Maritime Coastguard Agency releases consultation on postponing electronic passenger counting for seagoing passenger vessels

Published on: 01 March 2023


The MCA is seeking industry views via a consultation on proposed changes to introduce additional flexibility in relation to persons counting obligations on passenger ships.


The MCA has launched an industry consultation seeking views on changes to UK secondary legislation to delay the deadline for electronic reporting and widen the discretion of the Secretary of State to grant exemptions to the persons counting obligations. The amending Statutory Instrument is the Merchant Shipping (Counting and Registration of Persons on Board) (Amendment) Regulations 2023. These regulations affect seagoing passenger vessels only (i.e. those operating outside of inland categorised waters).

Your views are sought in respect of the following areas:

  1. the regulatory proposals, including (but not limited to):

    • postponing the deadline for electronic reporting of persons data through the Maritime National Single Window (MNSW) or Automatic Identification System (AIS) from 20 December 2023 to 20 December 2025.   
    • widen the Secretary of State’s (SoS) exemption powers to remove restrictions on the type of exemptions which may be granted
    • amend the Merchant Shipping (Life-Saving Appliances and Arrangements) Regulations 2020 to disapply the ambulatory reference which exists in those Regulations to the persons data obligations contained in Regulation 27 of Chapter III of SOLAS.
    • amend the word “Passengers” to read “Persons” on one occasion in the Regulations
    • Other amendments necessary due to leaving the EU
  2. the clarity and effectiveness of the draft documents to implement the changes to The Merchant Shipping (Counting and Registration of Persons on Board Passenger Ships) Regulations 1999 (SI 1999/1869) (as amended, particularly by the Merchant Shipping (Counting and Registration of Persons on Board Passenger Ships) Regulations 2021 (SI 2021/81)).

This consultation will run for one month from 28 February and closes at 11:45pm on 28 March 2023.

Consultation responses should submitted on the consultation response form to  

Full consultation documents as well as the consultation response form can be found on the website here – The Merchant Shipping (Counting and registration of persons on boards) (amendment) regulations 2023 – GOV.UK (

Consultation responses to be sent to or alternatively via the British Marine Technical team via

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