MEETING 9th December 1830 hrs DBYC
The board of SFTD today sets out the regulatory developments since our May Operational update. These changes impact on every member and therefore we ask that as many of you as possible attend the above meeting.
What Has Changed
When we issued the Operational Update and Skipper Development Factsheet on 21 May 2025, we anticipated UK regulatory change within 12–24 months. That change came faster than expected. The Merchant Shipping (Vessels in Commercial Use for Sport or Pleasure) Regulations 2025 and accompanying Code comes into force on 12 December 2025.
The Code confirms what the MAIB recommended: charities taking vulnerable participants sailing are engaged in commercial-equivalent activity and cannot rely on the pleasure vessel exemption. The Code now requires coding, commercially endorsed skippers, and a documented Safety Management System for such operations.
Our Jurisdictional Position
The Code explicitly excludes the Isle of Man from its definition of “UK.” SFTD operating POM3 from Douglas in Manx waters is not legally bound by the Code.
However, this does not change our exposure to civil liability. An Isle of Man court would admit UK standards as evidence of best practice. The LimbItless report and the 2025 Code set the benchmark against which a “reasonable operator” would be judged. Our position in May was correct: we must meet these standards voluntarily because it is the right thing to do, and because failing to do so is indefensible if something goes wrong.
What the May Update Got Right
The Board’s decision in May to implement immediate operational restrictions, mandate recovery-from-water training, and launch the Skipper Development Programme was exactly the right response. We acted before the regulation arrived. The planned meeting on 9th December will be an opportunity to tell members that the regulatory change we anticipated has now happened, and that SFTD was ahead of it.
What Remains Outstanding
Two gaps need to be addressed:
First, vessel standards for POM3. The May update addressed skipper qualifications, training, and operational limits. It committed to being commercially coded. Yesterday the board approved the commission of an independent survey of POM3 against UK 2025 Code standards. And to then update the vessel accordingly. Without this, we have qualified skippers and good procedures on a vessel that has never been independently verified. On this basis it was agreed that POM3 should not carry vulnerable participants until the independent survey and necessary rectifications have been carried out.
Second, UK port calls. Now the Code is in force, any voyage outside Manx waters “passengers” aboard would require full compliance coded vessel, commercially endorsed skipper, SMS. Until we have that capability such voyages should be formally suspended.
What We will be Communicating on 9th December 1830 @ Douglas Bay Yacht Club-
- Validation: The UK regulatory change we anticipated in May has now occurred. The Board’s proactive response means SFTD is not scrambling we are six months into a structured transition.
- Progress: Report on skipper qualifications obtained or in progress.
- POM4 update: Our current thinking in relation to a new vessel.
- POM3 vessel survey: Announce intention to commission an independent survey to Code-equivalent standards, closing the vessel gap.
- UK voyages: Confirm suspension of beneficiary voyages to UK ports until compliance capability exists.
- Timeline: Discuss our view on timelines of the above.
Tuesday 9th December 1830hrs Douglas Bay Yacht Club.
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