Tokyo MOU Revises Flag State and RO Performance Calculation Methodology
The Tokyo MOU has announced a revised method for calculating flag State and Recognized Organization (RO) performance for the New Inspection Regime (NIR). The changes introduce detention-rate benchmarks, a revised RO attribution method and a phased implementation schedule beginning in 2027.
Overview of the Tokyo MOU Changes
On 9 October 2026, the Tokyo Memorandum of Understanding on Port State Control in the Asia-Pacific Region (Tokyo MOU) announced changes to the calculation of flag State and Recognized Organization performance. These performance results are published in the Tokyo MOU Annual Report and used in determining ship risk profiles under the New Inspection Regime (NIR).
The revised method compares each flag State's or RO's detention rate with the regional average detention rate. It also changes the RO attribution terminology and method: the “related RO” will be used for performance calculation instead of the “responsible RO”.
Key dates: RO-related data collection starts on 1 January 2027. The first revised flag State and RO performance results are expected to be published around 1 May 2028, with the revised ratings applied to NIR ship selection from 1 July 2028.
The announcement concerns the methodology for calculating performance and its use in ship selection. It should not be interpreted as a new standalone shipboard convention requirement or as an automatic finding of legal responsibility against an RO.
New Flag State and RO Performance Categories
Under the revised method, performance is determined by comparing the detention rate of an individual flag State or RO with the regional average detention rate.
High Performance
Detention-rate comparison: Below the regional average detention rate.
The detention rate is lower than the regional benchmark.
Medium Performance
Detention-rate comparison: Equal to or above the regional average, but below twice the regional average.
The detention rate is at least the regional average but remains below twice that rate.
Low Performance
Detention-rate comparison: Equal to or above twice the regional average detention rate.
The detention rate is at least twice the regional benchmark.
Illustrative example
If the regional average detention rate were 2%, a rate below 2% would fall into the High category; a rate from 2% up to but not including 4% would be Medium; and a rate of 4% or above would be Low. This example is illustrative only and does not represent the actual Tokyo MOU regional detention rate.
The regional average used for the calculation is therefore important. A performance category should be read against the applicable published regional benchmark and the relevant assessment period.
Assessment Period and Counting of Detentions
As a general rule, the calculation uses data from the latest three calendar years. The Tokyo MOU has specified transitional assessment periods for the initial RO performance calculations.
Flag State performance
For the first revised calculation in 2027, flag State performance will use data covering 1 January 2025 to 31 December 2027.
RO performance — first assessment
The first RO performance assessment will use data from 1 January to 31 December 2027.
RO performance — second assessment
The specified second assessment period will cover 1 January 2027 to 31 December 2028.
One detention per inspection
Only one detention is counted for each flag State or RO for an inspection, irrespective of the number of detainable deficiencies related to that flag State or RO during that inspection.
For operational planning, owners, managers and ROs should distinguish the collection of data from the later publication and application of the resulting performance ratings.
Special Method for Smaller Fleets
The Tokyo MOU has provided a special method for a flag State or RO whose number of inspections during the assessment period is below the critical inspection threshold. The threshold is defined as “100/the regional average detention rate”.
Important: The threshold must be calculated using the regional average detention rate in the format prescribed by the Tokyo MOU. The actual regional average and resulting threshold should be checked against the official published data.
No Detentions — High Performance
Where the number of inspections is below the critical threshold, a qualifying smaller fleet with no detentions is assigned the High category.
One Detention — Medium Performance
A qualifying smaller fleet with one detention during the assessment period is assigned the Medium category.
More Than One Detention — Low Performance
A qualifying smaller fleet with more than one detention during the assessment period is assigned the Low category.
This provision addresses the effect that a small inspection population can have on rate-based comparisons. For a smaller fleet, even one detention can affect the resulting performance category.
“Related RO” Replaces “Responsible RO” for Performance Calculation
A key change is the use of the term “related RO” for RO performance calculation in place of “responsible RO”. The Tokyo MOU states that where a detainable deficiency is related to a statutory certificate, the RO that most recently issued or endorsed that certificate will be identified as the related RO.
The statutory certificate associated with the detainable deficiency is identified using the Tokyo MOU's published Background Table for RO Relation. The Tokyo MOU will continue collecting data on the “responsible RO” for its internal use.
How the related RO is identified
The deficiency is associated with a statutory certificate, and the latest issuing or endorsing RO for that certificate is identified as the related RO, using the Background Table.
What the change means
The attribution method used for RO performance calculations changes. This identification alone does not establish that the RO caused the underlying deficiency or determine legal liability.
The revised approach makes the traceability of statutory certification records relevant to the performance calculation. Shipowners and technical managers should ensure that certificate records and deficiency documentation are accurate and readily available.
Implementation Timeline
The Tokyo MOU has specified two principal milestones: commencement of collection under the new RO attribution method and later application of the revised performance results to NIR ship selection.
1 January 2027 — RO relation data collection starts
For initial inspections on or after this date, when a detainable deficiency is issued, the PSCO selects the statutory certificate related to the deficiency using the Background Table. Flag State data collection remains unchanged.
1 January–31 December 2027 — First RO assessment period
Data collected during 2027 will be used for the first revised RO performance calculation.
Around 1 May 2028 — Publication of results
The revised flag State and RO performance results are expected to be published in the Tokyo MOU Annual Report around this date.
From 1 July 2028 — NIR application
The revised flag State and RO performance results will be applied to ship selection based on the NIR on or after this date.
Do not confuse the dates: data collection begins on 1 January 2027, while application of the revised performance results to NIR ship selection is scheduled from 1 July 2028.
Practical Implications for Shipowners and Technical Managers
The revised method is primarily a flag State and RO performance calculation framework, but it matters to shipowners and technical managers because these performance results contribute to vessel risk profiling under the NIR.
Review PSC inspection history
Review past inspections, deficiencies and detentions to identify recurring technical or operational weaknesses and trends across the fleet.
Verify statutory certificates
Confirm that statutory certificates and endorsements are valid, applicable and consistent with the vessel's condition, equipment and current status.
Improve deficiency close-out
Record corrective actions, supporting evidence and verification of satisfactory completion. Investigate underlying causes rather than treating closure as a paperwork exercise.
Maintain traceable records
Keep survey reports, certificate records, maintenance documents, repair records and deficiency investigations complete and accessible.
These are prudent compliance practices and are not additional mandatory requirements created by this particular press release. Effective preparation can reduce avoidable deficiencies, but cannot guarantee a particular performance rating or prevent every detention.
Implications for Recognized Organizations
The related-RO methodology places emphasis on identifying the statutory certificate associated with a detainable deficiency and the RO that most recently issued or endorsed it. The Background Table will be used to select the related statutory certificate.
ROs may wish to review their internal processes for statutory certification traceability, survey documentation and analysis of detention trends. They should also ensure that their personnel understand the revised attribution process and its effective dates.
- Maintain accurate statutory certificate issue and endorsement records.
- Review the Tokyo MOU Background Table for RO Relation and applicable instructions.
- Ensure deficiency and certificate information is recorded consistently.
- Monitor published performance results and the applicable assessment periods.
The resulting performance category should be interpreted within the prescribed calculation methodology. It is not, by itself, a complete assessment of an RO's overall technical capability or a determination of causation for an individual deficiency.
Recommended Preparatory Actions Before 2027
Before the revised RO data collection begins, shipowners and technical managers can review their existing PSC compliance arrangements and identify areas requiring attention.
- Review fleet PSC history and detention trends.
- Identify recurring deficiencies and determine their underlying causes.
- Verify the accuracy and status of statutory certificates and endorsements.
- Check maintenance and inspection arrangements for safety-critical equipment.
- Ensure deficiencies are closed out with suitable evidence and verification.
- Review PSC preparation procedures and internal compliance checks.
- Monitor the Tokyo MOU website for the official Background Table and further implementation guidance.
These steps support sound compliance management and inspection readiness. The Tokyo MOU announcement does not prescribe this checklist as a separate mandatory programme.
Conclusion
The Tokyo MOU's revised flag State and RO performance methodology introduces a benchmark based on the regional average detention rate, a specific approach for smaller inspection populations and a new related-RO attribution method for performance calculations.
RO relation data collection begins on 1 January 2027. The first revised results are expected around 1 May 2028 and are scheduled to be applied to NIR ship selection from 1 July 2028.
For shipowners and technical managers, the practical priorities remain effective PSC preparation, reliable statutory certification, robust maintenance, traceable technical records and timely corrective action. These measures help support vessel compliance and reduce avoidable detention risks.
Official source
Tokyo MOU Secretariat, “Tokyo MOU’s Changing of the Method of Calculation of the Performance on Flag and RO”, press release dated 9 October 2026.
Consult the official Tokyo MOU website for the original announcement, the Background Table for RO Relation and any subsequent guidance.
Frequently Asked Questions
What is changing in the Tokyo MOU performance calculation?
Flag State and RO performance will be categorised by comparing the relevant detention rate with the regional average detention rate. The method also includes a special rule for smaller inspection populations and changes the RO attribution method from “responsible RO” to “related RO” for performance calculation.
When does the new RO data collection start?
Collection of RO relation data starts on 1 January 2027. For initial inspections on or after that date, PSCOs select the statutory certificate related to a detainable deficiency using the Tokyo MOU Background Table.
When will the revised performance results be used for NIR ship selection?
The first revised performance results are expected to be published around 1 May 2028 and are scheduled to be applied to NIR ship selection from 1 July 2028.
What is the difference between “responsible RO” and “related RO”?
For the revised performance calculation, the related RO is identified by reference to the statutory certificate associated with the detainable deficiency. The RO that most recently issued or endorsed that certificate is identified using the Background Table for RO Relation. Responsible-RO data will continue to be collected for internal Tokyo MOU use.
How are High, Medium and Low performance categories defined?
High means the detention rate is below the regional average. Medium means the rate is equal to or above the regional average but below twice that average. Low means the rate is equal to or above twice the regional average.
How are smaller fleets assessed?
Where the number of inspections is below the critical threshold specified by the Tokyo MOU, a flag State or RO with no detentions is rated High, one detention is Medium, and more than one detention is Low.
Does the revised RO method automatically mean that an RO caused a deficiency?
No. The related-RO method is a rule for attributing a detainable deficiency to a statutory certificate for performance calculation. Identifying an RO as the related RO does not, by itself, establish technical causation or legal responsibility.
What should shipowners and technical managers do now?
Review PSC and detention trends, verify statutory certificate records, strengthen deficiency investigation and close-out, maintain accurate technical records, and monitor official Tokyo MOU guidance. These practices support compliance readiness but do not guarantee a particular performance category.
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