Abstract: The development of artificial intelligence and automation is transforming the maritime sector, particularly through the emergence of Maritime Autonomous Surface Ships (MASS). However, this technological innovation poses unprecedented legal challenges concerning the roles of the master and crew, vessel registration, and legal liability. This study analyzes and compares the current legal frameworks governing MASS in the United Kingdom and China – two jurisdictions representing contrasting approaches: the UK adopts a proactive and flexible legislative strategy, while China maintains a cautious stance focused on controlled experimentation. Through the examination of legal texts, policy reports, technical standards, and academic literature, the paper identifies the strengths, limitations, and regulatory trajectories of both systems. Based on these findings, the research offers several policy recommendations for Vietnam, including: introducing a legal definition for MASS, formulating interim technical guidelines, establishing a regulatory sandbox mechanism, and actively participating in multilateral discussions within the International Maritime Organization (IMO). The ultimate goal is to develop a dynamic and adaptable legal framework that supports innovation while ensuring safety in the era of maritime digitalization.
Keywords: Maritime Autonomous Surface Ships (MASS), United Kingdom maritime legislation, Chinese maritime law, Vietnamese legal policy, regulatory sandbox.
1. Introduction
The development of automation technology, artificial intelligence (AI), and remote control has brought about a major breakthrough in the global maritime industry.[2] One of the most notable achievements is the emergence of Maritime Autonomous Surface Ships (MASS), which are waterborne vessels capable of navigation and operation with maritime functions performed wholly or partly without direct human intervention. MASS are reshaping the conduct of maritime transport, ranging from technical aspects to risk management, human resources, and legal frameworks.[3] However, this innovation also raises unprecedented legal challenges, as most existing maritime regulations still presuppose that ships must be directly manned and operated on board.[4] According to the classification of the International Maritime Organization (IMO), MASS are divided into four levels, from vessels with automated processes and human supervision (Level 1) to fully autonomous ships without any human intervention (Level 4).[5] This creates a significant gap in both international and national legal frameworks, particularly with respect to: (i) the legal definitions of “ship,” “master,” and “crew”; (ii) mechanisms for registration and flagging; (iii) civil and criminal liability in case of incidents; and (iv) safety standards, insurance, and technical inspections.[6] This research focuses on MASS and does not address other autonomous underwater vehicles such as AUVs (Autonomous Underwater Vehicles), since MASS are currently the main subject of international legal framework-building efforts and are more closely aligned with the concept of a “sea-going ship” under national and international law. Limiting the scope in this way ensures analytical focus and depth for the legal discussion in this article.
In this context, the United Kingdom and China emerge as two exemplary yet contrasting legal approaches. The United Kingdom has taken an early initiative to amend its laws, issuing the UK Code of Practice for MASS in 2018[7] and currently proposing amendments to the Merchant Shipping Act 1995 in order to establish a proactive legal framework for the commercial operation of MASS.[8] In contrast, China has introduced scattered adjustments within the Maritime Code of China 1992 and the Maritime Traffic Safety Law 2021, but the country has not yet formally recognized MASS as a legal category of “ship,” leading to significant obstacles in registration, inspection, and the attribution of liability.[9] In Vietnam, MASS remains a novel concept and has not yet been codified. The Vietnam Maritime Code 2015, although regarded as the fundamental legal instrument in this field, contains no provisions addressing unmanned ships or remotely operated ships. This situation underscores the urgent need to develop an open, flexible legal framework capable of regulating technological innovation.
Accordingly, this study is conducted with two main objectives: (1) to analyze and compare the legal frameworks governing MASS in the United Kingdom and China, thereby identifying model characteristics that can be drawn upon; and (2) to propose policy recommendations for improving Vietnamese law so as to anticipate the trend of autonomous maritime transport while ensuring maritime safety, security, and sovereignty. The research method employed in this article is comparative law, combined with qualitative analysis of legal texts, policy reports, and specialized academic literature in the fields of maritime affairs and technology law. The data are drawn from international sources (IMO, UNCLOS), national legislation (the United Kingdom, China, Vietnam), and the latest government reports. The structure of the article consists of six parts: following the introduction, Part 2 presents the international legal framework on MASS; Parts 3 and 4 analyze the legal frameworks of the United Kingdom and China, respectively; Part 5 compares the two legal systems and offers legal policy recommendations for Vietnam; and Part 6 provides the conclusion.
2.International Legal Framework for Maritime Autonomous Surface Ships (MASS)
2.1. Concept and Classification of Maritime Autonomous Surface Ships (MASS) under the International Maritime Organization (IMO)
MASS is the term officially used by the IMO to refer to ships with a high degree of automation, ranging from those still requiring human assistance to those capable of operating entirely without human intervention. According to the classification announced by the IMO at the meeting of the Maritime Safety Committee (MSC 100, 2018), MASS are divided into four levels based on the extent of human involvement.[10]
· Level 1 – Decision Support: The ship is equipped with automated systems that support decision-making, but a crew is still required to operate it.
· Level 2 – Remote Control with Seafarers On Board: The ship can be remotely controlled, but there are still crew members present on board.
· Level 3 – Remote Control without Seafarers On Board: All operational functions are carried out remotely, with no personnel present on board.
· Level 4 – Fully Autonomous: The ship operates independently and is capable of making decisions without any human intervention
This classification plays an important role in determining technical standards, legal obligations, and the extent of intervention required by national and international legal systems. However, the IMO also acknowledges that a ship may shift between different levels during its voyage, which renders the construction of a legal framework more complex and necessitates a high degree of flexibility.
The IMO plays a central role in coordinating and developing the international legal framework for MASS through the Regulatory Scoping Exercise (RSE), which commenced in 2017 and completed its initial phase in 2021.[11] Preliminary results indicate that most existing conventions may be applied to MASS provided that they are amended or supplemented with specific guidelines, particularly in relation to personnel, supervision, and liability.[12] Subsequently, the IMO is promoting the drafting of the MASS Code—an international code for autonomous ships—with adoption scheduled for 1 July 2030 and entry into force expected on 1 January 2032.[13] In the meantime, countries such as the United Kingdom and Norway are implementing regulatory sandboxes and conditional exemptions, which both facilitate technological experimentation and contribute practical data to the process of building the international framework. This mechanism represents a model of innovation governance, allowing stakeholders to test new technologies or operational models within a controlled and limited legal environment. It enables policymakers to assess the practical impact of emerging technologies on the existing legal system and to introduce appropriate adjustments without hindering technological development.[14]
2.2. Fundamental Legal Issues Raised by MASS
2.2.1. Legal Definitions of "Ship", "Master", and "Crew"
In both international conventions and national legislation, the definition of a ‘ship’ is typically associated with its capacity for navigation and maritime transport. However, the complete or partial removal of the crew may render MASS inconsistent with traditional definitions, such as those found in the United Kingdom’s Merchant Shipping Act 1995[15] or China’s Maritime Code 1992, both of which require human operation or presence on board. An even more serious issue arises with respect to the definitions of ‘master’ and ‘crew’—two legal positions that play a central role in the system of maritime duties and liabilities. For example, under the SOLAS Convention[16] and the STCW Convention,[17] all operations on board are regulated through the obligations and qualifications of the ‘master’ and ‘crew,’ whereas MASS may physically lack such positions altogether.[18] Consequently, determining whether a ‘remote operator’ or a ‘chief programmer’ could substitute for the legal role of the ‘master’ constitutes a complex legal question, and there is as yet no international consensus on how to resolve it.[19]
2.2.2. Civil and Criminal Liability, Safety, and Insuranc
In situations where a MASS causes a maritime accident, the central question is who bears liability. In the traditional ship model, liability is usually attached to the master, the shipowner, and hull insurance. However, with MASS, liability may be distributed among the software manufacturer, the navigation programming entity, the remote operator, or even the provider of meteorological data.[20] Similarly, standards of seaworthiness under contracts of carriage of goods by sea may also be affected if the ship fails to meet technical requirements due to the absence of a crew physically inspecting and operating the vessel. With respect to insurance, the current maritime insurance system still largely relies on traditional risk models, whereas MASS introduces non-traditional risks such as software errors, telecommunications failures, and cyberattacks—risks that are not yet comprehensively addressed in existing insurance contracts.[21]
2.2.3. Difficulties in Applying Existing International Conventions to MASS
The United Nations Convention on the Law of the Sea (UNCLOS 1982)[22] stipulates that the flag State must ensure that its ships are operated in conformity with safety standards and the competence of the crew (Article 94.3). However, this provision does not specify whether the crew must be physically present, leaving a gap in its application to MASS. Moreover, the absence of ‘persons’ on board may pose difficulties for port authorities in exercising their rights to inspect and detain ships in cases of violations.[23]”
The International Convention for the Safety of Life at Sea (SOLAS 1974, as amended)[24] is the core convention governing maritime safety. Article 14 of Chapter V requires that ships be ‘sufficiently and efficiently manned’ with qualified seafarers to ensure safety. Nevertheless, States may grant exemptions or allow equivalences under Article 3.2 of SOLAS, thereby creating legal space for MASS if deemed appropriate by the State.
The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW 1978, as amended)[25] sets out the standards for training, certification, and watchkeeping of seafarers. In the case of MASS, it remains unclear whether a ‘remote operator’ must hold qualifications equivalent to those of a master, or whether continuous watchkeeping is required under the provisions of the STCW.[26] The IMO is currently undertaking studies to develop new guidance on MASS in this context.
The International Convention for the Prevention of Pollution from Ships (MARPOL 73/78)[27] requires that ship operators take measures to prevent pollution arising from maritime activities. However, the absence of personnel on board means that violations may go undetected or unaddressed in a timely manner, thereby increasing environmental risks.[28]
The International Regulations for Preventing Collisions at Sea (COLREGs 1972)[29] require the maintenance of a proper lookout on board by all available means. The replacement of human lookouts with sensors and cameras on MASS constitutes one of the greatest challenges, and debate continues as to whether AI can meet the standard of seamanship in all circumstances.[30]
Thus, MASS are not merely a new technological product but also a test for the existing international legal system—which was built on the assumption of the physical presence of humans on board. While many international rules remain in force, their application to MASS encounters significant difficulties and inconsistencies. The role of the IMO is pivotal in coordinating amendments and developing a new legal framework.[31] In the meantime, each State must proactively develop appropriate and flexible domestic legislation in order to both safeguard national interests and anticipate the emerging trend of next-generation maritime technologies.
3. The Legal Framework of the United Kingdom for Maritime Autonomous Surface Ships (MASS)
3.1. The Current Legislation Governing MASS
The Merchant Shipping Act 1995 (MSA 1995)[32] is the core legal instrument governing maritime affairs in the United Kingdom, covering ship registration, the role of the master and crew, maritime safety, as well as civil and criminal liability. The definition of “ship” under Section 313(1) of the MSA 1995 is “every description of vessel used in navigation.” This is an open definition, encompassing even vessels without a human operator, provided that the vessel engages in lawful navigation. However, the Act does not provide a clear definition of autonomous or unmanned ships. This leads to uncertainty in application, particularly in relation to Section 49 on minimum manning requirements—which may create obstacles if a MASS operates without a crew—and Section 313 on the “master” and “crew,” whose current definitions imply the physical presence of such persons on board.
According to Section 313 of the MSA 1995, the master is defined as “the person having command or charge of a ship”—a legally open definition that does not require the individual to be physically present on board. Accordingly, the remote operator of a MASS could, in principle, be regarded as the “master” if he or she exercises full decision-making authority over the voyage, navigation, and safety. However, transferring this role from ship to shore raises multiple legal issues, such as: how should legal obligations be discharged in cases of emergency? Can responsibilities such as accident reporting or responding to unforeseen incidents be validly fulfilled through technological intermediaries? And what would happen if the system were subject to cyberattacks or communication failures? Similarly, the definition of crew under current United Kingdom law is tied to seamen working on board, as stipulated in Section 313(1) of the MSA 1995, and does not extend to remote operators. Therefore, it would need to be revised in future legislation to legally recognize shore-based personnel.
In relation to international law, the United Kingdom is a full party to conventions such as SOLAS, STCW, MARPOL, COLREGs, and directly applies the safety standards derived therefrom. However, most of these provisions continue to assume the physical presence of persons on board. While they do not explicitly prohibit MASS, they create administrative and technical barriers to the registration and operation of such vessels.
3.2. Technical Guidance: The MASS Code of Practice 2018
To gradually address the legal gap in the regulation of MASS, the United Kingdom Maritime and Coastguard Agency (MCA) promulgated the MASS Code of Practice (COP) in 2018.[33] This document does not carry statutory force (non-statutory guidance), but serves as a technical framework providing orientation for the design, operation, and authorization of MASS during the transitional period, when the existing legal system has not yet been adapted to accommodate the new technology. Specifically, the 2018 UK MASS Code of Practice sets forth the following guidelines:
+Scope of application: Applicable to MASS with a length of less than 24 meters operating within the internal waters and territorial sea of the United Kingdom. This segment constitutes the most common category of vessels in autonomous technology pilot projects, typically employed for hydrographic surveys, scientific research, or port support..
+Classification of MASS: The Code establishes a system for classifying MASS based on criteria such as length, speed, and operational risk level, while also incorporating the concept of “autonomy levels” to reflect the extent of human involvement in operations. This classification system serves to determine the appropriate requirements applicable to each specific type of vessel.
+Technical Requirements: The Code proposes technical standards relating to: hull design and structural engineering; control systems and human–machine interfaces; communication and data equipment; emergency and accident response procedures; as well as insurance and legal liability.
+Risk-Based Approach: A key feature of the Code is the adoption of a risk-based safety case approach. Instead of applying rigid technical standards as for traditionally crewed vessels, MASS operators are required to present and demonstrate a “safety case” for each specific situation. This includes risk analysis, preventive measures, and emergency procedures tailored to the operational characteristics of the vessel.
Although it does not carry binding legal force, the 2018 MASS Code of Practice has been used by the MCA as the official technical basis for assessing and granting temporary operational authorizations for MASS projects, in the absence of a unified legal framework for such vessels. The issuance of this Code reflects the United Kingdom’s flexible policy approach, striking a balance between promoting innovation and ensuring maritime safety in the practical implementation of technology.
3.3. Workboat Code Edition 3 – 2023: A Step Forward in the Legal Regulation of MASS
In November 2023, the United Kingdom’s Maritime and Coastguard Agency (MCA) officially issued the Workboat Code – Edition 3, replacing its previous editions and incorporating updated provisions relating to autonomous ship technology. This marks the first time that a technical code with binding legal effect (effective as of 13 December 2023) has been promulgated in the United Kingdom with specific regulations governing Remotely Operated Unmanned Vessels (ROUVs).
Within its scope of application to workboats under 24 meters in length operating in the inland waters and territorial sea of the United Kingdom,[34] the Workboat Code – Edition 3 introduced Annex 2, specifically dedicated to MASS, particularly Remotely Operated Unmanned Vessels (ROUVs).[35] This Annex sets out technical requirements covering: hull structure; remote control systems; human–machine interfaces; connectivity and communication standards; safety measures; voyage data; as well as emergency response procedures in conditions where no personnel are physically present on board.
A noteworthy point is that the Workboat Code – Edition 3 retains the philosophy of a risk-based safety management approach, which had already been established in the 2018 MASS Code of Practice. This demonstrates a reasonable continuity and the regulatory strategy of “soft-to-hard law,” whereby the United Kingdom has gradually institutionalized non-binding guidance into binding legal norms.
The promulgation of the Workboat Code – Edition 3 demonstrates the United Kingdom’s flexible yet proactive approach in regulating MASS. The United Kingdom has taken the initiative in developing and adapting its domestic legal framework to provide a safe and legitimate corridor for the testing and practical application of MASS technology.
3.4. Flexible Regulatory Policy
One of the legal instruments applied by the United Kingdom to facilitate the operation of MASS within its national waters is the Load Line Exemption Certificate, provided for under Section 9 of the Merchant Shipping (Load Line) Regulations 1998.[36] Specifically, Section 9(1) stipulates that: “The competent authority may issue an exemption certificate to a particular ship or class of ships where it considers that compliance with the load line regulations is impracticable or unnecessary for securing the safety of the ship or of persons on board, provided that such exemption does not adversely affect the safety of the ship or of persons on board.”
Through this mechanism, certain MASS have been granted pilot operation authorization even though they do not fully comply with the traditional technical standards applied to crewed vessels, such as requirements for proper load line markings under the 1966 International Convention on Load Lines (ICLL 1966).[37] However, this is a pragmatic measure rather than a purpose-designed regulatory tool specifically for MASS. In practice, this mechanism exhibits several notable limitations, including:
- It was not specifically designed for MASS, and therefore lacks the capacity to adequately address the operational characteristics of remotely operated or autonomous vessels;
- The approval process is complex, costly, and lacks transparency, creating difficulties for companies in accessing and implementing it;
- It does not fundamentally address core legal issues concerning the legal status of remote operators, liability, and operational safety.
In this context, the United Kingdom government has implemented a regulatory sandbox through the Maritime Autonomy Regulation Lab (MARLab), in coordination with the Department for Transport (DfT) and relevant stakeholders in the maritime sector. MARLab establishes a flexible legal testing environment, allowing MASS to operate under controlled conditions to evaluate and adapt existing regulations in a responsive manner. According to the MARLab summary report,[38] although the Merchant Shipping Act 1995 does not prohibit the presence or operation of MASS, legal gaps still exist regarding:
- Status of the “master”: It is necessary to clearly establish that an individual operating a MASS remotely (remote operator) can be regarded as the “master” under the legal definition;
- Concept of “crew”: It needs to be expanded to include personnel working at Remote Operations Centres (ROCs);
- Requirements for documentation and technical records: Including logbooks and certification, as well as clearly defining the operational boundaries within which a MASS may legally operate.
Thus, MARLab serves not only as a technical testing platform but also as a foundation for recommending legal reforms, aiming to establish a specialized and coherent legal framework for MASS in the United Kingdom in the future.
3.5. General Assessment of the United Kingdom’s Legal Framework for MASS
The current legal framework of the United Kingdom demonstrates a flexible and proactive approach to Maritime Autonomous Surface Ships (MASS), thanks to the open-ended definitions of “ship” and “master” in the law, as well as transitional support mechanisms such as regulatory sandboxes and the Load Line Exemption policy. The issuance of the MASS UK Code of Practice 2018 exemplifies efforts to bridge technical gaps during the period in which the legal framework was not yet fully developed. However, the system still exhibits limitations, such as the absence of an official legal definition of MASS and difficulties in applying traditional concepts of “crew” and “manning” to remotely operated vessels. The UK government is currently implementing comprehensive legal reforms to establish a dedicated regulatory framework for MASS,[39] laying the groundwork for the United Kingdom’s leading role in the international governance of autonomous shipping. In summary, this represents an “adaptive transitional” model—balancing technological innovation with rigorous legal oversight.
4. Legal Framework of China for Maritime Autonomous Surface Ships (MASS)
4.1. Current Legislation Governing MASS
The Maritime Code of China (MCC) 1992[40] is the foundational legal instrument regulating commercial maritime transport in China. According to Section 2 of Article 3, the term “ship” is defined as “sea-going vessels and other mobile devices”, excluding vessels used for military or official purposes, or with a tonnage under 20 GT. This definition effectively excludes most small-scale MASS models currently being tested in China, even if they are capable of offshore operations.For legal registration, a vessel must comply with the 2014 Ship Registration Regulations and meet technical standards issued by the China Classification Society (CCS). However, to date, the CCS has not issued technical standards specifically for unmanned vessels, rendering the registration of MASS technically and legally unfeasible.[41]
In addition, the Maritime Traffic Safety Law (MTSL) 2021[42] provides detailed regulation on vessel operation, navigation, and manpower requirements. Article 33 requires that all vessels must have a “minimum safety manning” and be operated by “crew with appropriate certification”, which poses a significant obstacle for MASS models without personnel physically on board. However, the definition of “ship” in Article 117 of the MTSL is framed more broadly, encompassing “mobile devices” such as offshore platforms and non-displacement vessels. Nevertheless, most operational provisions still implicitly assume a crewed model, resulting in an internal conflict between the definitions and their practical application.
Within China’s legal system, concepts such as “ship,” “master,” and “crew” are all linked to physical presence on board. According to Article 35 of the Maritime Code, the “master” is the person physically present on the vessel, holding command authority and bearing responsibility for its operation. Similarly, “crew” under Article 31 of the MCC and Article 4 of the 2020 Crew Management Regulations is understood to be individuals who are registered, certified, and work directly on board. Consequently, a remote operator is not legally recognized as a “master” or part of the “crew,” and therefore cannot assume the corresponding legal responsibilities. This is considered one of the most significant legal barriers to the practical deployment of MASS.[43]
4.2. Civil and Criminal Liability, and Insurance
Regarding civil liability, Section 1 of Article 47 of the MCC stipulates that the shipowner has the obligation to “ensure that the vessel is seaworthy, adequately manned, and properly equipped”, which is difficult to apply to unmanned vessels. Meanwhile, Article 51 allows for exemptions from liability for navigational errors of the master or crew, but this provision is no longer suitable for MASS—vessels without personnel on board—unless there is a legal mechanism recognizing the remote operator as part of the crew, which currently does not exist.
Regarding collisions, Articles 168–169 of the MCC apply a fault-based liability principle. In cases where the fault arises from software systems, sensors, or control algorithms, liability may shift to the manufacturer under the product liability provisions in Article 1202 of the Civil Code of China 2020 and Articles 41–42 of the Product Quality Law 2018.
Regarding criminal liability, Article 133 of the Criminal Code 2020 allows prosecution for acts causing serious accidents due to violations of traffic regulations, which could apply if a MASS causes an incident due to programming errors or remote operation. Additionally, Article 338 permits criminal sanctions for acts of environmental pollution, such as oil spills or hazardous chemical leaks from a MASS. However, these criminal provisions still focus on holding specific individuals accountable—an approach that is difficult to implement if the operator is not physically present in China or is not recorded in the national vessel registration system.[44]
4.3. China’s Cautious and Incremental Approach
Unlike the United Kingdom, China is currently adopting a cautious and incremental approach.[45] Technically, test zones such as the Zhuhai Wanshan Marine Test Field have been established to conduct limited trials of MASS models. However, legally, there has been no systematic effort to comprehensively amend fundamental statutes such as the MCC or MTSL. Nevertheless, some initial initiatives have been launched, notably proposals from the Ministry of Transport and the China Maritime Law Association regarding the establishment of a dedicated legal framework for MASS or the integration of MASS-specific regulations into the next amendment of the Maritime Code.
In addition to domestic initiatives, at the international level, China is also demonstrating an increasingly active role in the development of a global legal framework for MASS. Notably, the country actively participates in discussions at the Legal Committee (LEG) and the Maritime Safety Committee (MSC) of the IMO. In recent years, China has consistently submitted commentaries, national reports, and policy proposals providing guidance on the application of existing international maritime conventions to MASS. A prominent example is the proposal submitted on April 1, 2025, by the China Maritime Safety Administration (CMSA) to the IMO.[46] This document recommends the development of a “Guidelines for the Implementation of Legal Committee Instruments Related to MASS”, aimed at assisting member states in correctly interpreting and applying current legal provisions in light of emerging technologies.
This proposal does not aim to alter or amend the core content of existing international conventions (UNCLOS 1982, SOLAS 1974, or COLREGs 1972) but focuses on clarifying the interpretation and scope of application of legal provisions in the context of emerging non-traditional entities such as MASS. The document emphasizes the need for a guidance-oriented approach rather than early legislative amendments, especially given that the technology is still developing and has not reached a stable stage. This indicates that China does not seek to lead fundamental legal reform; instead, it aims to build a supportive, supplementary legal foundation that is flexible and adaptable, through the development of technical and legal guidelines.
This approach also clearly reflects China’s typical philosophy of legal regulation: rather than confronting head-on the legal challenges posed by new technologies, China seeks gradual adaptation through cautious yet strategic steps. The development of the aforementioned guidelines is seen as an intermediate measure, demonstrating China’s international commitment to the IMO while allowing the country to continue evaluating the practical operation of MASS before undertaking comprehensive amendments to international conventions and domestic laws. At the same time, through proposing initiatives and guiding discussions in international legal forums, China is gradually consolidating its position as a norm-shaping actor in the field of international maritime law on automation.
4.4. General Assessment of China’s Legal Framework on MASS
The current maritime legal system of China, including the MCC 1992 Act and the MTSLC 2021, is not yet prepared to accommodate unmanned surface vessels (MASS) at the level of autonomous operation without onboard crew. Although the laws provide a broad definition of “ship,” core concepts such as “master” and “crew” remain tied to physical presence on board (Article 35 of the MCC; Article 33 of the MTSLC), making it impossible for remote operators to assume legal responsibility under the existing legislation. Furthermore, MASS cannot be officially registered because they do not meet the current technical standards and inspection requirements of the China Classification Society. This results in MASS operating in China today falling within a “legal gray area,” not recognized as legitimate commercial vessels. Regarding legal liability, the legal framework is insufficiently clear to determine the subject responsible for civil, criminal, or environmental liability in the event of accidents caused by software faults or autonomous systems. This issue is particularly serious for MASS at levels 3–4, where humans no longer have direct control.
Although there is no official roadmap for amending the MCC or MTSLC, China is adopting a step-by-step approach: limited field trials, research on a “goal-based assessment framework,” and leaving open the possibility of developing specialized legislation for MASS in the future. It can be seen that China’s legal framework remains conservative, emphasizing safety and state control, but is gradually opening up flexible approaches to anticipate autonomous maritime technology
5. Comparison between the United Kingdom and China in Regulating Maritime Autonomous Surface Ships and Legal Policy Recommendations for Vietnam
5.1. Comparison of Legal Approaches to MASS between the United Kingdom and China
The United Kingdom and China represent two distinct legal models in their approach to regulating MASS. The United Kingdom pursues a proactive transition strategy, leveraging the open legal definitions in the MSA 1995 to legalize MASS during the period before specialized legislation is enacted. Additionally, the UK government has issued the MASS Code of Practice 2018, Workboat Code - Edition 3, and implemented supportive mechanisms such as legal testing frameworks and draft exemption policies to facilitate technical trials within a flexible legal framework. In contrast, China adopts a cautious and incremental approach, maintaining traditional definitions in the MCC 1992 and MTSLC 2021, while prioritizing real-world testing in supervised areas before proceeding with amendments to the core legislation
Regarding legal definitions, the United Kingdom defines a “ship” as any vessel engaged in navigation at sea (Section 313, MSA 1995), allowing MASS to be recognized as ships if they possess navigational capability. In contrast, the definition of “ship” in Article 3(2) of the MCC 1992 excludes vessels under 20 GT — a segment that mainly comprises autonomous vessels in the testing phase — which prevents most MASS in China from official registration. The issue is further exacerbated by the fact that the China Classification Society’s inspection standards currently lack specific criteria for unmanned vessels.
A clear point of divergence lies in the legal recognition of the roles of “master” and “crew.” In the United Kingdom, the definition of “master” under the MSA 1995 does not require physical presence on board, allowing a remote operator to be considered the master if they hold command authority. In contrast, Article 35 of the MCC 1992 mandates that the master must be physically present on the vessel to exercise command. Additionally, Article 31 of the MCC 1992 and China’s 2020 Crew Regulations require crew members to be certified individuals working directly on the ship. Consequently, remote operators in China are not legally recognized, creating a liability gap in the event of legal incidents involving MASS.
Differences are also reflected in liability and insurance mechanisms. The United Kingdom is developing technical guidelines and equivalence mechanisms to regulate non-traditional risks posed by MASS. Insurance providers in the UK have also begun adjusting policies to cover software errors, loss of communication, or cyberattacks. Meanwhile, China maintains existing regulations on "seaworthiness," which require vessels to be operated and maintained regularly by humans— a requirement that MASS cannot fulfill without a revision of the concept.
From an international perspective, the United Kingdom has actively participated in the development of the MASS Code under the International Maritime Organization (IMO),[47] while also aiming to amend SOLAS, STCW, and other core conventions to accommodate unmanned ships. China is likewise demonstrating an increasingly active role in the process of establishing a global legal framework for MASS; however, it appears to be adopting a strategy of waiting for international regulations to be finalized before incorporating them into its domestic law. This indicates that the level of proactiveness and legal readiness for MASS in the United Kingdom is higher than that of China.
In summary, it can be concluded that the United Kingdom is establishing a legal environment that is adaptive, innovation-friendly, and influential in shaping international standards, whereas China prioritizes safety, risk control, and only expands its legal framework once sufficient technical practice has been accumulated. These represent two complementary models in regulating MASS: one focuses on institutional leadership, the other on consolidating practical implementation—both offering valuable reference points for developing countries such as Vietnam.
5.2. The Current Legal Framework of Vietnam Regarding Maritime Autonomous Surface Ships (MASS)
As of now, the Vietnamese legal system has not established any legal provisions—either directly or indirectly—governing Maritime Autonomous Surface Ships (MASS). While some countries have issued technical guidelines or are in the process of amending their laws, the existing legal frameworks in Vietnam remain based on the traditional model, which requires the physical presence of human operators on board vessels.
The 2015 Vietnamese Maritime Code, the foundational legal instrument in the field of maritime transport, contains no references to the concepts of “autonomous ships,” “remotely controlled ships,” or “unmanned vessels.” According to Clause 1, Article 3, a “seagoing ship” is defined as a floating vehicle operating at sea for purposes such as transportation, scientific research, or national defense. However, the entire legal design of this concept, along with provisions on the "master" (Article 130)[48] and "crew" (Article 147),[49] is constructed on the assumption of the direct and continuous physical presence of human operators on board. As a result, MASS of levels 3 and 4 under the classification of the International Maritime Organization (IMO)—that is, vessels operated entirely without onboard personnel or operated remotely—fall into a legal vacuum. This leads to a number of consequences regarding registration, testing, insurance, and liability in the event of incidents.
In addition, other relevant legal instruments—such as the Law on Inland Waterway Traffic (2004, as amended in 2014), the Maritime Traffic Law, the Road Traffic Law, the Law on High Technologies, and the Law on Cyber Information Security—have yet to include provisions compatible with the operational realities of transport vehicles that are not directly controlled by humans. This results in a systemic legal gap that hinders technological innovation and the application of MASS in potential areas such as environmental monitoring, hydrographic surveying, short-distance transport, or unmanned rescue operations.
5.3. Policy Lessons from the United Kingdom and China
International experience indicates two viable policy approaches to regulating MASS, with the United Kingdom and China representing two distinct models.
The United Kingdom adopts an open, flexible, and innovation-driven approach by leveraging existing legal definitions, issuing technical codes of practice (such as the UK Code of Practice 2018 and the Workboat Code – Edition 3), allowing MASS trials through legal sandbox mechanisms and administrative exemptions (e.g., Load Line Exemption), while simultaneously developing a clearly defined roadmap for legislative reform.
China, by contrast, implements a cautious management strategy, characterized by controlled testing and post-trial legalization. MASS projects are confined to closely monitored areas (e.g., Zhuhai Wanshan Test Field), continue to adhere to traditional legal definitions, and only consider amending laws after test results and specific risk assessments have been completed.
From these two models, it can be concluded that both the soft pilot approach and the step-by-step cautious approach hold value in the Vietnamese context. However, either approach must be adjusted to align with Vietnam’s level of institutional development, technological oversight capacity, and the imperative of safeguarding national maritime sovereignty.
5.4. Policy Proposals and Action Framework for Vietnam
First, amend the basic legal definitions in the Maritime Code and traffic laws.
Vietnam needs to gradually integrate modern legal concepts into the existing legal system, specifically: (i) “Maritime Autonomous Surface Ships (MASS)” classified according to levels of automation consistent with IMO recommendations; (ii) “Remote operator” with legal status equivalent to that of a shipmaster; and (iii) “Remote or virtual crew,” including personnel operating at the shore control center. Clearly defining the legal status of operators in MASS operation is a prerequisite for implementing mechanisms related to liability, insurance, registration, and incident handling. Additionally, Vietnam may refer to China’s experience of maintaining traditional definitions but applying them flexibly in supervised testing zones, thereby accumulating data and cautiously adjusting definitions in line with technological development stages.
Second, develop a national technical code for MASS.
Before legal amendments can be enacted, Vietnam should issue a national technical code of practice for MASS under 24 meters, led by the Vietnam Maritime Administration in coordination with the Register of Shipping and the Ministry of Transport. This code could propose: (i) standards for design, control, security, and communication; (ii) accident response procedures and technical safety verification processes; and (iii) risk management methods based on a case-by-case approach.
Third, implement legal sandbox mechanisms in selected areas.
Vietnam can establish legal sandbox mechanisms in coastal or inland waterways with good control conditions, such as Ha Long Bay (automated tourism trials); Vung Tau (oil and gas maritime logistics); and Han River – Da Nang (smart urban water transport). Legal sandboxes allow operation within defined timeframes, scopes, and technical capabilities, while collecting data to support legal amendments. Similar to China’s model, test zones must be clearly defined and involve close coordination among relevant authorities to ensure safety and risk control, providing scientific and practical foundations for subsequent legal reforms.
Fourth, develop an insurance framework and liability allocation.
Operating MASS poses challenges to traditional liability and insurance regimes. Vietnam needs to: (i) study experimental insurance models; (ii) establish mechanisms for allocating responsibility among stakeholders—remote operators, system programmers, shipowners, and manufacturers; and (iii) amend civil and commercial laws to clarify compensation obligations in cases of technical faults.
Fifth, proactively participate in international initiatives.
Vietnam should actively engage in IMO working groups related to MASS to: (i) gain early access to global standards and practices; (ii) represent the interests of developing countries with small vessel fleets and short transport routes; and (iii) propose standard models appropriate to national and ASEAN regional capacities.
In conclusion, Vietnam needs to adopt a harmonized approach combining the UK’s flexible legal framework with China’s stepwise risk control. In the initial phase, issuing technical guidance and controlled trials will lay the foundation for building technological oversight and governance capacity. In the long term, Vietnam must systematically amend its laws to integrate MASS into the national legal system, while ensuring major objectives: maritime safety, protection of national interests, and the ability to integrate internationally in the digital maritime era.
6. Conclusion
The emergence and rapid development of Maritime Autonomous Surface Ships (MASS) challenge traditional legal principles that are built on the assumption of direct human control onboard vessels. In this context, the study and comparison of legal models from pioneering countries such as the United Kingdom and China offer significant theoretical and practical value for the process of building an appropriate institutional framework in Vietnam. This research shows that the United Kingdom adopts a proactive and flexible approach, leveraging open definitions within existing laws and issuing technical guidelines such as the MASS UK Code of Practice 2018 and Workboat Code – Edition 3. The UK government implements legal sandbox mechanisms and is in the process of amending laws to establish a specialized legal framework for MASS, while actively participating in global initiatives under the International Maritime Organization (IMO). In contrast, China maintains a cautious and stepwise approach, prioritizing field testing within tightly controlled regulatory frameworks and only considering legal amendments after accumulating sufficient practical data. Despite their differences, both countries demonstrate that a legal system capable of adapting to technological innovation requires a combination of flexible thinking, evolutionary regulatory techniques, and a solid legal foundation.
For Vietnam, the current legal gap concerning MASS is evident. However, this also presents an opportunity for Vietnam to engage with the issue early and develop an approach suitable to its domestic legal and technical capabilities. Based on international comparisons, this study proposes a combined approach: amending laws to legally recognize Maritime Autonomous Surface Ships, issuing technical standards during the transitional phase, implementing legal sandbox mechanisms, and gradually integrating with international standards through active participation in IMO.
In conclusion, MASS is not merely a technological product but an institutional test. The law needs to evolve from reactive thinking to innovation leadership, from a static regulatory model to a dynamic regulatory system, if it truly intends to accompany the development of the maritime industry in the 21st century.
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16.Zhao, X., & Wang, J., China's legal response to maritime autonomy: Gaps and challenges, Journal of Maritime Affairs (2023).
17.Wangwang Xing, Contemplating Maritime Autonomous Surface Ships (MASS) under the International Law on Ship-Source Pollution, Marine Pollution Bulletin 207 (2024).
18.W. Xing và L. Zhu, Legal barriers and gaps for unmanned merchant ships under Chinese law, Marine Policy, 153, 6 (2023).
[1]
This research is funded by the National Foundation for Science and Technology Development (NAFOSTED) under project code 505.99-2023.08.
* Dr. Do Viet Cuong, Faculty of International Law, University of Law, Vietnam National University, Hanoi. Approved for publication on June 22, 2025. Email: cuongvietdo@vnu.edu.vn
** Master’s Student, International Law Program, Course 29, University of Law, Vietnam National University, Hanoi.
[2] Anas S. Alamoush and Aykut I. Ölçer, Maritime Autonomous Surface Ships: Architecture for Autonomous Navigation Systems, Journal of Marine Science and Engineering 13, 1, 122 (2025).
[3] Xem CHONG-JU CHAE AND RAPHAEL BAUMLER, EDS., MARITIME AUTONOMOUS SURFACE SHIPS (MASS) - REGULATION, TECHNOLOGY, AND POLICY: THREE DIMENSIONS OF EFFECTIVE IMPLEMENTATION, VOL. 11, WMU STUDIES IN MARITIME AFFAIRS, SPRINGER NATURE SWITZERLAND (2024); A. S. Alamoush, A. I. Ölçer and F. Ballini, Drivers, Opportunities, and Barriers for Adoption of Maritime Autonomous Surface Ships (MASS), Journal of International Maritime Safety, Environmental Affairs, and Shipping 8, 4 (2024); Xue Li and Kum Fai and Yuen, A Human-Centred Review on Maritime Autonomous Surfaces Ships: Impacts, Responses, and Future Directions, Transport Reviews 44, 4, 791–810 (2024); Joel Coito, Maritime Autonomous Surface Ships: New Possibilities and Challenges in Ocean Law and Policy, International Law Studies 97, 1 (2021); Mingyu Kim et al., Autonomous Shipping and Its Impact on Regulations, Technologies, and Industries, Journal of International Maritime Safety, Environmental Affairs, and Shipping 4, 2, 17–25 (2020).
[4] Search NATALIE KLEIN, DOUGLAS GUILFOYLE, MD SAIFUL KARIM AND ROB MCLAUGHLIN, MARITIME AUTONOMOUS VEHICLES AND INTERNATIONAL LAW: MARITIME SECURITY PERSPECTIVES, ROUTLEDGE, ISBN 9781032675596 (2025); David Molina Coello, Is UNCLOS Ready for the Era of Seafaring Autonomous Vessels?, The Journal of Territorial and Maritime Studies 10, 1, 21–37 (2023); Robert Veal, Tsimplis Michael, and Andrew and Serdy, The Legal Status and Operation of Unmanned Maritime Vehicles, Ocean Development & International Law 50, 1, 23-48 (2019); Henrik Ringbom, Regulating Autonomous Ships—Concepts, Challenges and Precedents, Ocean Development & International Law 50, 2–3, 141–69 (2019).
[5] International Maritime Organization (IMO), Autonomous Shipping, (2021),
https://www.imo.org/en/MediaCentre/HotTopics/Pages/Autonomous-shipping.aspx
[6] HENRIK RINGBOM, ERIK RØSÆG AND TROND SOLVANG, AUTONOMOUS SHIPS AND THE LAW, ROUTLEDGE, ISBN: 9780367692049 (2023).
[7] Maritime UK, UK Code of Practice for Maritime Autonomous Surface Ships: Up to 24 Metres (Maritime UK, 2018),
https://www.maritimeuk.org/documents/379/MASS_UK_COP_2018_V2_B8rlgDb.pdf
[8] Department for Transport (DfT), Maritime Autonomy and Remote Operations: Final Impact Assessment(14/09/2023), https://www.gov.uk/government/publications/maritime-autonomy-and-remote-operations-final-impact-assessment Search British Maritime Law Association, CMI Questionnaire: Unmanned Ships (UK National Response), Comité Maritime International(2019), https://comitemaritime.org/work/unmanned-ships/
[9] Zhao, X., & Wang, J., China's legal response to maritime autonomy: Gaps and challenges, Journal of Maritime Affairs (2023).
[10] International Maritime Organization (IMO), Autonomous Shipping, (2021),
https://www.imo.org/en/MediaCentre/HotTopics/Pages/Autonomous-shipping.aspx
[11] International Maritime Organization (IMO), Autonomous ships: regulatory scoping exercise completed, (2021), https://www.imo.org/en/MediaCentre/PressBriefings/pages/MASSRSE2021.aspx
[12] Outcome of the regulatory scoping exercise for the use of Maritime Autonomous Surface Ships (MASS), MSC.1/Circ.1638 (2021),
https://wwwcdn.imo.org/localresources/en/MediaCentre/PressBriefings/Documents/MSC.1-Circ.1638%20-%20Outcome%20Of%20The%20Regulatory%20Scoping%20ExerciseFor%20The%20Use%20Of%20Maritime%20Autonomous%20Surface%20Ships...%20(Secretariat).pdf
[13]Search International Maritime Organization (IMO), Maritime Safety Committee - 108th session (2024), https://www.imo.org/en/MediaCentre/MeetingSummaries/Pages/MSC-108th-session.aspx
Search International Maritime Organization (IMO), Maritime Safety Committee - 109th session (2024), https://www.imo.org/en/MediaCentre/MeetingSummaries/Pages/MSC-109th-session.aspx
[14]
Decree No. 94/2025/ND‑CP of the Government dated April 29, 2025, stipulating the Controlled Testing Mechanism in the Banking Sector
Ministry of Science and Technology, National Agency for Science and Technology Information,
“Regulatory Sandbox Mechanism: From Theory to Practical Application Worldwide”,
Digital Development Strategy Bulletin No. 7/2021,
https://vista.gov.vn/vn-uploads/chien-luoc-phat-trien/2021_07/btld-so-7-2021.pdf
[15] See the definition of “ship” and the role of the master in the United Kingdom’s Merchant Shipping Act 1995, as cited in the British Maritime Law Association (BMLA), CMI Questionnaire on Unmanned Ships: UK National Response (Comité Maritime International, 2019), pp. 2–4.
https://comitemaritime.org/work/unmanned-ships/
[16] International Maritime Organization (IMO), International Convention for the Safety of Life at Sea (SOLAS), Consolidated Edition (1974).
[17] International Maritime Organization (IMO), International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW) (1978).
[18] HENRIK RINGBOM, ERIK RØSÆG AND TROND SOLVANG, AUTONOMOUS SHIPS AND THE LAW, ROUTLEDGE, ISBN: 9780367692049, 13-18 (2023).
[19] Search Barbara Stępień, Can a Ship Be Its Own Captain? Safe Manning of Autonomous and Uncrewed Vessels, Marine Policy 148, 105451 (2023).
[20] Zhao, X., & Wang, J. (2023). China's legal response to maritime autonomy: Gaps and Zhao, X., & Wang, J., China's legal response to maritime autonomy: Gaps and challenges, Journal of Maritime Affairs, 4-8 (2023).
[21] Chae, Y., & Baumler, R., Legal risks and insurance challenges in operating autonomous ships, Marine Policy, 3-7 (2023).
[22] United Nations, United Nations Convention on the Law of the Sea (UNCLOS) (1982).
[23] Search David Molina Coello, Is UNCLOS Ready for the Era of Seafaring Autonomous Vessels?, The Journal of Territorial and Maritime Studies 10, 1, 21–37 (2023).
[24] International Maritime Organization (IMO), International Convention for the Safety of Life at Sea (SOLAS), Consolidated Edition, Article 3.2 on exemptions, and Article 14, Chapter 5 on maritime safety(1974).
[25] International Maritime Organization (IMO), International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW),
Regulations II/1 (1978 [amended]).
[26] HENRIK RINGBOM, ERIK RØSÆG AND TROND SOLVANG, AUTONOMOUS SHIPS AND THE LAW, ROUTLEDGE, ISBN: 9780367692049, 64-68 (2023).
[27] International Maritime Organization (IMO), International Convention for the Prevention of Pollution from Ships (MARPOL), Appendix I, Regulation 15 (1973 [amended 1978]).
[28] Search Wangwang Xing, Contemplating Maritime Autonomous Surface Ships (MASS) under the International Law on Ship-Source Pollution, Marine Pollution Bulletin 207 (2024).
[29] International Maritime Organization (IMO), Convention on the International Regulations for Preventing Collisions at Sea (COLREGs), Rule 5 (1972).
[30] HENRIK RINGBOM, ERIK RØSÆG AND TROND SOLVANG, AUTONOMOUS SHIPS AND THE LAW, ROUTLEDGE, ISBN: 9780367692049, 97-102 (2023).
[31] Barbara Stępień, Navigating New Waters: IMO’s Efforts to Regulate Autonomous Shipping, Chinese Journal of International Law 23, 3, 599–629 (2024).
[32] United Kingdom, maritime commercial law 1995, Chapter 2
https://www.legislation.gov.uk/ukpga/1995/21/contents
[33] Maritime and Coastguard Agency (MCA), UK Maritime Autonomous Surface Ships: Code of Practice (2018), https://www.gov.uk/government/publications/maritime-autonomous-surface-ships-uk-code-of-practice
[34] Search the United Kingdom Maritime and Coastguard Agency, The Workboat Code – Edition 3 (Department for Transport, 23 Oct. 2023), in which this Code sets out the technical and safety requirements for workboats operating in the waters of the United Kingdom, including remotely operated or automated vessels – serving as a practical legal basis for testing and operating MASS within the framework of current legislation.
https://www.gov.uk/government/publications/the-workboat-code-edition-3.
[35] HFW (Holman Fenwick Willan), “UK publishes third edition of the Workboat Code”, Lexology, 9 Nov. 2023, See the United Kingdom Maritime and Coastguard Agency, The Workboat Code – Edition 3 (Department for Transport, 23 Oct. 2023), which sets out the technical and safety requirements for workboats operating in the waters of the United Kingdom, including remotely operated or automated vessels – serving as a practical legal basis for testing and operating MASS within the framework of current legislation.Access:https://www.lexology.com/library/detail.aspx?g=59f92eb4-9775-45ee-82a6-a221e3e48d94.
[36]
United Kingdom, The Merchant Shipping (Load Line) Regulations 1998
https://www.legislation.gov.uk/uksi/1998/2241/made
[37]
International Convention on Load Lines, 1966 – Load Line 66 , view at:
https://vmrcc.gov.vn/data/upload/files/S3.pdf
[38]
See the following reports:
(1) Maritime and Coastguard Agency, Maritime Autonomy Regulation Lab (MARLab) Report (2020), https://www.gov.uk/government/publications/maritime-autonomy-regulation-lab-marlab-report/maritime-autonomy-regulation-lab-marlab-report
(2) Department for Transport; Maritime and Coastguard Agency, Future of Transport Regulatory Review: Maritime Autonomy and Remote Operations – Final Impact Assessment (14 September 2023),
https://assets.publishing.service.gov.uk/media/650198b239d9f100143d3a41/fot-regulatory-review-maritime-autonomy-and-remote-operations-final-impact-assessement.pdf
(3) Department for Transport, Future of Transport Regulatory Review: Maritime Autonomy and Remote Operations – Consultation Response (14 September 2023),
https://www.gov.uk/government/consultations/future-of-transport-regulatory-review-maritime-autonomy-and-remote-operations
[39] Search the United Kingdom Government, Future of Transport Regulatory Review: Maritime Autonomy and Remote Operations (Department for Transport, 28 September 2021; updated 14 September 2023), in which the DfT proposes amending primary legislation to empower the Maritime and Coastguard Agency (MCA) to develop a specialized regulatory framework for Maritime Autonomous Surface Ships (MASS), demonstrating the UK Government's commitment to comprehensive legal reform.Access : https://www.gov.uk/government/consultations/future-of-transport-regulatory-review-maritime-autonomy-and-remote-operations.
[40] Maritime Code of the People’s Republic of China (Adopted at the 28th Meeting of the Standing Committee of the Seventh National People’s Congress on 7 November 1992; amended 14 April 2016), xem tại https://english.court.gov.cn/2016-04/14/c_761422.htm
[41] W. Xing and L. Zhu, Legal barriers and gaps for unmanned merchant ships under Chinese law, Marine Policy, 153, 6 (2023).
[42] National People’s Congress of the People’s Republic of China, Civil Code of the People’s Republic of China (Promulgated 28 May 2020; in force 1 January 2021), xem tại http://en.npc.gov.cn.cdurl.cn/2021-04/29/c_846012.htm
[43] W. Xing and L. Zhu, Legal barriers and gaps for unmanned merchant ships under Chinese law, Marine Policy, 153, 5 (2023).
[44] Xem Qiong Chen et al., From Concept to Practicality: Unmanned Vessel Research in China, Heliyon 9, 4, e15182 (2023).
[45] W. Xing và L. Zhu, Legal barriers and gaps for unmanned merchant ships under Chinese law, Marine Policy, 153, 8 (2023).
[46] China Maritime Safety Administration, “Draft Guidelines for Autonomous Ships’ Compliance with IMO Legal Committee Instruments Successfully Incorporated into IMO Legal Committee’s Work Plan,” China MSA (2025),https://en.msa.gov.cn/html/enmsa/newsList/article/2025/e052d08b9cc44cbfb58beaeea39e458c.html.
[47] See the United Kingdom Government, United Kingdom National Maritime Strategy for the IMO Instruments Implementation Code (2021), which demonstrates the UK's proactive role in developing and implementing legal instruments at the International Maritime Organization (IMO), including the MASS Code.
https://www.gov.uk/government/publications/united-kingdom-national-maritime-strategy-for-the-imo-instruments-implementation-code/united-kingdom-national-maritime-strategy-for-the-imo-instruments-implementation-code
[48] Article 130 of the 2015 Vietnam Maritime Code defines the "master" as the person who directly commands the ship, issues orders to the crew, and is responsible for all activities on board.
[49] According to Article 147 of the 2015 Vietnam Maritime Code:“The crew includes individuals present on board who have received appropriate training, hold valid professional certificates, and are assigned duties corresponding to the ship's size and function.”
