The use of open registers by shipping companies is receiving additional focus at present, in part due to the launch of an inquiry last year by the U.S. Federal Maritime Commission (FMC) into so-called “flags of convenience”.

ICS has submitted detailed evidence to the FMC, including its annual Flag State Performance Table, strongly making the point that ‘flags of convenience’ is a pejorative term, not recognised by the global shipping industry or by the United Nations agencies which regulate it.

ICS fully supports all efforts to discourage the use of any flag State Administration that fails to meet its international obligations. But it’s important to distinguish between outliers with which only a small number of ships may be registered and the vast majority of flag states, including the large open registers responsible for the majority of the global fleet, which continue to demonstrate a very high level of performance,

The latest iteration of the  ICS Flag State Performance Table, which came out last week, provides shipowners with a snapshot of whether those flag State administrations which they chose to use have substance and are meeting their international obligations.  The table covers important issues such as the enforcement of international regulations governing safety, environment protection and seafarers’ working conditions.

The latest update confirms that the vast majority of the commercial fleet is registered with flag state administrations which continue to demonstrate very high levels of performance, based on data, published by external sources, such as Port State Control inspection records.

In today’s global economy, and especially in an industry as inherently global as shipping, there is nothing untoward about the concept of open registers, whereby the flag a ships flies may be different to the country of beneficial ownership.

The notion that developing countries, such as Bahamas, Liberia and the Marshall Islands oversee the enforcement of the very highest standards on board those ships for which are responsible might seem surprising to some. But this is demonstrated by the ICS Table as an incontrovertible fact. Arbitrary distinctions between so-called traditional or national flags and open registers are no longer meaningful when seeking to assess their quality.

The situation today is very different to that which prevailed in the 1990s when serious concerns existed about the growth of open registers, which are now responsible for the majority of the world fleet. This is due to developments such as the IMO Member State Audit Scheme and, as a vital adjunct to flag state inspections, the increasing sophistication of Port State Control regimes globally which now aggressively target any ship which calls at a foreign port if it flies the flag of a country whose levels of performance may be subject to legitimate scrutiny.

In 2015, Koji Sekimizu, then the IMO Secretary-General, famously said “We have moved beyond flags of convenience… they have become international registries with international responsibilities”. Indeed, the latest version ICS Table reaffirms that open registers are now amongst the highest performing flag States.

The ICS Flag State Report 2025-2026 can be downloaded from the ICS website along with a range of other publications available for free download or purchase.