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The ISM Code, ISPS, MLC, and AMSA's safety management requirements were written for the commercial shipping industry. If you're running Kimberley cruises, Fiordland expeditions, or island discovery voyages, you need compliance that's right-sized, practical, and won't drown your operation in paperwork. That's what we do.
Small ship expedition and luxury cruise operations are growing rapidly across both Australia and New Zealand — from the Kimberley Coast and Top End to Fiordland, the Marlborough Sounds, and the Bay of Islands. Darwin is establishing itself as a gateway for vessels exploring the Top End, Arnhem Land, and the Indonesian archipelago. Tasmania's wild coastline and remote anchorages are attracting boutique operators. New Zealand's Fiordland, Sounds, and offshore islands are seeing increasing interest from both domestic and internationally flagged expedition vessels.
Most of these operators are founder-led, operationally excellent — and navigating maritime compliance for the first time. We work with operators at every stage: start-up, pre-launch, and established operators reviewing their compliance frameworks as routes or flag states change.
These are the most common questions we hear from new small cruise operators — and the honest answer is: it depends on your vessel's size, flag, and routes. Here's the practical picture.
Under AMSA's National Law, domestic passenger vessels do not fall under the ISM Code — but they do require a Marine Safety Management System (MSMS), which is AMSA's equivalent. This must be properly documented, implemented, and surveyed. If your vessel operates only in Australian domestic waters, the ISM Code does not apply — but you still need a functioning safety management system that AMSA can assess.
The moment your vessel moves into international trade — PNG, Indonesia, Timor-Leste — ISM, ISPS, and MLC compliance requirements come into play, depending on your vessel's gross tonnage and passenger numbers. This is the threshold many growing Kimberley and Top End operators are approaching. Getting the framework right before you cross that line is far easier than retrofitting it afterwards.
A Designated Person Ashore (DPA) is required under the ISM Code — a shore-side point of contact who has direct access to senior management and can be reached at all times when the vessel is operating. For small operators, appointing an external contracted DPA is a practical, cost-effective solution that satisfies the requirement without adding a full-time shore-based role.
A Safety Management System (SMS) is the documented framework covering how your vessel operates safely — emergency procedures, crew responsibilities, maintenance, reporting, and more. For a 30-person expedition vessel, a well-written SMS is not the same thing as the one a 300-metre bulk carrier needs. We can assist operators in developing right-sized, practical SMS frameworks that your crew will actually use — not a shelf full of binders nobody reads.
The Maritime Labour Convention (MLC 2006) formally applies to vessels over 500GT on international voyages — but the principles of good crew welfare practice apply regardless. For small vessel operators hiring permanent crew, having a clear employment framework, documented hours of rest, and onboard welfare provisions is both good practice and increasingly expected by crew in this market.
The ISPS Code applies to passenger vessels on international voyages. If you are calling at international ports — Port Moresby, Bali, Kupang, Dili — you will need a Ship Security Plan, a designated Company Security Officer, and ISPS-compliant procedures. We can assist with CSO services and Ship Security Plan guidance for small operators entering international trade.
Listed from north to south and west to east — the regions where we have direct operational experience and active client interest.
Komodo, Raja Ampat, Banda Sea, Spice Islands, and the broader Indonesian archipelago. A growing number of Australian-based operators are extending into Indonesian waters. Requires careful compliance planning before departure including flag state obligations and Indonesian port state requirements.
Darwin is rapidly establishing itself as Australia's northern expedition hub — operators exploring the Top End, Kakadu waterways, Cobourg Peninsula, and Arnhem Land, and positioning Darwin as the gateway to Indonesia and Timor-Leste. AMSA compliance requirements apply from day one of domestic commercial operation.
One of Australia's fastest-growing small ship cruise destinations. Vessels operating through the Buccaneer Archipelago, Montgomery Reef, and Collier Bay out of Broome or Darwin. Remote operations, limited port infrastructure, and high environmental sensitivity make a robust SMS and DPA arrangement essential.
Papua New Guinea's coastline, island groups, and Coral Triangle waters attract expedition operators from both Australia and internationally. PNG crossing operations require full ISM/ISPS/MLC compliance and a functioning DPA arrangement. AMSA and PNG port state control are both active in this corridor.
Small luxury liveaboard and expedition operators in the Whitsundays, Coral Sea, and outer GBR — serving dive, wildlife, and nature tourism markets. AMSA National Law compliance applies to all domestic commercial operations. Strong port state control presence for vessels in this zone.
Tasmania's wild southwest, Huon Valley, Macquarie Harbour, and remote anchoring grounds are attracting boutique small ship operators. Wilderness cruising, island exploration, and fly-cruise itineraries are establishing a genuine market here. AMSA DCV requirements apply for domestic commercial operations.
New Zealand's Bay of Islands and Northland are a natural fit for small cruise and charter operations — historically significant, scenically outstanding, and an established market for nature and wildlife voyages. A frequent first port of call for international expedition vessels arriving in New Zealand. Maritime NZ requirements apply from first commercial port call.
Auckland's Hauraki Gulf and the Coromandel Peninsula offer protected cruising grounds with strong domestic demand for small ship experiences. Tauranga and the Bay of Plenty are growing as commercial cruise hubs. Maritime NZ MOSS compliance applies for all NZ domestic commercial vessels in these waters.
The Marlborough Sounds and Queen Charlotte Sound support a growing small ship and boutique cruise market — wine, wildlife, and wilderness itineraries. Maritime NZ compliance requirements apply throughout.
New Zealand's Fiordland, Doubtful Sound, Dusky Sound, and Stewart Island attract both domestic and international expedition operators. Remote, weather-dependent operations with limited port infrastructure and no mobile coverage — where a robust SMS and accessible DPA are critical, not optional. Maritime NZ requirements and DOC concession compliance both apply.
French Polynesia (Papeete, Bora Bora, Marquesas), Cook Islands, Fiji, Vanuatu, and New Caledonia — vessels completing Pacific circuits between Australia, New Zealand, and the islands. Remote desktop compliance support and DPA coverage throughout. Onboard attendance for vessels in these waters subject to applicable entry requirements.
Operating in a remote area not listed here? We work with operators across the full range of Australian and New Zealand coastal and island waters, and throughout the broader South Pacific. Get in touch to discuss your specific itinerary and what compliance applies.
The ISM Code and maritime compliance frameworks were designed for commercial shipping — and most compliance consultants come from that background. Our founding principal, Craig Hopkins, spent two decades in command on commercially operated vessels in precisely the types of waters where small expedition and luxury cruise operators work: island groups, remote anchorages, weather-dependent itineraries, and flag states that require careful management.
That means when we assist with or audit your SMS, we are drawing on genuine operational experience — not a theoretical framework designed for a container ship. We know what a realistic emergency muster looks like on a 40-passenger expedition vessel. We know what crew welfare looks like on a month-long remote itinerary. We can assist in building compliance frameworks that actually work at sea, not just on paper.
A straightforward assessment of your vessel's compliance obligations based on its flag, size, passenger numbers, and intended routes. We tell you what you need, what you don't, and what the sequence should be — without upselling unnecessary complexity.
For operators with an existing Safety Management System, we conduct a gap analysis against the applicable requirements — identifying what's missing or needs updating before AMSA or a flag state surveyor arrives.
Internal audit services →Contracted DPA services for operators whose vessel requires a DPA under ISM — including out-of-hours cover for remote itinerary operations where your vessel may be unreachable by a European-based management team.
DPA services →CSO appointment and Ship Security Plan assistance for operators entering international trade — particularly relevant for vessels crossing to PNG, Indonesia, or Timor-Leste where ISPS compliance is required at port.
CSO services →Book a free 15-minute call. We'll tell you straight what you need and what you don't — no jargon, no upsell.