The Tokyo Memorandum of Understanding (Tokyo MOU) issued a notice on its official website on October 9, announcing that it will introduce a new methodology for calculating the performance of flag States and recognized organizations (ROs), thereby changing the way both are assessed in its annual report and the way they are used to determine ship risk levels under the New Inspection Regime (NIR).

Under the revised methodology, flag States and recognized organizations will be classified as high-, medium-, or low-performance based on a comparison of their detention rates with the regional average. The specific classification depends on whether each detention rate is below the regional average, is equal to or above the regional average but below twice that average, or is equal to or above twice the regional average, as follows:

A flag State or recognized organization whose detention rate is lower than the regional average detention rate is classified as “high” performance;

A flag State or recognized organization whose detention rate is greater than or equal to the regional average detention rate but lower than twice the regional average detention rate is classified as “medium” performance;

A flag State or recognized organization whose detention rate is greater than or equal to twice the regional average detention rate is classified as “low” performance.

The data period used to calculate the detention rate of a flag State or recognized organization and the regional detention rate is the most recent three calendar years; however, for the RO detention rate and regional detention rate used to calculate recognized organization performance, the first year will use data from January 1 to December 31, 2027, and the second year will use data from January 1, 2027 to December 31, 2028.

In each inspection, each flag State or recognized organization is counted only once for a detention, regardless of how many detainable deficiencies related to it are involved.

For flag States or recognized organizations with small fleets, if the number of inspections during the data period used is less than the critical number of inspections (i.e., “100 divided by the regional average detention rate”), their performance will be determined as follows:

A flag State or recognized organization with no detentions during that period is classified as “high” performance;

A flag State or recognized organization with one detention during that period is classified as “medium” performance;

A flag State or recognized organization with more than one detention during that period is classified as “low” performance.

When calculating recognized organization performance, the “related RO” rather than the “responsible RO” will be used. When a detainable deficiency is related to a statutory certificate and that certificate was most recently issued or endorsed by a recognized organization, that recognized organization is identified as the related RO. In this regard, the statutory certificate related to a detainable deficiency is identified through the use of the “Background table.”

Data collection related to recognized organizations will begin on January 1, 2027. In initial inspections conducted on or after that date, port State control officers (PSCOs) will use the Background table to select the statutory certificate related to a detainable deficiency. The method for collecting flag State data remains unchanged.

The revised flag State and recognized organization performance assessment results will be published in the Tokyo MOU annual report around May 1 each year and will apply to ship selection under the New Inspection Regime (NIR) from July 1 of the same year.

In the first assessment under the new methodology, the 2027 flag State performance calculation will use data from January 1, 2025 to December 31, 2027, while the recognized organization performance calculation will use data from January 1 to December 31, 2027.

The assessment results are expected to be published in the annual report around May 1, 2028, and will apply to ship selection under the New Inspection Regime from July 1, 2028.

The adjustment planned by the Tokyo MOU follows similar action taken by the Paris Memorandum of Understanding. The Paris MOU is revising its recognized organization (RO) performance assessment methodology in preparation for the revised EU port State control directive, which will enter into force on July 6, 2027. Both methodologies compare detention rates with regional or overall averages and link deficiencies that can lead to detention to the recognized organization that issued or endorsed the relevant statutory certificate.

The International Association of Classification Societies (IACS) has raised concerns about the Paris MOU’s approach, warning that detention rates may not accurately reflect the actual extent of a recognized organization’s involvement in deficiencies. The association believes that operational, maintenance, and crew-related issues may be beyond a recognized organization’s direct control, which could lead to inaccurate performance classifications and subject ships to more port State control (PSC) inspections. IACS calls for further validation, appropriate statistical safeguards, and open discussion with maritime stakeholders, while exploring possible appeal mechanisms and recommendations to strengthen port State control officer training and oversight.