MSC-FAL.1/Circ.3/Rev.3
4 April 2025
GUIDELINES ON MARITIME CYBER RISK MANAGEMENT
1 The Facilitation
Committee, at its forty-first session (4 to 7 April 2017), and the Maritime
Safety Committee, at its ninety-eighth session (7 to 16 June 2017), having considered
the urgent need to raise awareness on cyber risk threats and vulnerabilities,
approved the Guidelines on maritime cyber risk management.
2 The Guidelines
provide high-level recommendations on maritime cyber risk management to
safeguard ships from current and emerging cyberthreats and vulnerabilities. The
Guidelines also include functional elements that support effective cyber risk
management.
3 The Maritime
Safety Committee, at its 104th session (4 to 8 October 2021), and the
Facilitation Committee, at its forty-sixth session (9 to 13 May 2022), approved
an update to the additional guidance and standards included in paragraph 4.2 of
the Guidelines.
4 The Maritime
Safety Committee, at its 108th session (15 to 24 May 2024), and the Facilitation
Committee, at its forty-ninth session (10 to 14 March 2025), approved a
revision to the Guidelines on maritime cyber risk management, as set out in the
annex.
5 Member Governments
are invited to bring the contents of this circular to the attention of all
stakeholders concerned.
6 This circular and
any revisions supersede the interim guidelines contained in MSC.1/Circ.1526.
ANNEX
GUIDELINES ON MARITIME CYBER RISK MANAGEMENT
1 INTRODUCTION
1.1 These Guidelines
provide high-level recommendations for maritime cyber risk management. For the
purpose of these Guidelines, maritime cyber risk refers to a measure of
the extent to which Computer Based Systems (CBS) are threatened by a potential
circumstance or event, which may result in shipping-related operational, safety
or security failures as a consequence of information or systems being
corrupted, lost or compromised.
1.2 Stakeholders should
take the necessary steps to safeguard shipping from current and emerging
threats and vulnerabilities related to digitalization, integration and
automation of processes and systems in shipping.
1.3 For details and
guidance related to the development and implementation of specific risk
management processes, users of these Guidelines should refer to specific Member
Governments' and flag Administrations' requirements and guidance, as well as
relevant international and industry standards and best practices.
1.4 Risk management is
fundamental to safe and secure shipping operations. Risk management has
traditionally been focused on operations in the physical domain, but greater
reliance on digitalization, integration, automation and network-based systems
has created an increasing need for cyber risk management in the shipping
industry.
1.5 Predicated on the
goal of supporting safe and secure shipping, which is operationally resilient
to cyber risks, these Guidelines provide recommendations that can be
incorporated into existing risk management processes. In this regard, the
Guidelines are complementary to the safety and security management practices
established by this Organization.
2 GENERAL
2.1 Key definitions
Computer Based System (CBS) means a programmable
electronic device, or interoperable set of programmable electronic devices,
organized to achieve one or more specified purposes such as collection,
processing, maintenance, use, sharing, dissemination, or disposition of
information. CBSs on board include IT and OT systems. A CBS may be a
combination of subsystems connected via a network. Onboard CBSs may be
connected directly or via public means of communications (e.g. Internet) to
ashore CBSs, other vessels' CBSs and/or other facilities.
Cyber incident means an occurrence or a sequence of
occurrences, which actually or potentially results in adverse consequences to a
CBS or to the information that they process, store or transmit, and which may
require a response action to mitigate the consequences.
Cyber risk management means the process of
identifying, analysing, assessing and communicating a cyber-related risk and
tolerating, terminating, transferring or treating it to an acceptable level by
taking into consideration the costs and benefits of actions taken by
stakeholders.
Information Technology (IT) refers to CBSs that are
focused on the use of data as information, including software, hardware, and
communication technologies (e.g. commercial information, or data about the
crew, such as salaries, certificates, etc.).
Operational technology (OT) refers to CBSs that are
focused on the use of data to control or monitor physical processes (e.g. the
main engine's oil temperature levels, which are forwarded to the control room).
2.2 Background
2.2.1 Digital
technologies, including CBS, have become essential to the
operation and management of numerous systems critical to the safety and
security of shipping and protection of the marine environment. In some cases,
these systems are to comply with international standards and the
Administration's requirements. However, the vulnerabilities created by
accessing, interconnecting or networking with these systems can lead to
cyberthreats and risks which should be addressed. Relevant systems could
include, but are not limited to:
.1 Bridge systems, (such
as navigation systems, ship safety systems, communications systems, etc.);
.2 Cargo, bunkering,
lubrication, ballast and other pumping handling and management systems;
.3 Propulsion, fuel and
machinery management and power control systems;
.4 Security, access
control and surveillance systems;
.5 Passenger and crew
servicing and management systems;
.6 Passenger, crew and
subcontracted service personnel facing public networks;
.7 Administrative and
crew welfare systems;
.8 Ship-port interfaces;
and
.9 Ship-to-shore
integrated systems (e.g. remote control systems/Maritime Autonomous Surface
Ships).
2.2.2 When looking at
CBSs, the distinction between information technology (IT) and operational
technology (OT) systems should be considered. Furthermore, the protection of
information during data exchange, storage and usage within these systems should
also be considered. Vulnerabilities in the OT systems may increase the
operational safety risks of ships that may jeopardize the safety of both crew
and passengers. Therefore, OT systems should be segmented from IT systems,
protected from Internet-facing systems and have appropriate protection tools.
2.2.3 While these
technologies and systems provide significant efficiency gains for the maritime
industry, they also present threats and risks to the operation of systems
integral to shipping which, if affected, will have a safety, security and
environmental impact. These risks may result from vulnerabilities arising from
inadequate security-by-design, operation, integration, maintenance of systems
or system patching, and from intentional and unintentional actions.
2.2.4 Cyber risks are
presented by malicious actions (e.g. hacking or introduction of malware) or the
unintended consequences of benign careless actions (e.g. software maintenance
or user permissions). In general, these actions can expose or exploit
vulnerabilities (e.g. outdated software or ineffective firewalls) in CBSs.
Effective cyber risk management should consider assessing and addressing both
kinds of threats.
2.2.5 Vulnerabilities can
result from inadequacies in design, integration and/or maintenance of systems,
as well as lapses in cyber hygiene. In general, where vulnerabilities in CBSs
are exposed or exploited, either directly (e.g. weak passwords and/or careless
password management leading to unauthorized access) or indirectly (e.g. the
absence of network segregation), there can be implications for the
confidentiality, integrity and availability of data, as well as implications
for the safety and security of a ship, particularly where critical systems
(e.g. bridge navigation, main propulsion systems, cargo on/off-loading systems)
are compromised.
2.2.6 Effective cyber risk
management should also consider risks posed by third-party vendors, embedded
systems, and cyberthreats related to software and hardware supply chains of
systems used in shipping. Account should also be taken of CBS maintenance
devices and systems.
2.2.7 These rapidly
changing technologies and threats make it difficult to address these risks only
through technical standards. As such, these Guidelines recommend a risk
management approach to cyber risks that is resilient and evolves as a natural
extension of existing safety and security management practices.
2.2.8 In considering
potential sources of threats and vulnerabilities and associated risk mitigation
strategies, a number of potential control options for cyber risk management
should be taken into account, including amongst others, management, operational
or procedural, and technical controls.
2.3 Application
2.3.1 These Guidelines are
primarily intended for ships, and are designed to encourage safety and security
management practices in the cyber domain.
2.3.2 Recognizing that no
two ISM companies in the shipping industry are the same, these Guidelines are
expressed in broad terms in order to have a widespread application. Ships with
limited digital systems may find a simple application of these Guidelines to be
sufficient; however, ships with complex digital systems may require a greater
level of care and should seek additional resources through reputable industry
and Government partners.
3 ELEMENTS OF CYBER
RISK MANAGEMENT
3.1 For the purpose of
these Guidelines, cyber risk management means the process of
identifying, analysing, assessing and communicating a cyber-related risk and
tolerating, terminating, transferring or treating it to an acceptable level,
considering costs and benefits of actions taken by stakeholders.
3.2 The goal of
maritime cyber risk management is to support safe and secure shipping, which is
operationally resilient to cyberthreats and risks. Safeguarding ships and
ship-port interfacing systems from emerging threats should involve a range of
controls that are continually evolving. Therefore, cyber resilient security
features should be incorporated in the ship's equipment and systems at the
design, manufacturing, integration, operation and maintenance stages.
3.3 Effective cyber
risk management should start at the senior management level. Senior management
should follow the relevant training and embed a culture of cyber risk awareness
into all levels of an organization and ensure a holistic and flexible cyber
risk management regime that is in continuous operation and constantly evaluated
through effective feedback mechanisms.
3.4 One accepted
approach to achieve the above is to comprehensively assess and compare an
organization's current, and desired, cyber risk management postures. Such a
comparison may reveal cybersecurity gaps in CBSs that can be addressed to
achieve cyber resilience objectives through a risk-based approach. This
risk-based approach is to evaluate the cyber risks, considering ship type and
operational profile as well as onboard systems' complexity and connectivity,
which will enable an organization to best apply its resources in the most
cost-effective and efficient manner.
3.5 These Guidelines
present the functional elements that support effective cyber risk management.
These functional elements are not sequential – all should be concurrent and
continuous in practice and should be incorporated appropriately in a risk
management framework. The functional/technical cybersecurity controls listed
under each of the functional elements represent the minimum controls that
should be implemented. Additional cybersecurity controls may be considered
depending on the evaluation of the identified cyber risks.
.1 Govern: Establish
and monitor risk management strategy, expectations and policies. Define
personnel roles and responsibilities for cyber risk management. Ensure business
continuity, such as backup management and disaster recovery, and crisis
management.
.1 Designate a person
or entity accountable for the planning, resourcing and execution of
cybersecurity activities.
.2 Ensure that the
designated person or entity is given the necessary authority and support to
fulfil their duties and that they have sufficient knowledge and expertise in
cyber risk management.
.2 Identify: Determine
the current cyber risk to ships and ship/port interfaces.
.1 Identify the
systems, assets, services, data and capabilities, interdependencies between
safety critical systems (including the information flow) that, when disrupted,
pose risks to ship operations, human safety, safety of the ship and/or a threat
to the environment, including those related to the software and hardware supply
chains.
.2 Establish and
maintain an inventory of digital systems on board the ship. These systems and assets
could include the systems listed in paragraph 2.2.1 of these guidelines.
Identify internal and external systems dependencies and network connections.
.3 Carry out a risk
assessment of those systems, services, assets, data and capabilities critical
to ship operations, the sudden operational failure of which may result in
hazardous situations. Identify cyber-related threats. Identify vulnerabilities
to systems, services, assets, data and capabilities. Assess the likelihood and
impact of a cyber incident on the safety, availability, integrity and
confidentiality of those elements.
.3 Protect: Implement
risk control processes and measures to protect CBSs, and contingency planning
to protect against a cyber incident and ensure business continuity of shipping
operations, human safety, safety of the vessel and/or threat to the
environment.
.1 Assign unique
credentials for all users, separate user and privileged accounts, collect
security devices and deactivate accounts for departing employees or users.
.2 Change all default
passwords on all devices, enforce a strong password policy and consider
establishing other user account access control management measures to safeguard
against malicious attempts such as brute force attacks, phishing, etc. Use multi-factor
authentication or continuous authentication solutions, secured voice, video and
text communications and secured emergency communication systems within the
entity, where appropriate.
.3 Limit exploitable
services on the Internet, establish a hardware and software approval process,
collect and securely store logs for intrusion detection and incident response,
and segment OT device networks from IT networks. Ensure security in network and
information systems acquisition, development and maintenance, including
vulnerability handling and disclosure.
.4 Implement security
measures (such as firewall or antivirus) for any ship digital systems and
devices that have access to the Internet or the company's intranet, or any
interaction with third party or landside network and information systems,
particularly those of ship/port interfaces. Implement policies and procedures
regarding the use of cryptography.
.5 Establish controls
to protect systems from the use of unauthorized removable media.
.6 Mandate annual basic
cybersecurity training for all employees and OT-specific cybersecurity training
for OT users, and cybersecurity familiarization to all crew members upon
engagement on board the ship. This training for all employees and OT users
should include elements on cyber hygiene, the recognition and detection of an
ongoing cyber incident, as well as response and recovery. Knowledge on
cybersecurity should occasionally be tested, for example through drills and
exercises.
.7 Perform regular
system backups, software updates, and develop and maintain incident response
(IR) plans.
.8 Establish policies
on software and hardware supply chain security for those systems and assets
that have been identified as critical.
.9 Establish policies
and procedures to assess the effectiveness of cyber risk management measures,
such as audits, and to periodically review and update these measures.
.4 Detect: Develop,
implement and practise activities necessary to detect a cyber incident in a
timely manner. Implement appropriate measures to detect unintended activity on
CBS and timely identification of a cyber incident.
.1 Maintain a list of
relevant threats, threat actor tactics, techniques and procedures and actively
monitor systems for those threats.
.2 Annual basic
cybersecurity training for all employees should include training on recognizing
and detecting an ongoing cyber incident.
.5 Respond: Develop,
implement and practise activities and plans to provide resilience and