A ship’s certificate is about to expire, the survey port is still weeks away and the cargo schedule is tight. The Administration grants a three-month extension and the ship loads one more cargo. That is the pattern the Australian Maritime Safety Authority (AMSA) says its port State control officers are finding, and its position is that a statutory certificate extension used that way can be invalid and the ship can be detained.
AMSA set this out in Marine Notice 2026/01, “Invalid extensions of statutory certification” (page updated 28 August 2026). The Liberian Administration passed it on to its fleet on 23 September 2026 in Marine Advisory 22/2026. Nothing in the notice is a new rule. It applies wording already in SOLAS, and it says what AMSA will do about ships that ignore it.
What SOLAS Allows for a Statutory Certificate Extension
SOLAS regulation I/14(e) is the provision. If a ship is not in a port where it is to be surveyed when a certificate expires, the Administration may extend the certificate, but only to allow the ship to complete its voyage to the port where it will be surveyed, and only where that appears proper and reasonable. No certificate may be extended for more than three months, and on arrival in the survey port the ship may not leave on the strength of the extension: it needs a new certificate first.
A statutory certificate extension also buys no extra validity. When the renewal survey is completed, the new certificate for a cargo ship runs to a date not more than five years from the original expiry date, not from the end of the extension.
Two other paragraphs of the same regulation are easily confused with it. Regulation I/14(f) allows a grace period of up to one month for a ship on short voyages whose certificate has not been extended under the earlier paragraphs. Regulation I/14(d) is different again: where the renewal survey has been completed but the new certificate cannot be issued or placed on board in time, the existing certificate can be endorsed for up to five months. That covers paperwork after a survey, not trading before one.
What “Proper and Reasonable” Means for an Extension
The IMO Survey Guidelines under the HSSC, 2025 (Assembly resolution A.1207(34)), section 5.9.2, say what the Administration should be guided by when a ship is in a port where the survey cannot be completed. In summary:
- an additional survey of at least the scope of an annual survey is carried out, and the renewal survey is carried out as far as possible;
- if dry-docking is required but cannot be done, an underwater inspection of the bottom is carried out, or, where that is not possible (poor visibility, draught restrictions, current, refusal by the port), an internal inspection of the bottom structure as far as practicable;
- the ship sails directly to a named final agreed cargo discharge port and then directly to a named agreed port to complete the survey and/or dry-docking;
- the extension is for the minimum time needed to complete the survey and/or dry-docking;
- the condition of the ship found by those surveys is taken into account in setting the duration, distance and any operational restrictions of the voyage; and
- the extension does not run beyond the validity of the class certificate covering structural, mechanical and electrical compliance.
The direct voyage is the condition AMSA’s notice turns on.
What AMSA Is Finding
AMSA says its port State control officers are finding ships whose certificates were extended under SOLAS I/14(e) or (f) but which keep trading commercially instead of proceeding directly to the survey port. It describes three-month statutory certificate extensions where the ship continues to trade, or intends to, for that period; extensions longer than the minimum needed to complete the survey; and ships that often need dry-docking as part of that survey. It also notes that the relaxations the IMO allowed during COVID-19 (Circular Letter No.4204/Add.19) have been withdrawn now that normal survey and certification procedures have been reinstated.
The consequence it states is that a ship whose certificates have been extended contrary to a convention or code requirement may be detained at a port State control inspection. Where the flag State’s recognised organisation (RO) issued the extension, the RO may be held responsible for the detention. A detained ship may be allowed to sail to the survey port under the IMO Procedures for Port State Control, 2025 (resolution A.1206(34)). For Australian-flagged ships, AMSA grants an extension only if it is allowed by a convention provision, is for completing the voyage to the final cargo discharge port and then directly to the survey port, and appears proper and reasonable. AMSA’s wider 2025 port State control results, including its 4.8% detention rate, are in PSC Detentions 2025: Paris, Tokyo, USCG and AMSA Compared.
The Flag State View
The Liberian advisory is useful because it turns the notice into instructions for a manager. The Administration’s stated position is that an extension is an exceptional statutory mechanism, not a substitute for timely survey planning, dry-docking, repair or renewal. Commercial inconvenience, charter commitments, cargo schedules, berth availability or the wish to keep trading flexibility do not, by themselves, make a statutory certificate extension proper and reasonable, and a trading programme should not be built around the maximum extension period. An extension does not authorise unrestricted trading until the extended expiry date.
For Liberian-flagged ships the advisory asks owners and operators, among other things, to confirm the exact convention provision relied on; to make sure the authorisation names the certificate, the approved period, the reason, the final cargo discharge port, the survey or dry-docking port and all conditions; to follow the authorised itinerary and refer any deviation or additional employment to the Administration before it happens; to carry the authorisation, correspondence, confirmed survey and dry-dock bookings, voyage plan and supporting evidence on board; and to notify the Administration if the extension can no longer be followed as approved. Other flags will have their own requirements, so ask yours.
What This Changes for a Ship Manager
Treat a statutory certificate extension as a voyage instruction, not just a new expiry date. The authorised route, ports and conditions are what the extended validity depends on, so the page the Master checks should be the one the operations and chartering staff have actually read.
The failure usually starts weeks earlier, in the survey plan, not at the extension request. A statutory survey that slips to the edge of its window leaves only the extension route, and the extension exists for a ship that cannot reach its survey port before expiry. The ISM Code expects the Company to have procedures to ensure the ship is maintained in conformity with the relevant rules and regulations, with inspections held at appropriate intervals (ISM 10.1 and 10.2.1). A certificate that depends on an exceptional statutory certificate extension is a sign those procedures have not worked. The PFOS Ban Is in Force. The Survey Clock Is Already Running. makes the same point about survey dates that arrive on their own clock.
Vetting treats the same failure seriously. RightShip’s baseline criteria make a vessel with overdue class or statutory conditions, certificates, surveys or other mandatory requirements Unacceptable until the item has been remedied or accepted and RightShip is satisfied the reason has been resolved, as set out in RightShip Requirements for Dry Bulk Vessels: What Revision 4.0 Changes.
Remote survey is not a way out either. Under the guidance covered in MSC-MEPC.5/Circ.17: What the New Remote Survey and Audit Guidance Actually Allows, initial and renewal surveys can be done remotely only for documentary and data checks, so a missed renewal survey cannot simply be replaced by a remote one.
For a ship carrying an extension into an Australian port, the Liberian advisory lists the checks a Master should make before arrival. In substance:
- the original certificate and the extension authorisation are on board, valid, legible and consistent with each other;
- the authorised route, ports, dates and conditions match the actual voyage and the instructions the ship has received;
- no additional commercial voyage, cargo operation or deviation has been added outside the approved basis;
- survey and dry-docking arrangements are confirmed, with documentary evidence available;
- all imposed conditions and risk-control measures are implemented and recorded; and
- the company has given the ship a clear explanation and organised evidence for port State control, and any discrepancy is reported before arrival.
The regulation has not changed. What the notice adds is a port State’s stated intention to test the direct-voyage condition, and to detain ships, and hold ROs responsible, when it is not met.
Sources
The requirements above are taken from the SOLAS and IMO texts and from AMSA’s notice. The Liberian advisory is the flag State’s own position and applies to Liberian-flagged ships.
- AMSA Marine Notice 2026/01, Invalid extensions of statutory certification
- SOLAS 1974, as amended, chapter I, regulation 14 (consolidated edition 2024)
- IMO Resolution A.1207(34), Survey Guidelines under the HSSC, 2025, section 5.9
- IMO Resolution A.1206(34), Procedures for Port State Control, 2025, and IMO circular MSC-MEPC.5/Circ.1, both cited in AMSA’s notice
- Liberia Maritime Authority, Marine Advisory 22/2026, 23 September 2026
- International Safety Management (ISM) Code, paragraphs 10.1 and 10.2
More from the PSC Series
