5.2 Technological developments
Maritime technology is evolving rapidly, due to global shifts such as digitalisation, artificial intelligence, cybersecurity threats and decarbonisation mandates. These drivers accelerate the introduction of advanced materials, propulsion systems, and software-driven and interconnected ship product groups, which leads to a much higher degree of integrated systems of different components. Current mutual recognition practices, geared mainly toward non-safety-critical items, may not easily extend to integrated, safety-critical systems with emergent failure modes.
As systems become increasingly interconnected and automated – for instance, integrated bridge systems that merge navigation, propulsion, and safety controls – it grows harder to isolate a single component’s functionality or potential failure. A shortcoming in one part, certified under a mutual recognition certificate, could trigger cascading effects on another overall ship certification that is assured by a different EU RO.(1) van der Meulen, M and Myhrvold, T. Demonstrating safety of software-dependent systems. DNV, 2022. Such cascading phenomena reflect a systems-level failure mode: hardware, software, and operational processes may be individually compliant yet collectively induce emergent hazards. This viewpoint resonates with advanced risk analysis methods, which highlight that over-reliance on modular certificates without verifying integrated behaviour can obscure “unknown unknowns” in new or evolving technologies.(2) See Paté-Cornell, E. Engineering a Safer World: Systems Thinking Applied to Safety. MIT Press, Cambridge, 2011, p.638. See also van der Meulen, M and Myhrvold, T. cit. bove. This scenario underlines the importance of cohesive oversight and underscores the text’s reference to “serious safety reasons” which permit an EU RO to withhold recognition where system-level hazards are foreseen.
EU ROs thus face new complex challenges around how to provide reliable quality assurance, possibly demanding the revision of methods for managing safety risk concepts such as, for example, “modular assurance”.(3) McGeorge, D and Glomsrud, J A. A modular risk concept for complex systems. 2025, avaialble online https://arxiv.org/pdf/2402.12804v2 For example, the IMO’s developing Maritime Autonomous Surface Ships (MASS) framework could reshape risk assessments of product categories. Autonomous technology blurs traditional equipment lines, making discrete hardware part of an integrated network reliant on external data or remote operations. Set to become partly mandatory by 2028, the MASS Code could demand new risk-based requirements from EU ROs.(4) See https://transport.ec.europa.eu/transport-modes/maritime/maritime-autonomous-ships-and-shipping_en
Cybersecurity adds another layer of complexity. The IMO guidelines (MSC-FAL.1/Circ.3-Rev2)(5)https://wwwcdn.imo.org/localresources/en/OurWork/Security/Documents/MSC-FAL.1-Circ.3 Rev.2%20-%20Guidelines%20On%20Maritime%20Cyber%20Risk%20Management%20(Secretariat)%20(1).pdf highlight that the “holistic” approach is necessary to maintain system integrity, since reliance on separate or fragmented mutual recognised certificates as part of an overall holistic certification, could weaken unified cybersecurity standards, especially if an EU RO has no detailed knowledge of the software or security protocols integrated by another EU RO as part of the mutually recognized certificate.
Ultimately, while innovation in shipping is vital – particularly to meet decarbonisation targets, meet challenges from climate change, promote safe and efficient operation, and enhance cyber-resilience – serious safety implications suggest the maintenance of a carefully measured approach to mutual recognition. The existing scheme has proven workable for lower-risk components because the benefits (reduced duplication, efficiency gains) are seen to outweigh potential downsides. Extending it to more complex systems, however, demands scrutiny of how “appropriate cases” and “serious safety reasons” apply in light of integrated design, cybersecurity, and evolving global standards. Likewise, new challenges could prompt re-evaluation of previously low-risk items.