The UK Government published a revised edition of the Ports and Marine Facilities Safety Code in April 2025. This sets out fundamental safety benchmarks for harbour authorities and marine facilities across the UK.
The Code isn’t new given it was first introduced back in the early 2000s, but it has evolved since then. It’s designed to improve the safety of activities carried out across UK ports, harbours, marinas and other marine infrastructure. Not just for those using them but also for those who could be impacted by issues.
Whilst the Code initially only applied to UK Harbour Authorities, following the 2025 update that’s no longer the case. Its scope has widened so that it now includes a much broader range of marine facilities. If you operate a marina, terminal, pier, or any form of private marine infrastructure, you are now explicitly within its scope.
Key Requirements Introduced in the UK Ports and Marine Facilities Safety Code 2025 Revision
Key requirements under the revised Code include:
- You must appoint a senior Duty Holder responsible for marine safety performance;
- You need to assign an independent Designated Person to audit safety systems annually;
- A formal Marine Safety Management System is required to evidence robust risk assessment;
- You are required to publish a marine safety plan at least every three years with documented performance reporting; and
- Experience alone isn’t enough – personnel involved in marine operations must be appropriately trained, competent and regularly assessed.
These principles are supported by the complementary Guide to Good Practice on Port and Marine Operations. This provides helpful guidance for the practical implementation of the above and more.
Although compliance with the Code is technically voluntary at present, it is highly regarded by regulators. This means it carries significant practical and legal weight. The Code is endorsed by the Government’s Department for Transport, the Maritime and Coastguard Agency and other regulators. Due to this duty holders across the sector are expected to integrate its principles into their safety management frameworks. With this in mind, non-compliance can therefore be a significant consideration in legal proceedings following marine incidents. Flipping that; proving alignment could also be a major asset. Not only could it potentially offer some assurance should the worst happen, it’s also a clear signal of operational excellence to your insurers, lenders, and clients.
Practical Implications for Harbour Authorities and Marine Operators
We have recently been working with harbour authorities, assisingt where land is being occupied and used by operators where the responsibilities under the Code might overlap. Examples of where there might be overlap include: where there are berth operators, dredging or construction contractors, or marinas operating within a harbour area.
In these circumstances it will be important to identify gaps in risk control and conflicting procedures, understanding who is responsible for what. The Code strongly recommends that good practice would be to have a bridging agreement in place between the parties. This would detail what operations are covered, who controls movements, who manages specific hazards, how each party’s risk assessments work together, and who leads in a relationship. The bridging agreement does not transfer statutory duties.
If you need any assistance with ensuring compliance, please do get in touch with our specialist Marine Team.
This article was co-written by Jess Lewis, Associate, and Kate Westlake, Partner, in our specialist Marine sector.