Non-Compliance with Paris MoU Pre-Arrival and Notification Requirements

2026 Aug

Non-Compliance with Paris MoU Pre-Arrival and Notification Requirements

CIRCULAR Circular No. 011 (Amended)
SUBJECT Non-Compliance with Paris MoU Pre-Arrival and Notification Requirements
FROM Office of the Maritime Administrator, Vanuatu International Shipping Registry
TO All shipowners, managers, operators, masters and Special Agents of vessels trading in the Paris MoU region
AMENDMENT DATE 20 August 2026
EFFECTIVE DATE Upon publication
STATUS Version 2.0 – Supersedes the prior version of Circular No. 011


Authority and legal status. This Circular is issued by the Maritime Administrator under the functions and powers conferred by the Maritime Act [CAP 131], as amended by the Maritime (Amendment) Act No. 21 of 2025, including section 10C where applicable, and any additional written authority lawfully applicable to the subject. It shall be read with applicable mandatory IMO instruments and controlled VISR policies. It does not convert a direct statutory power into a delegated power, transfer a function assigned by law to another State entity, or amend any valid appointment, concession or other governing instrument.

Related controlled policies: VISR-QMS-POL-PSC-008 – International Fleet PSC Performance, Detention and Corrective Action Policy; VISR-QMS-POL-CI-002 – IMSAS Compliance, Internal Audit, Corrective Action and Continual Improvement Policy; VISR-QMS-POL-REC-005 – Document and Records Control, Retention and IMSAS Evidence Management Policy.


1. Purpose
This Circular establishes consequences for failure to comply with Circulars Nos. 002 and 010, including failure to submit a pre-arrival checklist, conceal known deficiencies, ignore a direction for inspection or audit, or delay reporting a PSC inspection or detention.

2. Examples of non-compliance
• Late, incomplete, false or unsupported pre-arrival submissions.
• Arrival at a Paris MoU port with known serious deficiencies that were not disclosed or corrected.
• Failure to arrange an enhanced FSI, RO survey or additional ISM audit when directed.
• Failure to report a PSC inspection, deficiency, detention or restriction immediately.
• Pressure on a master, inspector, RO or agent to conceal or misstate information.
• Repeat failure by vessels under common ownership or management.

3. Immediate measures
• VISR may require a pre-departure or post-departure inspection, additional audit, remote evidence review or company management meeting.
• Non-essential Registry services may be restricted pending satisfactory compliance.
• Vessel and company risk ratings may be increased and sister vessels may be reviewed.
• Where safety or documentary integrity requires, VISR may suspend or withdraw documents or initiate deletion in accordance with law.

4. Corrective action and reinstatement
The company must submit a root-cause analysis and corrective-action plan addressing both the vessel event and the failure of communication or management control. Restrictions will be lifted only after objective evidence shows effective correction and any applicable fees or penalties are settled.

Compliance records and communications
All applications, approvals, notices, reports, evidence, decisions, acknowledgements and corrective-action records required by this Circular must be transmitted through an official VISR channel and retained in the controlled Registry file in accordance with the VISR records policy. Communications from unverified domains or persons without written authority must not be relied upon.

Official contact: technical@register-vu.com. Urgent safety, casualty, sanctions or fraud matters must also be copied to info@register-vu.com and reported without delay.

Enforcement, reasons and reconsideration
Non-compliance may result in enhanced inspection, corrective-action requirements, service restrictions, suspension, administrative penalties, withdrawal or revocation of documents, or deletion from the Registry, to the extent authorized by law and the applicable written authority. Except where immediate protective action is necessary for safety, security, sanctions compliance, documentary integrity or preservation of evidence, an affected person will be notified of the material grounds and given a reasonable opportunity to respond. A request for reconsideration must be submitted in writing to the Office of the Maritime Administrator with supporting evidence within ten business days of the written decision, unless a shorter period is stated because of an urgent risk.

Supersession and effective application
This amended Circular supersedes the prior version of Circular No. 011 from the effective date stated above. Existing obligations, liabilities, investigations, fees and corrective actions arising under the prior version remain enforceable to the extent lawfully incurred and are to be administered under the clearer procedures stated in this amended version. If this Circular conflicts with a later Act, regulation or controlled VISR policy, the higher or later instrument prevails and the Circular shall be updated through document control.


Saade Makhlouf
Maritime Administrator of the Republic of Vanuatu
Vanuatu International Shipping Registry
Issued in Port Vila and New York
20 August 2026

 

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