Panama MMC-359 – ISPS Code Implementation and Certification
The Panama Maritime Authority's Merchant Marine Circular MMC-359 provides guidance on the implementation and certification of the International Ship and Port Facility Security (ISPS) Code. It establishes the Administration's requirements, policies and interpretations concerning ship security compliance, ISPS verification procedures and the issuance and maintenance of International Ship Security Certificates (ISSC).
The circular addresses the responsibilities of Companies, Company Security Officers (CSOs) and Recognized Security Organizations (RSOs), together with certification procedures, verification windows, security equipment failures, certificate invalidation and related administrative requirements.
Purpose, Scope and Regulatory Background
Purpose of MMC-359
The circular provides information and guidance concerning the Panama Maritime Authority's requirements for compliance with the ISPS Code. It also sets out the Administration's policies and interpretations regarding the application and implementation of the Code.
Scope of Application
MMC-359 applies to all Panama-registered ships engaged on international voyages of 500 gross tonnage (GT) or more.
The applicability of the ISPS Code is further addressed in section 4.1 of the circular and in MMC-123.
Regulatory Background
The ISPS Code entered into force on 1 July 2004 following its adoption as an amendment to the International Convention for the Safety of Life at Sea (SOLAS), 1974, under Chapter XI-2.
Previous Circular Superseded
MMC-359 expressly states that it supersedes Merchant Marine Circular MMC-368.
ISPS Code Applicability and E-Certificate Platform
The ISPS Code applies to all Panamanian-flagged ships of 500 gross tonnage and above engaged on international voyages, as described in MMC-123.
Panamanian-flagged ships operating in international waters or on international coastal voyages must also comply with the national regulations of the coastal State or port State in which they operate, as applicable, to meet the requirements of the ISPS Code.
Applications for the issuance of a Full-Term International Ship Security Certificate (ISSC) or ISPS Authorization are available through the Panama Maritime Authority E-Certificate Platform.
Users must register to access the system and download the applicable User Manual.
Responsibilities of the Company
Companies operating Panama-flagged ships subject to the ISPS Code are responsible for ensuring that security personnel, verification arrangements and certificate applications are properly managed.
Company Security Officer Designation
The Company must designate a Company Security Officer (CSO) and ensure that the CSO holds a Declaration of Company Security Officer duly endorsed by the Panama Maritime Authority before the initial, intermediate or renewal verification.
SSAS Testing Management
For ships entering the Panamanian Registry, the CSO must schedule the first Ship Security Alert System (SSAS) test through the E-Certificate Platform.
Thereafter, the CSO must schedule an SSAS test every twelve months in accordance with MMC-133.
Coordination with the RSO
The Company must maintain proper communication with its Recognized Security Organization to ensure that all ISPS verifications are carried out within the timeframes established in Part A, section 19.1 of the ISPS Code.
Exceptional Verification Delays
Where exceptional circumstances prevent completion of an ISPS verification within the applicable timeframes under Part A, section 19.1.1 of the ISPS Code, the Company must submit a request through the E-Certificate Platform before the Interim ISSC expires or before the applicable renewal verification window expires, as appropriate.
Full-Term ISSC Application
Following completion of the initial or renewal verification, the Company must apply through the E-Certificate Platform for the issuance of the Full-Term ISSC by the Panama Maritime Authority, ensuring that the ship remains covered by a valid certificate.
Responsibilities of the Company Security Officer (CSO)
The CSO acts as the primary liaison between the Company and the Panama Maritime Authority for matters concerning implementation of the ISPS Code.
- Ensure that any change in the CSO or Alternate CSO is immediately reflected in an updated Ship Security Plan (SSP).
- Ensure that an officially endorsed Declaration of CSO issued by the Panama Maritime Authority is kept onboard each ship.
- Apply for the Declaration of Company Security Officer to be duly endorsed by the Panama Maritime Authority before the initial, intermediate or renewal verification conducted by the RSO, in accordance with MMC-123.
- Ensure that the Continuous Synopsis Record (CSR) is requested upon registration of the ship under the Panamanian flag and updated whenever changes occur.
- Coordinate all ISPS verifications with the RSO within the timeframes established in the ISPS Code.
- Schedule the annual Ship Security Alert System test in accordance with MMC-133.
- Ensure that the CSO's name and contact details are correctly reflected in the Ship Security Plan.
Instructions to Recognized Security Organizations (RSOs)
RSOs acting on behalf of the Panama Maritime Authority, as listed in MMC-136, must maintain communication with the Company and ensure that ISPS verifications are completed within the timeframes established in Part A, section 19.1 of the ISPS Code.
Documents and Equipment to Verify
- A valid Declaration of Company Security Officer duly endorsed by the Panama Maritime Authority must be kept onboard.
- The ship must carry an updated Continuous Synopsis Record (CSR).
- The SSAS must be properly configured to transmit alerts to [email protected], in accordance with MMC-133.
- Confirmation of the Annual SSAS Test issued by the Flag Administration must be available.
CSR Verification and Reporting
The ISPS Verification Report must indicate the number and date of issuance of the CSR carried onboard at the time of verification.
A CSR that is unavailable onboard or not updated constitutes a minor non-conformity. The RSO must proceed in accordance with paragraph 4.7.7 of MMC-359.
Submission Following Intermediate Verification
After completion of the intermediate verification, the RSO must submit a copy of the Verification Report and a copy of the duly endorsed ISSC to the Panama Maritime Authority as soon as practicable and no later than 30 days after completion.
Submissions must be sent to: [email protected] and [email protected].
Failure to comply with this requirement is considered malpractice under the circular.
Suspension or Withdrawal of Interim ISSC
Whenever an Interim ISSC is suspended or withdrawn by an RSO, the RSO must immediately notify the Panama Maritime Authority at:
Conditional Certificates
Where a Conditional Certificate is issued by an RSO with prior authorization from the Panama Maritime Authority, a copy must be submitted to [email protected].
Transfer Between Recognized Security Organizations
When a ship transfers its ISPS certification between RSOs, the gaining RSO must notify the Panama Maritime Authority by email and complete the Notification Form for Transfer of ISPS Certification between RSOs.
- The gaining RSO must notify the Administration at [email protected].
- The applicable Notification Form for Transfer of ISPS Certification between RSOs must be completed and submitted.
- Immediately after completion of the verification, and in any event no later than 30 days thereafter, the gaining RSO must submit the Verification Report and duly endorsed ISSC to [email protected].
- Where the transfer occurs during an Initial, Intermediate, Additional or Renewal Verification window, the gaining RSO must follow the applicable procedures in Annex 1, Scenarios 9, 10, 11, 12 and 13.
RSOs acting on behalf of the Republic of Panama must not, under any circumstances:
- Issue consecutive Interim ISSCs.
- Extend the validity of an Interim ISSC.
- Issue a Short-Term ISSC following successful completion of an initial verification, except for the exceptional circumstances referred to in section 4.6.17.
- Issue a Full-Term ISSC, which is issued exclusively by the Panama Maritime Authority.
- Establish or modify the applicable security level for a ship.
ISPS Verification Report Requirements
Each ship subject to the ISPS Code must undergo the verifications specified in Part A, section 19.1. The ISPS Verification Report must include, as a minimum:
- Place and date of the ISPS verification.
- Identification of the audit team.
- Type and scope of verification: Interim, Initial, Intermediate, Renewal or Additional.
- Audit plan.
- Name of the Company Security Officer.
- Identification of the Ship Security Officer (SSO).
- Sequence number and date of issuance of the latest Continuous Synopsis Record.
- Date of the latest Annual Ship Security Alert System test.
- Details of observations, non-conformities and required corrective actions, where applicable.
- Recommendations.
- Conclusion.
Major Non-Conformities
Where an RSO identifies a major non-conformity that compromises the security of the ship, its cargo or its personnel, it must be documented and immediately reported to the CSO and the Administration through the Maritime Ship Security Department at [email protected].
Security Equipment or System Failures
Any failure of security equipment or systems, or suspension of a security measure that does not compromise the ship's ability to operate at Security Levels 1, 2 or 3, must be reported without delay.
The report must describe equivalent alternative security measures implemented onboard and provide an action plan with the repair or replacement schedule.
ISPS Verification Types and Certification
MMC-359 addresses Interim, Initial, Intermediate, Renewal and Additional Verifications, together with the different ISSC types and the conditions for their issuance and continued validity.
Interim Verification and Interim ISSC
An Interim ISSC may be issued only after the RSO has verified compliance with Part A, section 19.4 of the ISPS Code.
The circular identifies the following circumstances:
- A ship without an ISSC upon delivery or before entering or re-entering service.
- A ship transferred to the Panamanian Registry through a change of flag.
- A ship for which a Company has newly assumed responsibility for its operation.
Following the interim verification, the Interim ISSC must be clearly identified as an interim certificate and must not exceed six months' validity.
Initial Verification
The Initial Verification must be completed within the validity period of the Interim ISSC in accordance with Part A, section 19.1.1 of the ISPS Code.
It must be carried out before the ship is put into service or before the Full-Term ISSC is issued for the first time, to verify full compliance with the applicable requirements of Part A, sections 19.1 and 19.2.
Intermediate Verification
At least one Intermediate Verification must be carried out between the second and third anniversary dates of the Full-Term ISSC, corresponding to a period between 24 and 36 months from completion of the Initial or Renewal Verification.
The intermediate verification window cannot be extended or postponed. Failure to complete the verification within the prescribed period automatically invalidates the ISSC.
Following successful completion, the RSO endorses the Full-Term ISSC.
Renewal Verification
Renewal Verification must be carried out at intervals not exceeding five years and completed within the period established by Part A, sections 19.1.1.2 and 19.3 of the ISPS Code.
Following successful completion, the RSO endorses the existing Full-Term ISSC in accordance with Part A, section 19.3.4. The circular provides for a five-month endorsement period from completion of the renewal verification, during which the Company must apply through the E-Certificate Platform for the new Full-Term ISSC.
Additional Verification
An Additional Verification may be conducted at the request of the Panama Maritime Authority or by Port State Control Authorities.
Prior PMA authorization through the E-Certificate Platform is required for:
- Verification to close outstanding non-conformities.
- SSAS malfunction.
- Replacement of SSAS equipment.
Prior authorization is not required for:
- Change of ship name.
- Change of gross tonnage.
- Change of ship type.
- Port State Control detention.
- Flag State detention.
In cases of PSC detention, the PSC Inspection Report and the corresponding ISPS Verification Report must be submitted immediately to [email protected].
Full-Term ISSC
The Full-Term ISSC is issued exclusively by the Panama Maritime Authority after successful completion of an Initial or Renewal Verification and demonstration of compliance with the applicable requirements of SOLAS Chapter XI-2, the ISPS Code and additional Panama Maritime Authority requirements.
Its validity must not exceed five years from the completion date of the Initial or Renewal Verification.
The original Full-Term ISSC must be kept onboard the ship at all times.
Special ISSC Procedures and Exceptional Circumstances
Exceptional Delay of Initial Verification
If exceptional circumstances prevent completion of the Initial Verification before the Interim ISSC expires, the Company, shipowner, RSO or legal representative must submit a request through the E-Certificate Platform under the ISPS Authorizations option before expiry of the Interim ISSC.
The request must include:
- A statement from the RSO explaining why the verification could not be completed and specifying the exact date and place of the planned Initial ISPS Verification.
- A copy of the Interim ISSC.
- A copy of the valid Document of Compliance (DOC).
- A copy of the Safety Management Certificate (SMC).
The Administration will verify that the ship has a valid Conformance Test Report (CTR) when the application is received.
Prohibition of Consecutive Interim ISSCs
In accordance with Part A, section 19.4.5 of the ISPS Code, consecutive Interim ISSCs must not be issued.
Neither the Administration nor the RSO may grant an extension or consecutive Interim ISSC where the intention is to delay full compliance with SOLAS Chapter XI-2 and Part A of the ISPS Code.
Short-Term ISSC
In exceptional circumstances, the Panama Maritime Authority may authorize an RSO to issue a Short-Term ISSC, subject to the conditions stated in MMC-359.
The circular identifies circumstances involving changes to information during certificate validity, an Initial Verification completed on the same day that the Interim ISSC expires, the cases described in paragraph 4.6.5, and extraordinary circumstances in accordance with MSC-MEPC.5/Circ.17 dated 18 June 2026.
Its validity must not exceed 30 days from the date of issuance or remain valid beyond the ship's arrival at the next port.
Changes During Interim ISSC Validity
Where specified information changes during the validity of an Interim ISSC, the RSO must reissue the Interim ISSC with the same expiry date as the existing certificate.
- Change of ship's name.
- Change of gross tonnage.
- Change of Company name or registered address.
- Change of ship type.
Changes During Full-Term ISSC Validity
For the specified changes during Full-Term ISSC validity, the RSO must issue a Short-Term ISSC with validity not exceeding 30 days. The Panama Maritime Authority will subsequently reissue the Full-Term ISSC with the same expiry date as the existing certificate, provided the applicable requirements have been fulfilled.
- Change of ship name – Annex 1, Scenario 4.
- Change of gross tonnage – Scenario 5.
- Change of ship type – Scenario 6.
- Change of Company name or registered address – Scenarios 7 and 8.
Initial Verification Following Registration or Company Change
Following an Initial Verification after new construction, transfer to the Panama Registry or a change of Company, the Panama Maritime Authority will issue the Full-Term ISSC only after satisfactory completion of verification and receipt through the E-Certificate Platform of the application for amendment of item 14 of the CSR.
The amended CSR and Full-Term ISSC are issued simultaneously.
Certificate Validity and Renewal Requirements
Renewal When the Ship Is Not in a Suitable Port
Where the ISSC expires while the ship is not in a port where Renewal Verification can be carried out, the Panama Maritime Authority may extend the certificate in accordance with Part A, section 19.3.5 of the ISPS Code.
The request must be submitted through the E-Certificate Platform under the ISPS Authorizations option and must include confirmation from the RSO specifying the exact date and port where the Renewal Verification will be conducted, together with the reasons preventing completion of the verification.
Before expiry of the three-month extension period, the Renewal Verification must be completed and the Company must immediately apply through the E-Certificate Platform for the Full-Term ISSC.
Once the maximum extension period expires, the RSO must not issue additional ISPS certification. If the Renewal Verification has not been completed within the applicable period, the existing ISSC is considered invalid and the ISPS certification process must be re-initiated, including an Interim Verification, subject to prior authorization by the Administration.
Remote Verification
Remote verification may be carried out by the Recognized Organization (RO) in exceptional circumstances and in accordance with the conditions and limitations established in MSC-MEPC.5/Circ.17 – Guidance on Assessments and Applications of Remote Surveys, ISM Code Audits and ISPS Code, dated 18 June 2026.
A remote verification must be followed by the corresponding in-person verification, as applicable. It must not be considered a substitute for physical attendance and verification by the RO.
Conditional International Ship Security Certificate
A Conditional Certificate may be issued by a Recognized Organization (RO) only with prior authorization from the Panama Maritime Authority.
The circular identifies the following circumstances:
- Major non-conformities have been identified.
- Damage, failure or unavailability of equipment or systems affects the validity of the certificate.
- Other circumstances are duly justified and authorized by the Panama Maritime Authority.
Issuance is subject to a determination that the security of the ship and the safety and security of persons onboard are not compromised and that the situation does not present an unacceptable risk to maritime security.
The validity period is determined by the Panama Maritime Authority according to the circumstances and must not exceed 90 days. The certificate must be clearly identified as a "Conditional Certificate".
The issuing RO must submit a copy without delay to [email protected] and [email protected].
Major and Minor Failures
The circular establishes reporting and corrective-action requirements for failures affecting security equipment, systems and the ship's ability to comply with the ISPS Code.
Major Failure
Security equipment identified in the approved Ship Security Plan must remain operational at all times.
During ISPS verification, the RSO must verify that the SSAS and Long-Range Identification and Tracking (LRIT) equipment are fully operational and that the ship carries a valid Conformance Test Report (CTR), in accordance with MMC-133 and MMC-195.
Failure of either the SSAS or LRIT system, or absence of a valid CTR, is considered a Major Failure under the circular.
Major Failure Reporting
A Major Failure must be reported immediately to:
- The Panama Maritime Authority at [email protected].
- The Port Facility Security Officer (PFSO), where applicable.
- The competent authorities of relevant coastal States, where applicable.
Corrective Action for Major Failures
Immediate corrective action must be taken to restore compliance before the ship departs.
The Major Failure must be downgraded before the RSO endorses the ISSC following an Intermediate or Renewal Verification.
Where a Major Failure is identified during an Initial Verification, the RSO must request authorization from the Panama Maritime Authority for issuance of a Conditional Certificate.
Additional Verification
The Panama Maritime Authority may establish additional conditions or corrective measures before authorizing a Conditional Certificate.
An Additional Verification must be carried out within the period agreed by the Administration and the RSO to verify effective implementation of corrective actions.
Minor Failure
Any Minor Failure must be reported by the RSO to the Panama Maritime Authority without delay at [email protected].
The report must include:
- Details of equivalent alternative security measures implemented onboard until the failure or suspension is rectified.
- An action plan specifying the schedule for repair or replacement of the affected equipment or system.
Invalidation of the International Ship Security Certificate
Authority to Invalidate
An Interim ISSC may be invalidated only by the RSO that issued it.
A Full-Term ISSC may be invalidated only by the Panama Maritime Authority, following notification from the RSO. The notification must be submitted to [email protected].
Circumstances Leading to ISSC Invalidation
Under paragraph 4.8.2, an ISSC becomes invalid in circumstances including:
- The ship has not undergone the required Initial, Intermediate or Renewal Verification within the applicable ISPS Code timeframe.
- The Company ceases to assume responsibility for the operation of the ship.
- The ship is transferred to another flag State.
- A Full-Term ISSC has been issued to replace the Interim ISSC.
- The Company requests withdrawal of the ship from the Panama Maritime Authority's ISPS Register.
- A section of the approved Ship Security Plan requiring prior approval has been amended without authorization from the Panama Maritime Authority.
- Corrective actions arising from an ISPS verification have not been completed within the agreed timeframe.
- The ship operates in a manner that does not comply with applicable ISPS Code requirements.
- The ship fails to maintain its approved Ship Security Plan in accordance with the ISPS Code.
- Other circumstances which, in the opinion of the RSO, justify recommending invalidation to the Panama Maritime Authority.
Ships Out of Service for More Than Six Months or in Areas Affected by Warfare
Ships Out of Service
Where a ship has remained out of service for more than six months, the Company must request an Interim ISSC in accordance with Part A, section 19.4.2 of the ISPS Code.
Before issuance of the Interim ISSC, the RSO must verify that the ship complies with the applicable requirements of Part A, section 19.4.2. The procedures in Annex 1, Scenario 14, must also be followed.
Ships in Areas Affected by Warfare
Ships that have remained out of service for more than six months, or are located in areas affected by warfare and have been unable to carry out required audits due to such circumstances, may request Lay-Up Status from the Panama Maritime Authority.
Such requests are subject to applicable requirements and evaluation by the Administration.
Harmonization of ISM and ISPS Certification
The Panama Maritime Authority recognizes the harmonization of ISM and ISPS audits and certification. Harmonization reduces the number of separate auditor and verification visits onboard, optimizing the use of time and resources while maintaining compliance with the applicable regulatory requirements.
Following successful completion of a harmonized ISM/ISPS audit and verification, the Safety Management Certificate (SMC) and International Ship Security Certificate (ISSC) must be issued with the same date of issuance and the same expiry date.
The Company must apply through the E-Certificate Platform for issuance of the Full-Term ISSC in accordance with Annex 1, Scenario 17.
SSAS Exemption Certificate
Applications for a Ship Security Alert System (SSAS) Exemption Certificate must be submitted in accordance with the provisions of MMC-123.
Companies and relevant parties should refer to MMC-123 for the applicable application requirements and procedures.
Printing Requirements for ISSC, ISPS Authorization and SSAS Exemption Certificate
International Ship Security Certificate
The ISSC must be printed in a two-page format, using Letter size (8.5" × 11") or A4 size if Letter size is unavailable.
It must be kept onboard the ship and may be printed in black and white or in colour.
ISPS Authorization
The ISPS Authorization must be printed in a single-page format, using Letter size (8.5" × 11") or A4 size if Letter size is unavailable.
It must be kept onboard the ship and may be printed in black and white or in colour.
SSAS Exemption Certificate
The SSAS Exemption Certificate must be printed in a single-page format, using Letter size (8.5" × 11") or A4 size if Letter size is unavailable.
It must be kept onboard the ship and may be printed in black and white or in colour.
ISPS Compliance Checklist
The following checklist summarizes important requirements addressed in MMC-359 for Companies, CSOs and RSOs.
- Confirm that the ship falls within the scope of the ISPS Code and MMC-359.
- Ensure that the CSO is designated and holds a PMA-endorsed Declaration of CSO.
- Keep the approved Ship Security Plan updated, including the CSO's name and contact details.
- Ensure that the CSR is onboard, valid and updated.
- Schedule the first and subsequent annual SSAS tests in accordance with MMC-133.
- Confirm that SSAS alerts are configured to transmit to [email protected].
- Maintain operational SSAS and LRIT equipment.
- Maintain a valid Conformance Test Report in accordance with MMC-195.
- Coordinate ISPS verifications within the applicable ISPS Code verification windows.
- Submit exceptional-delay requests through the E-Certificate Platform before the applicable certificate expiry or verification window deadline.
- Ensure that the RSO submits the required Verification Reports and endorsed certificates within the specified 30-day period, where applicable.
- Apply through the E-Certificate Platform for issuance of the Full-Term ISSC following successful Initial or Renewal Verification.
- Report major and minor failures and implement the required corrective and alternative security measures.
- Ensure that the original Full-Term ISSC and applicable authorizations are kept onboard.
Frequently Asked Questions – Panama MMC-359
The following questions summarize key requirements of the Panama Maritime Authority's MMC-359. They are intended as a practical reference and should be read together with the complete circular and its applicable references.
Which ships are covered by Panama MMC-359?
MMC-359 applies to Panama-registered ships engaged on international voyages of 500 gross tonnage (GT) or more, as described in MMC-123.
Which circular does MMC-359 supersede?
MMC-359 expressly states that it supersedes Merchant Marine Circular MMC-368.
When did the E-Certificate Platform application process become available?
Effective 1 September 2025, online applications for Full-Term ISSC issuance and ISPS Authorization are available through the Panama Maritime Authority E-Certificate Platform. Users must register to access the system and download the User Manual.
Does the Company Security Officer require a PMA-endorsed declaration?
Yes. The Company must designate a CSO and ensure that the CSO holds a Declaration of Company Security Officer duly endorsed by the Panama Maritime Authority before the initial, intermediate or renewal verification.
How often must the SSAS test be scheduled?
For ships entering the Panamanian Registry, the first SSAS test must be scheduled through the E-Certificate Platform. Thereafter, the CSO must schedule an SSAS test every twelve months in accordance with MMC-133.
What must an RSO check during ISPS verification?
The RSO must verify, among other requirements, that a valid PMA-endorsed Declaration of CSO is onboard, the CSR is updated, the SSAS is configured to transmit alerts to [email protected], and confirmation of the Annual SSAS Test issued by the Flag Administration is available.
Who issues the Full-Term International Ship Security Certificate?
The Full-Term ISSC is issued exclusively by the Panama Maritime Authority after satisfactory completion of an Initial or Renewal Verification and fulfilment of the applicable requirements. The RSO does not issue the Full-Term ISSC.
What is the maximum validity of an Interim ISSC?
The Interim ISSC must be clearly identified as an interim certificate and must not exceed six months' validity.
Can consecutive Interim ISSCs be issued?
No. MMC-359 refers to Part A, section 19.4.5 of the ISPS Code and prohibits consecutive Interim ISSCs. Neither the Administration nor the RSO may grant an extension or consecutive Interim ISSC to delay full compliance with SOLAS Chapter XI-2 and Part A of the ISPS Code.
When must the Intermediate Verification be completed?
At least one Intermediate Verification must be completed between the second and third anniversary dates of the Full-Term ISSC, corresponding to 24 to 36 months from completion of the Initial or Renewal Verification. The circular states that this window cannot be extended or postponed.
What happens if the Intermediate Verification window is missed?
Failure to complete the Intermediate Verification within the prescribed period automatically invalidates the ISSC under MMC-359.
How long is the renewal endorsement period described in MMC-359?
Following successful Renewal Verification, the RSO endorses the existing Full-Term ISSC in accordance with Part A, section 19.3.4. MMC-359 describes a five-month validity endorsement period from the completion date of the renewal verification, during which the Company must apply through the E-Certificate Platform for issuance of the Full-Term ISSC.
When is prior PMA authorization required for an Additional Verification?
Prior authorization through the E-Certificate Platform is required for verification to close outstanding non-conformities, SSAS malfunction and replacement of SSAS equipment. The circular also identifies cases where authorization is not required, including specified ship particulars changes and PSC or Flag State detention.
What is the validity of a Short-Term ISSC?
Under the circumstances described in MMC-359, a Short-Term ISSC must not exceed 30 days from the date of issuance or remain valid beyond the ship's arrival at the next port.
Can an RSO issue a Conditional Certificate?
An RO may issue a Conditional Certificate only with prior authorization from the Panama Maritime Authority and subject to the conditions stated in MMC-359. The security of the ship and the safety and security of persons onboard must not be compromised. The certificate must not exceed 90 days' validity.
Which equipment failures are classified as Major Failures?
MMC-359 identifies failure of either the SSAS or LRIT equipment, or absence of a valid Conformance Test Report (CTR), as a Major Failure.
How must a Major Failure be reported?
It must be reported immediately to the Panama Maritime Authority at [email protected], the Port Facility Security Officer where applicable, and the competent authorities of relevant coastal States where applicable.
Can ISPS verification be conducted remotely?
Remote verification may be carried out in exceptional circumstances under the conditions and limitations established in MSC-MEPC.5/Circ.17 dated 18 June 2026. It must be followed by the corresponding in-person verification, as applicable, and cannot replace physical attendance and verification by the RO.
What happens when a ship remains out of service for more than six months?
The Company must request an Interim ISSC in accordance with Part A, section 19.4.2 of the ISPS Code. The RSO must verify compliance with the applicable requirements before issuing the Interim ISSC. The procedures in Annex 1, Scenario 14, must also be followed.
Does MMC-359 allow harmonization of ISM and ISPS certification?
Yes. The Panama Maritime Authority recognizes harmonization of ISM and ISPS audits and certification. Following successful completion of a harmonized audit and verification, the SMC and ISSC must have the same issuance date and expiry date.
How must the ISSC and related documents be printed and kept onboard?
The ISSC must be printed in two pages. The ISPS Authorization and SSAS Exemption Certificate must each be printed on one page. Letter size (8.5" × 11") or A4 size where Letter size is unavailable may be used. Each document must be kept onboard and may be printed in black and white or colour.
Regulatory References and Related Panama Circulars
MMC-359 refers to the following legislation, international instruments and Panama Maritime Authority circulars:
- Law No. 7 of 27 October 1977 – adoption of the SOLAS Convention.
- Resolution No. 106-107-DGMM of 9 October 2017.
- SOLAS Chapter XI-2 – Special Measures to Enhance Maritime Security.
- International Ship and Port Facility Security (ISPS) Code.
- IMO Resolution MSC.198(80) of 20 May 2005.
- MSC-MEPC.5/Circ.17 of 18 June 2026 – Guidance on Assessments and Applications of Remote Surveys, ISM Code Audits and ISPS Code.
- Panama Merchant Marine Circular MMC-123.
- Panama Merchant Marine Circular MMC-133 – Ship Security Alert System (SSAS).
- Panama Merchant Marine Circular MMC-136.
- Panama Merchant Marine Circular MMC-183 – Continuous Synopsis Record.
- Panama Merchant Marine Circular MMC-346.
- Panama Merchant Marine Circular MMC-399.
- Panama Merchant Marine Circular MMC-195 – LRIT requirements, as referenced in the failure provisions.
Official Contact and Further Information
Panama Maritime Authority
General Directorate of Merchant Marine
Maritime Ships Security Department
Telephone: +507 501-5037 / 501-5085
Email: [email protected]
Official website: Panama Ship Registry – Circulars
E-Certificate Platform: Panama Maritime Authority E-Certificate Platform
Circular Revision History
- October 2026: Completely revised.
- August 2025: Modifications to paragraphs 4.2.4, 4.2.5, 4.7.2.2, 4.7.4.6, 4.8.2, 4.8.3, 4.10.3, 4.10.5, 4.11.2 and 4.19.1, as stated in the supplied revision history.
- June 2025: Modification of paragraph 4.7.2.
- March 2025: Correction in paragraph 4.7.3.
- February 2025: Restructuring of the circular.
- June 2024: Elimination of paragraph 17 regarding overdue verification and renumbering of paragraphs.
- September 2023: Restructuring of the circular.
- May 2021: Inclusion in the references and replacement of Annex 1 – paragraph 17.4 and paragraph 26 (note).
- February 2021: New paragraphs 7.11, 11.4, 15.1 and 26; paragraphs renumbered.
- May 2020: New paragraph 25 and renumbering of paragraphs.
- December 2019: Modification of item 9.2 and items 5, 9, 12 and 17 of Annex 1.
- October 2019: Change of circular subject, restructuring of numerical sequence and modification of paragraphs 8, 9, 10, 11, 12, 13 and 14.
- June 2019: Inclusion of the Annex for application for SSAS Exemption Certificate.
- March 2019: Modification of paragraph 7 and 9, and new paragraphs 9.1, 14, 20.1 and 21.
- January 2019: Inclusion of paragraphs 19 and 20.
- December 2018: Modifications and new paragraphs concerning items 11, 17 and 19; modification of item 18, point 4.
- February 2018: Inclusion of new paragraphs 2.10 and modification of items 8, 9 and 12.
- November 2017: Earlier circular issue.