Consultation on the merchant shipping (EPIRB and PLB registration) regulations 2025
- From:
- Maritime and Coastguard Agency
- Published
- 5 December 2024
- Last updated
-
1714JanuaryOctober 2025 — See all updates
Detail of outcome
This section is included under the ‘Public Feedback’ tab as a joint document.
Detail of feedback received
Section 1: Introduction
This consultation sought views on a new Statutory Instrument (SI), The Merchant Shipping (EPIRB and PLB Registration) (Radiocommunications) (Amendment) Regulations 2025 (“the new regulations”) which will amend EPIRB registration requirements to reflect changes in technology and introduce new PLB registration requirements for UK flagged ships, hovercraft and watercraft to enable His Majesty’s Coastguard (HMCG) to take Search and Rescue (SAR) action more efficiently.
These requirements derive from the UK’s obligations in international law and form an important part of the SAR framework to ensure that details held on the United Kingdom’s online registration platform are as accurate as possible for SAR purposes, meeting their underlying critical aim, the prevention of loss of life at sea.
The new regulations will revoke and replace The Merchant Shipping (EPIRB Registration) Regulations 2000 and also make various amendments to other SIs.
Section 2: Consultation
This consultation was published on www.gov.uk and notifications of the consultation were sent to more than 50 organisations, including shipping and marine industry companies, fishing and leisure craft organisations, equipment manufacturers, government departments and agencies, and other interested parties. A press notice was also issued, and the consultation was publicised on numerous social media platforms.
The consultation consisted of the proposed draft legislation, a De Minimis Options Assessment (DMOA), a Marine Guidance Note (MGN) and a Merchant Shipping Notice (MSN). The consultation was carried out from 5 December 2024 until 21 February 2025.
Consultees were invited to comment on any aspect of the consultation; but more specifically to respond to the consultation questions as outlined in Section 4 of this report.
A total of seven responses were received; not all respondents answered all the questions posed and some submitted additional comments. These have been fully considered. A list of respondents can be found in section 5 below. The MCA would like to thank individuals and organisations who submitted responses to this consultation.
Section 3: Key findings
The consultation highlighted a number of key areas which have led to further investigation and amendments where appropriate. The key points raised are detailed below:
Application of the Regulations:
Some respondents believed that these Regulations are applicable to paddle boarders and kayakers; however, this is not the case – they are applicable to UK flagged ships, hovercraft and watercraft. It is therefore evident that greater clarity is required in the guidance to ensure all stakeholders (including amateur sailors, divers, paddle boarders, and kayakers etc.) fully understand the scope of these regulations.
Consequently, the government has undertaken a thorough review and revision of both the MSN and MGN, taking into account feedback received, and will undertake another short consultation process, with the aim of ensuring that the guidance is sufficiently clear on the application of these regulations.
Offences and penalties:
There was some support for making the registration of EPIRBs and PLBs used in the maritime environment compulsory. Overall, however, most respondents felt that the proposed offences and penalties lacked proportionality and believed that non-registration of a PLB would result in either an immediate vessel detention or prison sentence. This is not the case, and it is clear that guidance needs to be more detailed to provide clarity.
The MCA, like any UK regulator in respect of each area of activities it oversees, must ensure that the maritime regulatory framework is capable of being enforced effectively. This derives from the UK’s obligations under international law, as well as domestic legal responsibilities.
Enforcement comprises a range of responses, which include prosecution or detention of a ship for breach of a prescribed requirement. However, the MCA must act reasonably, fairly and proportionately in exercising its enforcement functions. Therefore, prosecution would only be pursued in the more serious cases of breaches, and the maximum prescribed penalties would only be available to be imposed by the courts in the most exceptional/or egregious cases, e.g. where a failure or repeated failure to register a beacon is proven to have caused loss of life.
Registration of beacons:
From the responses received, it was clear that stakeholders were keen that PLBs should be registered to an individual rather than a ship – and that ship details should not be a mandatory element for PLB registration. Feedback also highlighted that where beacons are frequently transferred between ships in various scenarios, constantly updating registration details would be onerous and ultimately could dissuade users from registering beacons.
In response to this feedback, the MCA are now proposing that the responsibility for registering a PLB lies with the PLB owner. We intend to consult stakeholders further on this change.
For frequent transfers of PLBs from one United Kingdom ship or hovercraft, or watercraft, to another, registration of ship details is not mandatory. However, registering these details can assist search and rescue operations if needed.
Further information relating to the need for accurate and timely registration details has also been provided in the MGN, explaining how as many details as possible can support the reduction in the current high rate of false alerts (92%) in order to utilise search and rescue resources more efficiently, reduce the risk of life to everyone and how the availability of as much intelligence as possible supports the deployment of the right resources to the right place to ensure the best possible outcome.
Section 4: Consultation questions and answers
The MCA would like to thank the respondents for taking the time to read and respond to the consultation.
The consultation has provided useful feedback from a variety of sectors. The government has utilised this feedback to review and revise the statutory instrument and the associated guidance documents and will now be going out for a shorter second round of consultation.
The Response form was Section 5 of the Consultation Document. This section contains a full list of consultation questions, a summary of responses to those questions and the MCA’s response.
Q1 Do you agree that the MCA should make the registration of EPIRBs and PLBs used in the maritime environment compulsory?
Summary of consultee views:
There were 7 responses to this question: 3 were in favour and 3 against, one respondent gave a Yes and No answer. Some consultees supported the compulsory registration of EPIRBs but had concerns relating to the registration of PLBs, as proposed.
MCA response:
The MCA welcomes the feedback and has taken this into account in the review and revision of PLB registration, particularly in regard to the view that these should not necessarily be linked to a vessel, but to individuals. It is hoped that these revisions will make PLB registration less onerous to users. However, the MCA intends to proceed with making PLB registration requirements compulsory for UK flagged ships, hovercraft and watercraft.
Q2 Do you consider that you have received sufficient notification of the requirements with which you will have to comply?
Summary of consultee views:
There were 7 responses to this question – 3 stated yes and 4 stated no. Further communication was requested to ensure that stakeholders were fully aware of requirements. There were concerns from some that they had not heard about the consultation through official channels and that dialogue should have taken place with individual stakeholder groups.
One respondent also wanted to see a long grace period before making PLB registration mandatory and a PR campaign to inform PLB owners of the registration requirement.
MCA response:
Noting concerns relating to who the Regulations apply to, the guidance has been revised to provide further clarity.
The consultation was published on Gov.uk, through multiple social media channels at the time of launch, as well as being disseminated to numerous stakeholders, including individuals and groups. The number of stakeholders means that having dialogue with every individual/group is prohibitive in terms of resource - our usual approach is to undertake a consultation exercise to seek as many views as possible from as many stakeholders as possible and then utilise this to inform where clarification and or amendments may be required. Some more targeted consultation may then be considered, as well as further consultation to seek as many views as possible.
However, it is useful to understand where our dissemination did not reach the intended target audience/stakeholders. Due to the small number of responses received, we have taken the decision to review and revise documentation and go out to consultation again, taking further steps to ensure that the consultation opportunity is more widely received by stakeholders to ensure sufficient notification of the requirements.
As registration takes approximately 5 minutes, the MCA did not see the need for a grace period or lead-in time to implementation: however, as there will be a further round of consultation, it will be more than a year between initial notification of our intention to change the regulations and their implementation.
Q.3 Do you think that the proposed new regulations and accompanying Merchant Shipping Notice will implement the requirements of both EPIRB and PLB registration clearly and in a way which is effective?
Summary of consultee views:
All 7 respondees stated no. One respondent stated that the legislation was not clear as it suggested that the SI did not apply to a kayaker who has a PLB for personal use.
Some respondents supported the mandatory registration of EPIRBs and PLBs used on UK flagged vessels but felt that PLBs should be registered to an individual rather than to a vessel as proposed, so that registration details would not need to be updated when frequently transferring between vessels.
MCA response:
Greater clarity and information is needed in the guidance to ensure that stakeholders are clear about who these regulations apply to, whether they be amateur sailors, divers, paddle boarders, kayakers etc. It is correct that the legislation does not apply to kayakers but by not stating who the legislation does NOT apply to in the guidance, this has created some uncertainty.
Therefore, the MCA has clarified in the guidance that the requirements do not apply to certain apparatus not propelled by mechanical means, such as kayaks and paddleboards. Nevertheless, we would encourage anyone who is carrying out activities on water using such apparatus to register their 406 MHz PLBs as this would assist if rescue were to be required.
In response to concerns and feedback relating to PLBs being registered to an individual rather than a vessel, the MCA are now proposing that the responsibility for registering a PLB lies with the PLB owner. We intend to consult stakeholders further on this change.
Q4
a) Do you agree that the offences and penalties as set out in the proposed new regulations are necessary, fair and proportionate?
Summary of consultee views:
Overall, most (5/7) respondents felt that the proposed offences and penalties lacked proportionality and believed that a prison sentence would be immediately bestowed upon any-one not registering their PLB. One respondent wanted more rationale behind the penalties to facilitate understanding.
MCA response:
Further clarity and detail has been added to the guidance to explain that the MCA, like any UK regulatory in respect of each area of activities it oversees, must ensure that the maritime regulatory framework is capable of being enforced effectively. This derives from the UK’s obligations under international law, as well as domestic legal responsibilities.
Enforcement comprises a range of responses, which include prosecution or detention of a ship for breach of a prescribed requirement. However, the MCA must act reasonably, fairly and proportionately in exercising its enforcement functions.
Therefore, guidance has been revised to explain that prosecution would only be pursued in the more egregious cases of breaches, and the maximum prescribed penalties would only be available to be imposed by the courts in the most exceptional/or egregious cases, for example, where a failure to register a beacon is proven to have caused loss of life.
b) Is there a way that the penalties can be more effective?
Summary of consultee views:
Two respondents stated yes, two responded no and 3 did not provide a response.
One respondent felt that it would be beneficial to implement a period of education during the early implementation of the legislation to ensure that minor omissions of registration could be supported by advice and education rather than a formal penalty.
MCA response:
Providing more clarity on proportionality and consideration/application of penalties may help consultees assess their effectiveness.
The MCA agree that omissions of registration would be supported by advice and education prior to consideration of any detention/penalty. The MCA will also be publicising the requirements prior to implementation.
c) Do you feel that the proposed penalties will act as an effective deterrent for non-compliance with the requirements of the proposed new regulations?
Summary of consultee views:
One respondent stated yes, five stated no and one stated yes and no. One respondent felt that as long as the registration remained at no charge, then safety conscious individuals and boat operators would recognise the benefits of registration and how it would enhance the chances of them being located in a search and rescue situation.
Other respondents felt that the penalties were disproportionate, so this would deter owners from registration.
MCA response:
The MCA welcomes this feedback and has revised the guidance to reinforce the objectives of this regulation, which is to enable HMCG to take SAR action more efficiently to support the deployment of the right resources to the right place to ensure the best possible outcome, as well as provide more details of the benefits of providing additional details.
As stated in 5.4a) above, prosecution would only be sought in the most egregious of circumstances and further detail has been provided in the guidance.
Q5
a) Does the updated MGN 665 (Amendment 1) meet your needs and provide enough information?
Summary of consultee views:
One respondent stated yes, 3 stated no and 3 provided no response or stated they did not know.
One respondent stated that the MGN did not state that a kayaker needed to register a PLB.
Other feedback wanted the MGN to acknowledge and provide guidance on the scenario where a holder may use a PLB on different UK registered vessels, changing frequently between vessels.
MCA response:
Feedback noted: the MCA will clarify that this does not apply to kayakers or paddle boarders. Text has been added that confirms that although this regulation is not applicable to non-motorised vessels, all owners of PLBs are encouraged to register their PLB.
As stated in 5.3 above, the MCA has amended guidance in response to feedback relating to PLBs being registered to an individual rather than a vessel.
b) Do you feel there is a better way of providing guidance in respect of the requirements in the proposed new regulations? Please provide reasoning for your answer.
Summary of consultee views:
6 respondents stated yes, one stated no. Suggestions included publicity campaigns, disseminating information and guidance to various stakeholder groups and adding QR codes to devices which link directly to on-line registration.
MCA response:
The MCA welcomed these suggestions and will look to take these forward.
Q6 Are you able to provide possible estimates of the costs of complying with the proposed new regulations?
Summary of consultee views:
5 respondents stated no, with one saying there were not costs for PLB holders; 2 did not answer.
MCA response:
No response as costs were not provided.
Q7
a) Do you consider the assessment of the financial impacts and costs of the changes to be accurate?
Summary of consultee views:
One respondent stated yes, 1 no, 2 did not respond, 2 provided other answers, which were that it would not encourage amateur sailors to buy PLBs and one respondent stated that there was not financial impact on individual PLB holders.
MCA response:
No response as insufficient information provided.
b) Are you, or do you know of, a small, medium and/or micro business(es) that will be disproportionally affected by any of the measures outlined?
Summary of consultee views:
2 responded yes, 2 responded no and 3 provided no answer.
There was concern that some small/micro organisations may struggle with online processes and may require assistance, so the offences and penalties proposed should be reviewed.
There was further concern that individual holders of PLBs who frequently change vessels due to the nature of their work would be disproportionately affected by the requirement to update ship details.
MCA response:
As stated above in section 5.4b), in circumstances where organisations may require assistance, minor omissions of registration would be supported by advice and education.
The MCA has amended guidance in response to feedback relating to PLBs being registered to an individual rather than a vessel.
c) Do you foresee any unintended consequences of the proposed new regulations that have not been mentioned in the consultation documents?
Summary of consultee views:
6 respondents said yes, and one said no. Again, there was concern that excessive penalties would have unintended consequences.
There was concern that the assumed mandatory requirement to enter ship details may result in individual holders not registering PLBs because they are not used on a single UK ship. The issue of registration for multiple vessels was also raised.
MCA response:
The inclusion of ship details is not mandatory, and this has now been clarified in the guidance. Points made relating to the penalties have been clarified in revised guidance.
More information is being provided about the objectives in terms of greater efficiency in SAR operations and also reducing false alerts. We are also trying to provide greater clarity surrounding responsibility for registration when PLBs are carried on board different vessels.
Q8 Do you have any additional comments to add to the response?
Summary of consultee views:
Some respondents supported the update to legislation to include PLBs but felt that was not new and there is already a requirement to register a PLB within the existing legislation. However, there are a similar number of views that registration of PLBs should not be mandatory.
There were further comments requesting the review of penalties as it was felt that these may dissuade individuals from using these devices.
Comments relating to the frequent transfer of PLBs to different vessels were also repeated.
MCA response:
There are differing opinions on whether the requirement to register PLBs is currently a requirement, so the MCA is making it clear that PLBs are included. However, a key objective of amending the legislation is to enable HMCG to take SAR action more efficiently support the deployment of the appropriate resources to the right place to ensure the best possible outcome.
Clarification regarding penalties and the frequent transfer of PLBs to different vessels have been covered in previous questions.
Section 5: Who Responded
Responses were received from the following:
- British Sub Aqua Club (BSAC)
- Cruising Association
- Two individual respondents
- National Federation of Fishermen’s Organisations (NFFO)
- Royal Yachting Association
- Scottish Fishermen’s Federation (SFF)
Section 6: Next Steps
To address the feedback received during the initial consultation, the MCA will undertake a shorter, second public consultation. This will run from 13 October to 7 November 2025. Following its conclusion, the MCA intends to make and lay the regulations in early 2026.
Original consultation
Summary
In accordance with international requirements, the MCA maintains an online portal for registration of UK coded 406 MHz EPIRBs and PLBs. This MSN explains all the registration requirements.
This consultation closesran atfrom
to
Consultation description
-
This consultation seeks your views on the draft of The Merchant Shipping (EPIRB and PLB Registration) (Radiocommunications) (Amendment) Regulations 2025 (“the new regulations”).
-
The new regulations have six aims. These are:
a. To update and replace the existing instrument: The Merchant Shipping (EPIRB Registration) Regulations 2000;
b. To reflect changes in technology and improve response timings by updating the registration requirements for EPIRBs (Emergency Position Indicating Radio Beacons);
c. To introduce the requirement to register PLBs (Personal Locator Beacons) used in the maritime environment;
d. To strengthen sanctions for breach of the registration requirements;
e. To introduce these changes for UK flagged ships and hovercraft (and include watercraft falling within the scope of the Merchant Shipping (Watercraft) Order 2023);
f. To make amendments to other Statutory Instruments.
Documents
ANNEX B - DRAFT - MSN 1924 (M+F) EPIRB and PLB registration requirements
PDF, 114 KB, 3 pages
ANNEX D - DRAFT - EPIRBs DMOA - BRU cleared
PDF, 313 KB, 14 pages
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Updates to this page
Published 5 December 2024
Last updated 1714 JanuaryOctober 2025
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Update history
2025-10-14 13:18
Public and Final feedback sections completed.
2025-01-17 16:00
Extended to 21st February
2024-12-05 09:00
First published.
This section is included under the ‘Public Feedback’ tab as a joint document.
Detail of feedback received
Section 1: Introduction
This consultation sought views on a new Statutory Instrument (SI), The Merchant Shipping (EPIRB and PLB Registration) (Radiocommunications) (Amendment) Regulations 2025 (“the new regulations”) which will amend EPIRB registration requirements to reflect changes in technology and introduce new PLB registration requirements for UK flagged ships, hovercraft and watercraft to enable His Majesty’s Coastguard (HMCG) to take Search and Rescue (SAR) action more efficiently.
These requirements derive from the UK’s obligations in international law and form an important part of the SAR framework to ensure that details held on the United Kingdom’s online registration platform are as accurate as possible for SAR purposes, meeting their underlying critical aim, the prevention of loss of life at sea.
The new regulations will revoke and replace The Merchant Shipping (EPIRB Registration) Regulations 2000 and also make various amendments to other SIs.
Section 2: Consultation
This consultation was published on www.gov.uk and notifications of the consultation were sent to more than 50 organisations, including shipping and marine industry companies, fishing and leisure craft organisations, equipment manufacturers, government departments and agencies, and other interested parties. A press notice was also issued, and the consultation was publicised on numerous social media platforms.
The consultation consisted of the proposed draft legislation, a De Minimis Options Assessment (DMOA), a Marine Guidance Note (MGN) and a Merchant Shipping Notice (MSN). The consultation was carried out from 5 December 2024 until 21 February 2025.
Consultees were invited to comment on any aspect of the consultation; but more specifically to respond to the consultation questions as outlined in Section 4 of this report.
A total of seven responses were received; not all respondents answered all the questions posed and some submitted additional comments. These have been fully considered. A list of respondents can be found in section 5 below. The MCA would like to thank individuals and organisations who submitted responses to this consultation.
Section 3: Key findings
The consultation highlighted a number of key areas which have led to further investigation and amendments where appropriate. The key points raised are detailed below:
Application of the Regulations:
Some respondents believed that these Regulations are applicable to paddle boarders and kayakers; however, this is not the case – they are applicable to UK flagged ships, hovercraft and watercraft. It is therefore evident that greater clarity is required in the guidance to ensure all stakeholders (including amateur sailors, divers, paddle boarders, and kayakers etc.) fully understand the scope of these regulations.
Consequently, the government has undertaken a thorough review and revision of both the MSN and MGN, taking into account feedback received, and will undertake another short consultation process, with the aim of ensuring that the guidance is sufficiently clear on the application of these regulations.
Offences and penalties:
There was some support for making the registration of EPIRBs and PLBs used in the maritime environment compulsory. Overall, however, most respondents felt that the proposed offences and penalties lacked proportionality and believed that non-registration of a PLB would result in either an immediate vessel detention or prison sentence. This is not the case, and it is clear that guidance needs to be more detailed to provide clarity.
The MCA, like any UK regulator in respect of each area of activities it oversees, must ensure that the maritime regulatory framework is capable of being enforced effectively. This derives from the UK’s obligations under international law, as well as domestic legal responsibilities.
Enforcement comprises a range of responses, which include prosecution or detention of a ship for breach of a prescribed requirement. However, the MCA must act reasonably, fairly and proportionately in exercising its enforcement functions. Therefore, prosecution would only be pursued in the more serious cases of breaches, and the maximum prescribed penalties would only be available to be imposed by the courts in the most exceptional/or egregious cases, e.g. where a failure or repeated failure to register a beacon is proven to have caused loss of life.
Registration of beacons:
From the responses received, it was clear that stakeholders were keen that PLBs should be registered to an individual rather than a ship – and that ship details should not be a mandatory element for PLB registration. Feedback also highlighted that where beacons are frequently transferred between ships in various scenarios, constantly updating registration details would be onerous and ultimately could dissuade users from registering beacons.
In response to this feedback, the MCA are now proposing that the responsibility for registering a PLB lies with the PLB owner. We intend to consult stakeholders further on this change.
For frequent transfers of PLBs from one United Kingdom ship or hovercraft, or watercraft, to another, registration of ship details is not mandatory. However, registering these details can assist search and rescue operations if needed.
Further information relating to the need for accurate and timely registration details has also been provided in the MGN, explaining how as many details as possible can support the reduction in the current high rate of false alerts (92%) in order to utilise search and rescue resources more efficiently, reduce the risk of life to everyone and how the availability of as much intelligence as possible supports the deployment of the right resources to the right place to ensure the best possible outcome.
Section 4: Consultation questions and answers
The MCA would like to thank the respondents for taking the time to read and respond to the consultation.
The consultation has provided useful feedback from a variety of sectors. The government has utilised this feedback to review and revise the statutory instrument and the associated guidance documents and will now be going out for a shorter second round of consultation.
The Response form was Section 5 of the Consultation Document. This section contains a full list of consultation questions, a summary of responses to those questions and the MCA’s response.
Q1 Do you agree that the MCA should make the registration of EPIRBs and PLBs used in the maritime environment compulsory?
Summary of consultee views:
There were 7 responses to this question: 3 were in favour and 3 against, one respondent gave a Yes and No answer. Some consultees supported the compulsory registration of EPIRBs but had concerns relating to the registration of PLBs, as proposed.
MCA response:
The MCA welcomes the feedback and has taken this into account in the review and revision of PLB registration, particularly in regard to the view that these should not necessarily be linked to a vessel, but to individuals. It is hoped that these revisions will make PLB registration less onerous to users. However, the MCA intends to proceed with making PLB registration requirements compulsory for UK flagged ships, hovercraft and watercraft.
Q2 Do you consider that you have received sufficient notification of the requirements with which you will have to comply?
Summary of consultee views:
There were 7 responses to this question – 3 stated yes and 4 stated no. Further communication was requested to ensure that stakeholders were fully aware of requirements. There were concerns from some that they had not heard about the consultation through official channels and that dialogue should have taken place with individual stakeholder groups.
One respondent also wanted to see a long grace period before making PLB registration mandatory and a PR campaign to inform PLB owners of the registration requirement.
MCA response:
Noting concerns relating to who the Regulations apply to, the guidance has been revised to provide further clarity.
The consultation was published on Gov.uk, through multiple social media channels at the time of launch, as well as being disseminated to numerous stakeholders, including individuals and groups. The number of stakeholders means that having dialogue with every individual/group is prohibitive in terms of resource - our usual approach is to undertake a consultation exercise to seek as many views as possible from as many stakeholders as possible and then utilise this to inform where clarification and or amendments may be required. Some more targeted consultation may then be considered, as well as further consultation to seek as many views as possible.
However, it is useful to understand where our dissemination did not reach the intended target audience/stakeholders. Due to the small number of responses received, we have taken the decision to review and revise documentation and go out to consultation again, taking further steps to ensure that the consultation opportunity is more widely received by stakeholders to ensure sufficient notification of the requirements.
As registration takes approximately 5 minutes, the MCA did not see the need for a grace period or lead-in time to implementation: however, as there will be a further round of consultation, it will be more than a year between initial notification of our intention to change the regulations and their implementation.
Q.3 Do you think that the proposed new regulations and accompanying Merchant Shipping Notice will implement the requirements of both EPIRB and PLB registration clearly and in a way which is effective?
Summary of consultee views:
All 7 respondees stated no. One respondent stated that the legislation was not clear as it suggested that the SI did not apply to a kayaker who has a PLB for personal use.
Some respondents supported the mandatory registration of EPIRBs and PLBs used on UK flagged vessels but felt that PLBs should be registered to an individual rather than to a vessel as proposed, so that registration details would not need to be updated when frequently transferring between vessels.
MCA response:
Greater clarity and information is needed in the guidance to ensure that stakeholders are clear about who these regulations apply to, whether they be amateur sailors, divers, paddle boarders, kayakers etc. It is correct that the legislation does not apply to kayakers but by not stating who the legislation does NOT apply to in the guidance, this has created some uncertainty.
Therefore, the MCA has clarified in the guidance that the requirements do not apply to certain apparatus not propelled by mechanical means, such as kayaks and paddleboards. Nevertheless, we would encourage anyone who is carrying out activities on water using such apparatus to register their 406 MHz PLBs as this would assist if rescue were to be required.
In response to concerns and feedback relating to PLBs being registered to an individual rather than a vessel, the MCA are now proposing that the responsibility for registering a PLB lies with the PLB owner. We intend to consult stakeholders further on this change.
Q4
a) Do you agree that the offences and penalties as set out in the proposed new regulations are necessary, fair and proportionate?
Summary of consultee views:
Overall, most (5/7) respondents felt that the proposed offences and penalties lacked proportionality and believed that a prison sentence would be immediately bestowed upon any-one not registering their PLB. One respondent wanted more rationale behind the penalties to facilitate understanding.
MCA response:
Further clarity and detail has been added to the guidance to explain that the MCA, like any UK regulatory in respect of each area of activities it oversees, must ensure that the maritime regulatory framework is capable of being enforced effectively. This derives from the UK’s obligations under international law, as well as domestic legal responsibilities.
Enforcement comprises a range of responses, which include prosecution or detention of a ship for breach of a prescribed requirement. However, the MCA must act reasonably, fairly and proportionately in exercising its enforcement functions.
Therefore, guidance has been revised to explain that prosecution would only be pursued in the more egregious cases of breaches, and the maximum prescribed penalties would only be available to be imposed by the courts in the most exceptional/or egregious cases, for example, where a failure to register a beacon is proven to have caused loss of life.
b) Is there a way that the penalties can be more effective?
Summary of consultee views:
Two respondents stated yes, two responded no and 3 did not provide a response.
One respondent felt that it would be beneficial to implement a period of education during the early implementation of the legislation to ensure that minor omissions of registration could be supported by advice and education rather than a formal penalty.
MCA response:
Providing more clarity on proportionality and consideration/application of penalties may help consultees assess their effectiveness.
The MCA agree that omissions of registration would be supported by advice and education prior to consideration of any detention/penalty. The MCA will also be publicising the requirements prior to implementation.
c) Do you feel that the proposed penalties will act as an effective deterrent for non-compliance with the requirements of the proposed new regulations?
Summary of consultee views:
One respondent stated yes, five stated no and one stated yes and no. One respondent felt that as long as the registration remained at no charge, then safety conscious individuals and boat operators would recognise the benefits of registration and how it would enhance the chances of them being located in a search and rescue situation.
Other respondents felt that the penalties were disproportionate, so this would deter owners from registration.
MCA response:
The MCA welcomes this feedback and has revised the guidance to reinforce the objectives of this regulation, which is to enable HMCG to take SAR action more efficiently to support the deployment of the right resources to the right place to ensure the best possible outcome, as well as provide more details of the benefits of providing additional details.
As stated in 5.4a) above, prosecution would only be sought in the most egregious of circumstances and further detail has been provided in the guidance.
Q5
a) Does the updated MGN 665 (Amendment 1) meet your needs and provide enough information?
Summary of consultee views:
One respondent stated yes, 3 stated no and 3 provided no response or stated they did not know.
One respondent stated that the MGN did not state that a kayaker needed to register a PLB.
Other feedback wanted the MGN to acknowledge and provide guidance on the scenario where a holder may use a PLB on different UK registered vessels, changing frequently between vessels.
MCA response:
Feedback noted: the MCA will clarify that this does not apply to kayakers or paddle boarders. Text has been added that confirms that although this regulation is not applicable to non-motorised vessels, all owners of PLBs are encouraged to register their PLB.
As stated in 5.3 above, the MCA has amended guidance in response to feedback relating to PLBs being registered to an individual rather than a vessel.
b) Do you feel there is a better way of providing guidance in respect of the requirements in the proposed new regulations? Please provide reasoning for your answer.
Summary of consultee views:
6 respondents stated yes, one stated no. Suggestions included publicity campaigns, disseminating information and guidance to various stakeholder groups and adding QR codes to devices which link directly to on-line registration.
MCA response:
The MCA welcomed these suggestions and will look to take these forward.
Q6 Are you able to provide possible estimates of the costs of complying with the proposed new regulations?
Summary of consultee views:
5 respondents stated no, with one saying there were not costs for PLB holders; 2 did not answer.
MCA response:
No response as costs were not provided.
Q7
a) Do you consider the assessment of the financial impacts and costs of the changes to be accurate?
Summary of consultee views:
One respondent stated yes, 1 no, 2 did not respond, 2 provided other answers, which were that it would not encourage amateur sailors to buy PLBs and one respondent stated that there was not financial impact on individual PLB holders.
MCA response:
No response as insufficient information provided.
b) Are you, or do you know of, a small, medium and/or micro business(es) that will be disproportionally affected by any of the measures outlined?
Summary of consultee views:
2 responded yes, 2 responded no and 3 provided no answer.
There was concern that some small/micro organisations may struggle with online processes and may require assistance, so the offences and penalties proposed should be reviewed.
There was further concern that individual holders of PLBs who frequently change vessels due to the nature of their work would be disproportionately affected by the requirement to update ship details.
MCA response:
As stated above in section 5.4b), in circumstances where organisations may require assistance, minor omissions of registration would be supported by advice and education.
The MCA has amended guidance in response to feedback relating to PLBs being registered to an individual rather than a vessel.
c) Do you foresee any unintended consequences of the proposed new regulations that have not been mentioned in the consultation documents?
Summary of consultee views:
6 respondents said yes, and one said no. Again, there was concern that excessive penalties would have unintended consequences.
There was concern that the assumed mandatory requirement to enter ship details may result in individual holders not registering PLBs because they are not used on a single UK ship. The issue of registration for multiple vessels was also raised.
MCA response:
The inclusion of ship details is not mandatory, and this has now been clarified in the guidance. Points made relating to the penalties have been clarified in revised guidance.
More information is being provided about the objectives in terms of greater efficiency in SAR operations and also reducing false alerts. We are also trying to provide greater clarity surrounding responsibility for registration when PLBs are carried on board different vessels.
Q8 Do you have any additional comments to add to the response?
Summary of consultee views:
Some respondents supported the update to legislation to include PLBs but felt that was not new and there is already a requirement to register a PLB within the existing legislation. However, there are a similar number of views that registration of PLBs should not be mandatory.
There were further comments requesting the review of penalties as it was felt that these may dissuade individuals from using these devices.
Comments relating to the frequent transfer of PLBs to different vessels were also repeated.
MCA response:
There are differing opinions on whether the requirement to register PLBs is currently a requirement, so the MCA is making it clear that PLBs are included. However, a key objective of amending the legislation is to enable HMCG to take SAR action more efficiently support the deployment of the appropriate resources to the right place to ensure the best possible outcome.
Clarification regarding penalties and the frequent transfer of PLBs to different vessels have been covered in previous questions.
Section 5: Who Responded
Responses were received from the following:
- British Sub Aqua Club (BSAC)
- Cruising Association
- Two individual respondents
- National Federation of Fishermen’s Organisations (NFFO)
- Royal Yachting Association
- Scottish Fishermen’s Federation (SFF)
Section 6: Next Steps
To address the feedback received during the initial consultation, the MCA will undertake a shorter, second public consultation. This will run from 13 October to 7 November 2025. Following its conclusion, the MCA intends to make and lay the regulations in early 2026.
Original consultation
Summary
In accordance with international requirements, the MCA maintains an online portal for registration of UK coded 406 MHz EPIRBs and PLBs. This MSN explains all the registration requirements.
This consultation closesran atfrom
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Consultation description
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This consultation seeks your views on the draft of The Merchant Shipping (EPIRB and PLB Registration) (Radiocommunications) (Amendment) Regulations 2025 (“the new regulations”).
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The new regulations have six aims. These are:
a. To update and replace the existing instrument: The Merchant Shipping (EPIRB Registration) Regulations 2000;
b. To reflect changes in technology and improve response timings by updating the registration requirements for EPIRBs (Emergency Position Indicating Radio Beacons);
c. To introduce the requirement to register PLBs (Personal Locator Beacons) used in the maritime environment;
d. To strengthen sanctions for breach of the registration requirements;
e. To introduce these changes for UK flagged ships and hovercraft (and include watercraft falling within the scope of the Merchant Shipping (Watercraft) Order 2023);
f. To make amendments to other Statutory Instruments.
Documents
ANNEX B - DRAFT - MSN 1924 (M+F) EPIRB and PLB registration requirements
PDF, 114 KB, 3 pages
ANNEX D - DRAFT - EPIRBs DMOA - BRU cleared
PDF, 313 KB, 14 pages
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Extended to 21st February
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Update history
2025-10-14 13:18
Public and Final feedback sections completed.
2025-01-17 16:00
Extended to 21st February
2024-12-05 09:00
First published.