Insurance is one of the essential quiet enablers of autonomous shipping and MASS operations. Without credible, scalable products and clear pathways to cover, capital will hesitate, counterparties will build in risk premiums, and projects will stall. It’s why, at our MASS@Moorgate event each year, insurance remains one of the most discussed—and most frequently misunderstood—topics. Too often it’s addressed late, or assumed to “follow the tech”, whereas in reality insurability should be one of the first questions asked to shape financing, contracting and operations.
This matters even more as USVs scale in size, cost and power. With larger assets and more complex operational envelopes, the probability and impact of incidents will rise. That makes the availability, scope and limits of cover a critical issue for growth. Owners and operators need certainty that third party liabilities will sit within the familiar mutual P&I framework, and clarity on what falls outside that coverage—such as land side ROC exposures and first party cyber/property risks.
Against that backdrop, the International Group of P&I Clubs has confirmed that liabilities arising from Maritime Autonomous Surface Ships are now eligible for pooling across all levels of autonomy, including fully unmanned vessels. While individual Club underwriting will remain case by case and compliance with flag/class/safety requirements will be key, this is a significant step. It aligns MASS with established mutual P&I principles and high limits, and provides the market signal the sector needs to support continued investment and safe deployment at scale.
What the IG announcement does
The International Group has confirmed that third party liabilities arising from MASS can be covered within its pooling arrangements, subject to Club Rules and underwriting. This follows the IMO’s approval of the MASS Code (mandatory enforcement is slated for January 1, 2032) and reflects the Group’s approach of adapting established mutual P&I principles to new technologies. In practical terms, autonomous vessels can now access the Group’s high limit mutual framework, provided the operation meets the usual standards around flag, class and safety.
What is—and is not—within P&I for MASS
On water third party liabilities remain within mutual P&I, as they do for conventionally manned ships. If a collision, pollution or cargo incident occurs, those liabilities are expected to be treated in the normal way—even where the proximate cause is a system error or a human error at a Remote Operations Centre directing the vessel. The shift from bridge to shore does not alter the basic allocation of third party risk within P&I.
By contrast, a ROC is a land side workplace and its liabilities are not marine P&I risks. Its staff are not “seafarers” for P&I purposes. Employers’ liability and public/occupiers’ liability should respond to workplace injuries and third party claims at the ROC, while property and business interruption cover should respond to damage to the ROC and its IT infrastructure. Hull and machinery continues to respond to damage to the vessel itself, and technology/product E&O policies should address vendor side exposures.
On cyber, the position is two fold. Malicious cyber incidents that lead to third party liabilities—such as a cyber induced navigational error resulting in a collision—are typically dealt with under mutual P&I in line with current Group practice, subject to the Rules and exclusions. First party cyber losses, such as systems damage, data loss or business interruption, are not P&I risks and should be insured under dedicated cyber policies. Given the digital dependency of MASS, Clubs will rightly scrutinise cyber resilience and incident response. War and terrorism remain excluded under the standard P&I war exclusions and require separate arrangements.
Operating a vessel remotely does not of itself make it a “specialist operation” for the purposes of mutual P&I. The specialist operations exclusion only applies where the vessel is actually performing a listed specialist activity (for example dredging, cable laying or similar operations identified in the Club Rules). Where such activities are undertaken, owners should expect the usual specialist operations carve outs to apply and arrange appropriate extensions or alternative covers as needed.
Not “plug and play”: underwriting will remain bespoke
Pooling eligibility does not mean “plug and play” cover is now available. P&I Clubs will assess entries on case by case approach. In our experience, we anticipate all of the below issues will be assessed by underwriters:
- Compliance: flag/class approvals, MASS Code certification (even where not mandatory), and any local regulatory requirements.
- ConOps and Operational Design Domain (ODD): clarity of the intended operational envelope, fallback states and contingency plans.
- ROC governance: location, staffing, training/competence, 24/7 coverage, escalation protocols.
- Safety management: SMS adaptations for remote/autonomous operations, surveys/certification (MASS Safety Certificate; MASS ROC Certificate), drills.
- Testing and validation: trials data, HIL/SIL evidence, robust change management.
- Security/data: cyber risk management (per IMO cyber guidance and MASS Code Chapters 9/10/13), data logging, integrity and retention protocols.
Given the number of issues, early engagement with your P&I Club and materially transparent documentation will be critical.
Paul Grehan, Autonomous Vessel Committee Representative, also gives a useful summary of the announcement in this video P&I cover for autonomous vessels.
Emphasising the importance of this announcement, Gard, a leading provider of protection & indemnity (P&I), marine and energy insurance and member of International Group of P&I Clubs confirmed "It's great that we can offer the exact same scope and limit of cover to Members operating remotely operated ships as we do for those operating traditionally manned vessels".
Conclusion
This is a major step forward for the sector. The IG’s pooling confirmation gives owners, operators and financiers a clearer runway to scale, while preserving the discipline of case by case underwriting. The message is clear: if you can demonstrate compliance, governance and control aligned with the IMO approved MASS Code and Club expectations, the mutual P&I model can and will respond to autonomous operations. Just as importantly, the clarifications on what sits within mutual P&I and what sits outside it bring welcome simplicity and continuity for market participants already familiar with P&I from a traditional maritime perspective—a pragmatic approach that is to be commended.
Our MASS team combines insurance coverage expertise with hands on USV project experience. Our team advises underwriters and assureds on policy wording, coverage and interface issues for MASS, and works with owners and operators to translate those requirements into practice—aligning charters and compliance packs so that operations are insurable and gaps between P&I, H&M, cyber and land side policies are avoided.
