. Review Fleet Compliance Assess compliance of current ships with emission standards, energy efficiency and pollution prevention measures. 3. Verify Documentation Review fuel records, technical documents, certificates and on board compliance records to identify any gaps. 4. Plan Surveys and Certification Schedule mandatory surveys and ensure environmental certificates remain valid and are renewed on time. 5. Strengthen Monitoring Systems Establish effective fuel consumption tracking, environmental reporting and recordkeeping systems. 6. Review Operational Procedures Review and revise internal fuel management, maintenance, inspections and environmental compliance procedures. 7. Train Key Personnel Ensure technical teams, vessel operators, and compliance personnel understand the new regulatory requirements and their responsibilities. 8. Monitor Future Regulatory Updates Environmental regulations continue to evolve. Regularly reviewing new amendments and IMO developments will help businesses remain compliant over the long-term. How Corpseed Can Help Understanding and implementing the Merchant Shipping (Prevention of Air Pollution from Ships) Rules, 2026 requires careful regulatory planning and ongoing compliance management. Corpseed supports maritime businesses with practical compliance solutions tailored to their operational requirements. 1. Regulatory Compliance Advisory Our experts help businesses understand the new regulatory framework and assess its applicability to their vessels and operations. Our services include: Applicability assessment under the Merchant Shipping Rules, 2026  Interpretation of regulatory requirements  Compliance roadmap development  Ongoing regulatory updates and advisory  2. Environmental Compliance Assessment We assist businesses in evaluating their current compliance status and identifying areas that may require corrective action before inspections or certification. Support includes: Fleet compliance assessment  Gap analysis against applicable requirements  Review of environmental compliance records  Recommendations for compliance improvements  3. Documentation and Certification Support Maintaining accurate documentation is essential for demonstrating compliance during surveys and inspections. Corpseed assists businesses in preparing and reviewing the required compliance documentation. Support includes: Review of technical and environmental records  Documentation for surveys and inspections  Assistance with environmental certification requirements  Compliance document management support  4. Survey and Inspection Readiness Preparing in advance for regulatory inspections can help minimise delays and compliance observations. Our assistance includes: Pre-survey compliance review  Inspection readiness assessment  Review of supporting documentation  Guidance on corrective actions, where required  5. Ongoing Maritime Compliance Support Environmental compliance is a continuous process. Corpseed provides ongoing advisory to help businesses stay aligned with changing maritime regulations and environmental requirements. Our support covers: Regulatory monitoring and updates  Periodic compliance reviews  Environmental reporting guidance  Advisory on future amendments and compliance obligations