PMSC 2025 Changes Explained: What it Means for You
Understanding the 2025 Update to the Port & Marine Facilities Safety Code
In April 2025, the UK Government released a refreshed version of the Ports & Marine Facilities Safety Code along with a revised Guide to Good Practice on Port and Marine Facilities. This is the most substantial update since 2016 and follows wide engagement across the ports and maritime community. The result is a clearer and more practical set of expectations for anyone involved in managing marine safety.
The Code continues to serve as the national reference point for safe operations in ports and marine facilities. Although it is non‑statutory, the Department for Transport and the Maritime & Coastguard Agency expect organisations to be able to demonstrate proportional compliance once they have chosen to adopt it. That expectation applies just as much to small marine facilities as it does to major ports.
At ABL, we see the 2025 update as a strong reminder of the value of structured governance, independent assurance and transparent safety oversight. These principles matter everywhere vessels move and interact and they rely heavily on two things that shape the whole Code: a well‑founded Navigational Risk Assessment and a confident, independent Designated Person.
Overview of the 2025 PMSC Changes Affecting Ports and Marine Facilities
The 2025 version brings several meaningful changes that affect the whole sector.
- The scope of the Code has been updated and formally presented as the Ports & Marine Facilities Safety Code. This reinforces that it applies across all types of marine facilities, not only those with statutory harbour powers.
- The language around non‑statutory and third‑party facilities is far clearer than before. The longstanding uncertainty over who is responsible for what in those environments has been addressed, which helps organisations understand their position and what they are expected to demonstrate.
- The structure of the document is easier to follow and the expectations around compliance have been laid out in a more accessible way. Proportionality is emphasised throughout so smaller or less complex facilities can adopt arrangements that reflect the scale of their operations without undermining safety standards.
- There is also a stronger focus on governance and accountability at senior levels. Boards and executive teams are asked to show that they understand their responsibilities for marine safety and that they support the processes needed to achieve it.
Navigational Risk Assessment (NRA) Requirements Under the 2025 PMSC
Navigational Risk Assessment remains at the heart of the Code. The 2025 update places greater weight on how relevant and defensible each assessment is. It must connect directly to the Marine Safety Management System and guide the decisions that shape harbour directions, procedures, pilotage and towage arrangements.
The expanded scope of the Code means non‑statutory and third‑party facilities are expected to hold documented NRAs that match their operations. This is especially important where these facilities sit inside or alongside the jurisdiction of statutory harbour authorities.
NRAs should no longer sit untouched for long periods. They are expected to be reviewed following;
- operational change
- shifts in vessel traffic
- new infrastructure
- the introduction of new activities
They must also be informed by real experience from incidents and near misses. Duty holders are expected to understand the navigational risk picture rather than rely on assessments produced many years ago.
A modern NRA is expected to be current and evidence‑based. It should help support decisions and demonstrate that the organisation is in control of the risks that vessels present.
Designated Person Role Under the PMSC – 2025 Expectations
Independent assurance and oversight
The 2025 update does not alter the statutory position of the Designated Person but it does raise the standard for how the role is delivered.
The DP remains a key source of independent assurance, providing confidence that the MSMS is functioning as intended and that controls derived from the NRA are effective.
Independence and effective challenge
The updated Code and Guide to Good Practice set clear expectations around the independence of the DP. The role should offer informed challenge, grounded in experience and supported by evidence.
The DP is expected to judge whether navigational risks are being managed in day‑to‑day operations rather than only on paper.
Board‑level engagement and evidence
Senior leaders are asked to ensure that the DP has direct access to decision‑makers and that their findings influence strategic choices. This includes assurance that NRA outcomes link visibly to governance, operational review and safety decisions across the organisation.
What the 2025 PMSC Changes Mean for Ports and Marine Facilities
Together, these updates encourage organisations to take a fresh look at their approach to navigational safety. They call for NRAs that reflect current operations and for a clear demonstration of how those assessments shape the Marine Safety Management System.
They also require confidence that the Designated Person can provide meaningful independent insight into how risks are managed in practice.
Finally, they place more weight on showing compliance to boards, the MCA and, when needed, investigators.
How ABL Supports Ports During Changes
The new Code expects organisations to show a clearer understanding of their risks and how they manage them in practice.
ABL helps duty holders meet these expectations with support that is grounded in real experience across ports and at sea. Here are some of the ways we can help you comply with confidence:
- Navigational Risk Assessments that reflect real operations
We produce NRAs that match the scale, activity and behaviour of vessels in your waters. Our work is shaped by 100s of years of marine experience as well as diverse data sets and tools. The results support safe decision‑making and give duty holders a well evidenced foundation for their MSMS.
- Independent audits using our transparent assurance platform – BEACON
Our governance and audit work is delivered through a proprietary digital tool that records evidence openly and tracks findings from opening meeting to close out. This gives boards and senior teams complete visibility of how controls are performing and where action is needed.
- Designated Person services that are genuinely independent
Our DPs are industry specialists who understand ports from the inside. They bring experience from sea going roles, port operations, pilotage, risk analysis and regulatory work. They carry out their assurance work without influence and with the full depth of ABL expertise behind them.
- Support across complex or specialised operations
We have dangerous cargo experts, marine engineers, port planners and data specialists who can help duty holders understand the risks linked to specific cargoes, infrastructure or vessel activity. This breadth ensures your assessments and audits reflect the true nature of your operations.
- Experience that comes from the real world, not theory alone
Many of our people have stood watch at sea, taken vessels alongside, run harbour operations and overseen busy port movements. Education gives structure but judgement comes from being on the ground. ABL provides both.
ABL helps organisations meet the intent of the 2025 Code with clarity, assurance and practical insight.
If you face a challenge in your port, we will stand with you and resolve it.