What the July 2027 MSMSR deadline means for Class 5 vessels
Class 5 vessels have until July 2, 2027 to comply with Canada’s Marine Safety Management System Regulations (MSMSR, SOR/2024-133). After that date, a Class 5 vessel may not operate unless its owner keeps a documented safety management system (SMS) and the vessel is run according to it. Transport Canada estimates about 7,900 vessels fall into Class 5.
The regulations came into force on July 3, 2024, and are being phased in by vessel class. Class 5 has the longest transition, which ends on the third anniversary of that date.
Is your vessel Class 5?
The MSMSR sorts Canadian vessels into five classes (section 1 of the regulations):
| Class | Vessels |
|---|---|
| 1 | Vessels to which SOLAS Chapter IX applies |
| 2 | 500 GT or more, or certified for 50 or more passengers and 24 m or more in length |
| 3 | Other vessels 24 m or more in length |
| 4 | Over 15 GT, or 15 GT or less and passenger-carrying or a towboat |
| 5 | All other vessels of 15 GT or less |
So a Class 5 vessel is a Canadian vessel of 15 GT or less that carries no passengers and is not a towboat. Small workboats, survey and research boats, crew and work skiffs, and small response and patrol boats commonly fall here.
The MSMSR does not apply to pleasure craft, human-powered vessels, vessels covered by the Fishing Vessel Safety Regulations or the Special-purpose Vessels Regulations, or unpowered vessels that carry no people and no oil or dangerous chemicals in bulk.
Which deadline applies to your vessel
The grace periods below apply only to vessels registered on or before July 3, 2024, as set out by Transport Canada.
| Vessel category | Grace period ends |
|---|---|
| Class 2 or 3 passenger-carrying; Class 4 over 15 GT or carrying more than 12 passengers | Safety Inspection Certificate date after July 2, 2025 |
| Class 2 or 3 non-passenger; Class 4 over 15 GT | Safety Inspection Certificate date after July 2, 2026 |
| Class 4 passenger-carrying and towboats, 15 GT or less, over 7 m | Certificate of Registry date after July 2, 2025 |
| Class 4 passenger-carrying and towboats, 15 GT or less, up to 7 m | Certificate of Registry date after July 2, 2026 |
| Class 5 vessels | July 2, 2027 |
Transport Canada’s own table lists some Class 4 vessels in two rows with different deadlines, so if you run Class 4 vessels, check them against section 604 of the regulations.
A Class 5 vessel registered after the regulations came into force does not get the grace period. Section 500(2) gives it six months from the day it is registered to have its SMS implemented.
What is different for Class 5
Class 5 has the lightest version of the rules, and three differences matter most:
- No certification. Class 5 vessels do not need a Canadian Document of Compliance or a Canadian Safety Management Certificate, and nothing goes to a recognized organization. Transport Canada checks the SMS when it inspects the vessel.
- Continuous improvement instead of internal reviews. Class 4 must evaluate its SMS at intervals of no more than 12 months. Class 5 must instead have procedures for continuously improving its SMS. TP 15566 still recommends an evaluation at least every 12 months.
- The document must be on board. The master must keep the SMS document on board (section 501), and the ship manager must produce it when Transport Canada asks.
What does not change is the core obligation: the vessel may only operate if the SMS is maintained and the vessel is run according to it (section 502).
What a Class 5 SMS must contain
Section 500 of the regulations lists the content. The documented SMS must include:
- A safety and environmental protection policy. A short statement of how the company runs its vessels safely and protects the environment.
- Instructions and procedures for operating safely and in line with the Canada Shipping Act, 2001, covering:
- inspection, maintenance and testing of equipment
- seaworthiness and stability
- voyage planning, safe navigation and vessel handling
- safety at sea
- Levels of authority and lines of communication between people ashore and on board. Who decides what, and who calls whom.
- Procedures for reporting shipping casualties and non-compliance.
- Emergency procedures, covering:
- casualties and accidents involving people
- equipment failure
- pollution incidents
- reporting emergencies
- Procedures for continuous improvement of the SMS itself.
TP 15566 adds practical expectations that an inspector is likely to look for. New and transferred crew should be familiarized with their duties before they need them (section 3.3.4). The SMS should say which drills are carried out on board (section 3.5.6.2). Any problem found should be traced to its cause, with a plan to stop it happening again (section 2.5.2).
What an inspector will ask to see
The regulations give Transport Canada the right to ask for the SMS document at any time, and inspectors may board at any reasonable time. For a Class 5 vessel, expect them to check three things:
- The document exists and is on board. It should be current, with a record of changes.
- The crew know it. Inspectors may ask the person in charge how they would respond to a fire, a person overboard or a spill, and compare the answer with the procedure.
- There is evidence it is followed. Drill records, equipment checks, reported deficiencies and what was done about them. A written system with no records behind it is exactly the gap an inspection is designed to find.
TP 15566 says SMS records must be kept for at least five years, and electronic records are acceptable if they are always available on board or online.
A six-month plan to July 2027
There are about eight months between November 2026 and the deadline. Six months is enough if you start now and leave time for the crew to use the system before it counts.
| Month | Work |
|---|---|
| 1 | List every vessel and confirm its class. Name the ship manager. Write the safety and environmental protection policy. |
| 2 | Write the operating procedures: equipment checks, stability and loading, voyage planning, safe navigation. Use what your crews already do, then fill the gaps. |
| 3 | Write the emergency procedures and the reporting procedures. Set the drill schedule for each vessel. |
| 4 | Set out authority and communication: who is in charge on board, who ashore, and how they reach each other. Write the continuous-improvement procedure, including a yearly evaluation. |
| 5 | Familiarize every crew member with the SMS. Run the first round of drills and record them. Start logging deficiencies and their fixes. |
| 6 | Run your first evaluation. Fix what it finds. Put the current SMS on board every vessel and keep the records where an inspector can see them. |
Keeping the records in one place
The hard part of an SMS is rarely writing it. It is keeping the records behind it current across every vessel, year after year, so they are ready when an inspector boards. Oceanaut keeps drills, deficiencies, crew certificates and training, and voyage records for each vessel in one place, and Remote Inspections lets you share them with an inspector through a single link.
This article is general information about the MSMSR, not legal advice. Check the current regulations and Transport Canada guidance for your vessel.
Frequently asked questions
What is a Class 5 vessel under the MSMSR?
A Canadian vessel of 15 gross tonnage or less that does not fall into Classes 1 to 4. In practice, that means vessels of 15 GT or less that are neither passenger-carrying vessels nor towboats, such as small workboats, survey boats and response boats. Fishing vessels covered by the Fishing Vessel Safety Regulations and pleasure craft are outside the MSMSR.
Do Class 5 vessels need a Safety Management Certificate?
No. Class 5 vessels must develop, document and follow a safety management system, but they do not need a Canadian Document of Compliance or Canadian Safety Management Certificate. Transport Canada verifies the SMS when the vessel is inspected.
What happens to Class 5 vessels registered after July 3, 2024?
The transitional period applies to vessels already registered when the regulations came into force. Under section 500(2), a Class 5 vessel must have its SMS implemented within six months after the day it is registered.
Does a Class 5 SMS have to be audited every year?
The regulations do not set an audit interval for Class 5. Instead, the SMS must include procedures for its continuous improvement. Transport Canada's guide, TP 15566, says evaluations should occur at least every 12 months.
How long must SMS records be kept?
TP 15566 says SMS-related documents must be kept for at least five years. Electronic records are acceptable if they are always available on board or online.