What is the International Maritime Organization’s MSC-FAL.1/Circ.3/Rev.2 Guidelines on Maritime Cyber Risk Management?

In response to the growing cyber threats targeting the maritime industry, the International Maritime Organization (IMO) issued the MSC-FAL.1/Circ.3/Rev.2 Guidelines on Maritime Cyber Risk Management. These guidelines, developed jointly by the Maritime Safety Committee (MSC) and the Facilitation Committee (FAL), aim to provide practical advice for implementing effective cyber risk management strategies within the shipping industry.

This article explains the purpose, scope, and key recommendations of the MSC-FAL.1/Circ.3/Rev.2 guidelines, as well as their importance for improving maritime cybersecurity and ensuring compliance with related regulatory frameworks like Resolution MSC.428(98).

1. What are the MSC-FAL.1/Circ.3/Rev.2 Guidelines?

The MSC-FAL.1/Circ.3/Rev.2 Guidelines provide a structured framework for managing cyber risks in maritime operations. Recognising that modern ships and port facilities rely heavily on interconnected digital technologies, the guidelines outline best practices to help stakeholders mitigate the risks associated with cyberattacks, system failures, and data breaches.

These guidelines apply to all entities involved in maritime operations, including:

• Shipowners and operators.

• Shipping companies.

• Port authorities and terminal operators.

• Service providers and suppliers.

The guidelines are not legally binding but serve as a critical reference for implementing Resolution MSC.428(98), which mandates that cyber risk management be integrated into the International Safety Management (ISM) Code by 1 January 2021.

2. Why Were These Guidelines Issued?

The shipping industry has become increasingly reliant on digital technology to improve efficiency, safety, and communication. However, this digital transformation has introduced significant cybersecurity risks, including:

• Cyberattacks: Hackers targeting ship navigation, cargo handling, or communications systems.

• Ransomware: Malicious software encrypting critical data and demanding payment for decryption.

• Data breaches: Unauthorised access to sensitive information, such as crew and cargo details.

• Operational disruptions: System failures impacting cargo logistics, vessel tracking, and port operations.

High-profile incidents like the NotPetya ransomware attack, which disrupted global shipping operations in 2017, demonstrated the urgent need for enhanced cybersecurity measures. The IMO guidelines aim to help maritime stakeholders proactively manage these risks and prevent future incidents.

3. Scope of the Guidelines

The MSC-FAL.1/Circ.3/Rev.2 guidelines cover a wide range of cyber risks affecting both Information Technology (IT) and Operational Technology (OT) in the maritime sector. IT systems handle business and administrative functions, while OT systems control physical processes, such as engine operations, navigation, and cargo handling.

The guidelines address the following areas:

• Cyber Risk Identification: Understanding the assets, threats, and vulnerabilities specific to maritime operations.

• Risk Assessment and Mitigation: Applying a risk-based approach to prioritise and implement security measures.

• Incident Response and Recovery: Establishing procedures to detect, respond to, and recover from cyber incidents.

• Training and Awareness: Ensuring that crew members and staff are aware of cyber risks and follow secure practices.

• Continuous Improvement: Regularly updating risk management strategies to address evolving threats and vulnerabilities.

4. Key Recommendations of the Guidelines

The MSC-FAL.1/Circ.3/Rev.2 guidelines provide detailed recommendations for managing maritime cyber risks. These recommendations are designed to be adaptable to different types of organisations and operational environments.

4.1. Establish a Cyber Risk Management Framework

Organisations should develop a comprehensive framework for managing cyber risks. This framework should include:

• Policies and Procedures: Define clear policies for handling cyber risks and ensure they are integrated into the overall safety management system.

• Roles and Responsibilities: Assign responsibilities for cybersecurity to specific individuals or teams within the organisation.

• Asset Inventory: Identify critical IT and OT assets that require protection.

4.2. Perform Cyber Risk Assessments

Risk assessments are essential for identifying potential threats and vulnerabilities. Organisations should:

• Identify Threats: Assess both external (e.g., hackers, malware) and internal (e.g., human error, insider threats) risks.

• Evaluate Vulnerabilities: Identify weaknesses in system configurations, software, and access controls.

• Determine Impact: Assess the potential consequences of cyber incidents, such as loss of control over navigation or cargo handling systems.

Based on the assessment, organisations should prioritise risks and implement appropriate mitigation measures.

4.3. Implement Technical and Organisational Measures

To mitigate cyber risks, organisations should deploy a combination of technical controls and organisational practices, such as:

• Network Security: Use firewalls, intrusion detection systems, and network segmentation to protect critical systems.

• Access Control: Limit access to sensitive systems and data based on roles and responsibilities.

• Data Protection: Encrypt data in transit and at rest to prevent unauthorised access or tampering.

• Patch Management: Regularly update software to address known vulnerabilities.

Organisations should also establish a cybersecurity incident response plan to ensure that incidents are quickly detected, contained, and resolved.

4.4. Conduct Cybersecurity Training and Awareness

Human error is a significant factor in many cyber incidents. To reduce this risk, organisations should provide regular cybersecurity training to all employees, including:

• Crew Members: Educate crew on secure practices for using onboard systems, such as navigation and communication equipment.

• Office Staff: Train employees to recognise and avoid phishing attacks, suspicious emails, and other social engineering tactics.

• Third-Party Contractors: Ensure that vendors and contractors understand and comply with the organisation’s cybersecurity policies.

Building a culture of cybersecurity awareness helps prevent both accidental and intentional security breaches.

4.5. Monitor and Audit Cybersecurity Measures

Cyber risk management is an ongoing process. Organisations should:

• Monitor Systems: Implement tools to continuously monitor IT and OT systems for suspicious activity.

• Conduct Regular Audits: Periodically evaluate the effectiveness of security controls and compliance with policies.

• Update Risk Assessments: Reassess risks whenever there are changes to technology, operations, or the threat landscape.

Continuous monitoring and improvement enable organisations to stay ahead of emerging threats and vulnerabilities.

5. Relationship with Resolution MSC.428(98)

The MSC-FAL.1/Circ.3/Rev.2 guidelines are closely aligned with Resolution MSC.428(98), which requires that cyber risk management be incorporated into the ISM Code. By following the guidelines, maritime organisations can demonstrate compliance with the resolution and ensure that cybersecurity is integrated into their safety management systems.

The guidelines also support compliance with other regulatory frameworks, such as the General Data Protection Regulation (GDPR) and the NIS2 Directive, which impose additional requirements for data protection and critical infrastructure security.

6. Benefits of Implementing the Guidelines

Implementing the MSC-FAL.1/Circ.3/Rev.2 guidelines offers several benefits for maritime organisations:

6.1. Enhanced Cybersecurity Resilience

By adopting a risk-based approach to cybersecurity, organisations can reduce the likelihood and impact of cyber incidents. Effective risk management helps protect critical systems, data, and operations from cyber threats.

6.2. Improved Safety and Operational Continuity

Cyber incidents can disrupt navigation, cargo handling, and other essential operations, posing risks to crew safety and business continuity. Implementing the guidelines ensures that organisations are prepared to detect and respond to incidents quickly, minimising downtime and operational impact.

6.3. Regulatory Compliance

Adhering to the guidelines helps organisations comply with international and regional cybersecurity regulations, reducing the risk of penalties, detentions, and reputational damage.

6.4. Increased Stakeholder Trust

Demonstrating a commitment to cybersecurity can enhance trust with stakeholders, including regulators, customers, and business partners. Organisations that prioritise cybersecurity are better positioned to compete in a security-conscious industry.

7. Conclusion

The IMO’s MSC-FAL.1/Circ.3/Rev.2 Guidelines on Maritime Cyber Risk Management provide a practical framework for managing cyber risks in the maritime sector. By following these guidelines, organisations can strengthen their cybersecurity posture, enhance operational resilience, and ensure compliance with regulatory requirements. In an era of increasing cyber threats, proactive cyber risk management is essential for maintaining safety, security, and business continuity in maritime operations.

For expert guidance on implementing maritime cybersecurity measures, risk assessments, or compliance with IMO regulations, contact our cybersecurity specialists today.