Maritime Legal Update
– April 2026
IGC Code Amendments –
Korean Register impact assessment and implications for LNG/LPG shipping and
shipbuilding contracts
(prepared by Marek Czernis & Co. Law
Office)
Firm note – project
and contractual advisory
The Law Office is actively advising shipowners,
shipyards, charterers and financiers on the implications of the upcoming IGC
Code amendments, particularly in relation to: shipbuilding contract risk
allocation, regulatory change clauses, design modifications and compliance,
project timelines and financing considerations.
1. Introduction – IGC
Code revision
Korean Register (KR) has published an impact
assessment of the upcoming amendments to the IGC Code, reflecting IMO’s ongoing
work since 2022 under the CCC Sub-Committee.
The amendments are expected to: be approved at
MSC 111 (May 2026), adopted in December 2026, enter into force on 1 July 2028.
2. Market scale
According to Clarksons: approx. 2,600 LNG/LPG vessels are in operation, approx.
650 vessels are on order.
This highlights the significant industry-wide
impact.
3. Implementation
challenge – 18 months
The 18-month period between adoption and
entry into force creates significant risks: design changes, procurement delays,
project disruption.
4. Key issue – keel
laying vs contract date
The amendments use keel laying
date instead of building contract date.
This may result in: different regulatory
regimes within one project, inconsistent compliance requirements across sister
vessels.
5. Industry response
KR: identified 97 amendment items, conducted
impact analysis, issued technical guidance, submitted proposals to IMO to
address interpretational issues.
6. Proposed solution
KR and industry stakeholders propose shifting
applicability back to:
building contract date
to ensure consistency and avoid disruption.
7. Contractual
implications
Key risks include: change in law exposure,
redesign obligations, delivery delays and claims.
8. Conclusion
The IGC Code amendments represent a major
regulatory shift for LNG/LPG shipping.
Stakeholders must proactively address
contractual, technical and financial implications.
The Law Office continues to actively support
clients in navigating these changes.
Final note – our
publications
Further insights are available at:
https://czernis.pl
https://www.linkedin.com/company/czernis