Does the 2026 SOLAS Rule Reach Old Ships?
Only if it is a passenger ship. MSC.550(108) catches existing ro-pax at the first survey on or after 1 Jan 2028; an existing car carrier is not named.
Only if the old ship carries passengers. Resolution MSC.550(108), in force since 1 January 2026, does reach existing tonnage — three of its paragraphs bind ships built before 2026, including ships built before 1 July 2012, at the first survey on or after 1 January 2028. Every one of those paragraphs is scoped to passenger ships. An existing cargo ship, which is what a pure car and truck carrier is, complies with the previously applicable text and has no retrofit obligation from this amendment at all. That is a correction to the earlier version of this post, and it is read from the resolution, not from a summary.
Which existing ships the 2028 date names
Passenger ships with vehicle, special category or ro-ro spaces — three times, in three places. The application clause the resolution inserts as paragraph 20.2.1.3 reads: passenger ships constructed before 1 January 2026, including those constructed before 1 July 2012, shall also comply with regulations 20.4.1.6, 20.4.4 and 20.6.2.3. Each of those three paragraphs then repeats the scope in its own text — 4.1.6 opens "for passenger ships constructed before 1 January 2026", 4.4 names "passenger ships with vehicle, special category or ro-ro spaces constructed before 1 January 2026", and 6.2.3 opens "for passenger ships constructed before 1 January 2026". The deadline in every case is the first survey on or after 1 January 2028.
"First survey" has a defined meaning. Under MSC.1/Circ.1290 it is the first annual survey, the first periodical survey or the first renewal survey, whichever falls due first after the date in the regulation. For a ferry on an annual cadence that is the first annual after 1 January 2028 — one cycle away, with plan approval expected ahead of it.
What an existing ro-pax has to fit by 2028
Three things, each with a number attached. Paragraph 20.4.1.6 requires a fixed fire detection and alarm system to the FSS Code across special category, open and closed ro-ro and vehicle spaces, providing smoke and heat detection throughout — with heat detectors at the spacing and coverage that apply to smoke detectors, and heat detection required only where a smoke detector already is. On the existing FSS Code table that is 74 m² per detector, 11 m between centres, 5.5 m from a bulkhead. Paragraph 20.4.4 requires video monitoring of the same spaces, cameras high enough to see over loaded vehicles, immediate playback, and 24 hours of retention on an existing ship against seven days on a newbuild, with the correspondence between each camera and its drencher section displayed at the monitor. Paragraph 20.6.2.3 requires fixed water monitors covering any weather deck used for vehicles, each of at least 1,250 L/min, positioned for unobstructed coverage and operable from a safe access way or by remote control.
The text leaves the Administration room on the hardest item. On the weather-deck monitors it may permit lower flow rates where 1,250 L/min is not practical for the size and arrangement of the ship, and alternative arrangements for ships that already had a monitor system before 2026. On detection the Korean Register's implementation note observes that combined smoke-and-heat detectors are already on the market and that the upgrade may be achievable by replacing detector heads and updating the control panel — but recommends owners confirm the extent with the manufacturer before assuming so.
What an existing car carrier has to fit
Nothing from this resolution. The application text of the amended section 4.1 is explicit: paragraphs 4.1.1 to 4.1.4 apply only to passenger ships constructed on or after 1 January 2026; 4.1.5 applies to cargo ships constructed on or after 1 January 2026; and "cargo ships constructed before 1 January 2026 shall comply with the previously applicable requirements of paragraph 4.1". No cargo ship appears in the video-monitoring paragraph, whose operative sentence begins "for passenger ships", nor in the weather-deck monitor section, whose operative sentences begin "in passenger ships". The 2028 date does not occur in any paragraph that a cargo ship is subject to.
What a car carrier does inherit is confined to newbuilds. A cargo ship constructed from 2026 gets paragraph 4.1.5 — an FSS Code fixed detection system "capable of rapidly detecting the onset of fire", tested after installation under normal ventilation with an overall response time to the Administration's satisfaction — and, if it voluntarily fits combined smoke-and-heat or linear heat detectors, the new FSS Code Chapter 9 spacing that MSC.555(108) applies to ships built from that date. Neither reaches a ship already in service.
Why the retrofit reading spreads
Because the resolution does touch cargo ships — just not the parts anyone retrofits. MSC.550(108) rewrites regulation 7.5.5 on accommodation and control-station detection for new cargo ships, and paragraph 20.3.1.5 on permanent openings in cargo-ship ro-ro spaces. Class summaries are accordingly titled for ro-ro, passenger and cargo ships, and the ABS application table has a cargo-ship row. A reader who takes the title and the 2028 date together, without following the paragraph numbers, arrives at a retrofit obligation that the paragraphs do not contain. The Korean Register's note draws the line plainly: existing provisions in SOLAS Chapter II-2 do not require combined or linear heat detectors on cargo ships.
Video monitoring is surveillance, not detection
The one point the earlier version had right survives the correction. The video system an existing ro-pax must fit by 2028 is a recording and playback system; the regulation says in terms that continuous monitoring of the image by the crew is not required. It exists to let a watch-keeper find the fire once something is visible and to give the investigation a timestamped record. It does not alarm ahead of flame, and it is not a detection layer. The detection layer on the same ship is the smoke-and-heat system in the overhead, at 74 m² per head — which tells the crew a zone, and now a somewhat smaller zone, is in alarm.
What it means for owners and underwriters
For a ro-pax owner the date is real and close. Three retrofit items, one of them — the weather-deck monitors — potentially a pump and piping job, all to be surveyed at the first annual after 1 January 2028. The sensible sequence is to get the manufacturer's assessment of the detection upgrade and the flag's position on monitor flow rates this year, and to book the work against the 2027 docking rather than the 2028 survey.
For a PCTC owner the honest statement is that no statutory deadline is coming before 2032 at the earliest, when the IMO's vehicle-carrier package could enter into force — and the interim guidelines that precede it are still being drafted. That does not mean the fleet is standing still; it means the pressure to fit detection beyond the FSS minimum is contractual and commercial, and should be described that way in a specification or a safety case. For an underwriter the practical rule is the same as for the newbuild: a submission that cites "2028 SOLAS compliance" for an existing car carrier is citing an obligation that does not exist, and the question to ask is what is actually installed on the deck.
How RoRoSAFE helps
Whether or not the 2028 date names your ship, per-vehicle detection can be fitted now. RoRoSAFE installs alongside the berth without drydock on existing ro-pax and car carriers. It adds thermal and battery-vent gas sensing that alerts before visible smoke. It complements the SOLAS detection a ship must carry and does not claim to satisfy it; it holds no class type approval yet.
Pilot: one deck · installed alongside the berth · no drydock · 6 months of dashboard access
Sources
- 1. IMO Resolution MSC.550(108), adopted 23 May 2024 — Amendments to Chapters II-2 and V of SOLAS 1974, in force 1 January 2026. Regulation 20 as amended: 2.1.3 (retroactive application — passenger ships constructed before 1 January 2026, including before 1 July 2012, to comply with 20.4.1.6, 20.4.4 and 20.6.2.3); section 4 chapeau and 4.1 application text (4.1.1–4.1.4 passenger ships constructed on or after 1 January 2026; 4.1.5 cargo ships constructed on or after 1 January 2026; cargo ships constructed before that date comply with the previously applicable 4.1); 4.1.6 (existing passenger ships — smoke and heat detection, heat detectors at smoke-detector spacing, only where a smoke detector already exists); 4.3.1 (efficient fire patrol in special category spaces); 4.4 (video monitoring — seven days new, 24 hours existing; camera-to-section correspondence displayed; continuous crew monitoring not required); 6.1 chapeau and 6.2.3 (existing passenger ships — weather-deck monitors of at least 1,250 L/min; Administration may permit lower rates or alternative arrangements). Read from the resolution text.
- 2. IMO Resolution MSC.555(108) — Amendments to Chapters 7 and 9 of the FSS Code, applying to ships constructed on or after 1 January 2026: combined smoke-and-heat and linear heat detector specifications and spacing. Existing smoke-detector spacing (74 m², 11 m, 5.5 m) from the FSS Code Chapter 9 table as reproduced in the ABS note below.
- 3. ABS Regulatory News No. 15/2025 (December 2025) — "Fire Safety Requirements for Ro-Ro, Passenger and Cargo Ships": application table by ship type and construction date; existing passenger ships to comply no later than the first survey on or after 1 January 2028; cargo ships constructed before 1 January 2026 — requirements prior to MSC.550(108) remain applicable; "first survey" defined per MSC.1/Circ.1290 as the first annual, periodical or renewal survey, whichever is due first.
- 4. Korean Register — "Amendments taking effect in 2026: SOLAS and related mandatory Codes": retroactive requirements on existing passenger ships confirmed by attending surveyors no later than the first survey on or after 1 January 2028; heat detectors at 5.5 m and 74 m²; combined detectors available on the market and the upgrade potentially achievable by replacing detectors and updating the control panel; existing SOLAS II-2 does not require combined or linear heat detectors on cargo ships.
- 5. DNV — "IMO Sub-Committee on Ship Systems and Equipment (SSE 12)", March 2026: interim guidelines on fire safety measures for PCTCs and on video monitoring and detection to precede SOLAS amendments; correspondence group to SSE 13 (March 2027); entry into force 1 January 2032 at the earliest.
Questions, answered
Does the January 2026 SOLAS fire amendment apply to existing ships?+
To existing passenger ships, yes. MSC.550(108) paragraph 20.2.1.3 makes three requirements retroactive on passenger ships constructed before 1 January 2026, including those built before July 2012: smoke-and-heat detection (20.4.1.6), video monitoring with 24-hour retention (20.4.4) and weather-deck water monitors of at least 1,250 L/min (20.6.2.3). Each must be met at the first survey on or after 1 January 2028. Existing cargo ships are not named.
Does the 2028 deadline apply to an existing car carrier?+
No. A PCTC is a cargo ship, and the amended section 4.1 states that cargo ships constructed before 1 January 2026 comply with the previously applicable requirements. The video-monitoring and weather-deck monitor paragraphs are written for passenger ships. No paragraph a cargo ship is subject to carries the 2028 date. The vehicle-carrier package is separate IMO work with entry into force in 2032 at the earliest.
What does an existing ro-pax have to fit by 2028?+
Three things. Heat detection added throughout vehicle, special category and ro-ro spaces at smoke-detector spacing — 74 m² per head, 11 m between centres, 5.5 m from a bulkhead — wherever a smoke detector already exists; a video monitoring system covering those spaces with immediate playback and 24 hours of retention; and fixed water monitors of at least 1,250 L/min each on any weather deck used for vehicles.
Is a video monitoring system the same as fire detection?+
No. The required system is recording CCTV with playback — the regulation says continuous crew monitoring of the image is not required. It helps a watch-keeper locate a fire once something is visible and gives investigators a timestamped record; it does not raise an alarm ahead of flame. Detection on the same ship remains the smoke-and-heat system in the overhead, which reports a zone.
Continue the thread
What Does SOLAS II-2/20 Ask of a Car Carrier?
Almost all of the 2026 amendment is written for passenger ships. A cargo ship gets one detection paragraph; the car-carrier package is still in draft.
Is Individually Identifiable Detection Required?
On a passenger ship, since 2012 — the FSS Code defines the term. On a car carrier, no: MSC.550(108) leaves cargo ships at section identification.
What Does SOLAS 2026 Video Monitoring Require?
Cameras over every passenger-ship vehicle deck, 7-day playback, each camera mapped to a drencher section, no one required to watch. Cargo ships: nothing.
Does Car-Carrier Fire Compliance Arrive in 2027?
No. 2027 holds no entry-into-force date. The calendar is 2026 (new passenger ships), 2028 (existing ro-pax) and 2032 at the earliest for PCTCs.
Is the Car-Carrier Fleet Too Old for EVs?
The newbuild wave isn't retiring old tonnage — a 26-year-old PCTC just sold for ~$42M. So EV cargo increasingly rides on 1990s-era fire detection.
What Port State Control Checks on Decks
Fire safety was the leading deficiency area in the Paris MoU's 2025 report, and a 2026 campaign targets cargo securing. What PSC checks on a vehicle deck.
Class Fire Notations Beyond the SOLAS Floor
SOLAS is the floor. Class notations like DNV's F-AMC and ClassNK's AFVC(FD)(EV) certify the early detection and evacuation owners add above it.
SOLAS II-2/7: Fixed Detection vs IR
Draft SOLAS II-2/7.11 would put two portable IR imagers on container ships. On a packed vehicle deck a hand-held imager can't reach most of the cargo.