- CORE REGULATORY FRAMEWORK
International Liability & Pollution Protection Framework
The Comoros Maritime Administration applies internationally recognized conventions governing civil liability for oil pollution and bunker oil pollution damage. These frameworks ensure that shipowners maintain adequate financial security to cover liabilities arising from pollution incidents, protecting coastal states, the marine environment, and third parties.
Compliance is assessed in accordance with the relevant IMO conventions and national implementing legislation.
COMPLIANCE & INTERNATIONAL STANDARDS
Civil Liability Convention (CLC 1969 / 1992 Protocol)
The International Convention on Civil Liability for Oil Pollution Damage requires registered shipowners to maintain insurance or other financial security to cover liability for oil pollution damage.
The Convention applies to all seagoing vessels carrying oil in bulk as cargo. Ships carrying more than 2,000 tons of oil are required to maintain insurance coverage for pollution liability.
This Convention entered into force in Comoros Maritime Administration on 7 October 2004.
Bunkers Convention (2001)
Under the International Convention on Civil Liability for Bunker Oil Pollution Damage, registered owners of ships over 1,000 gross tonnage must maintain insurance or equivalent financial security to cover liability for bunker oil pollution damage.
This Convention entered into force in Comoros Maritime Administration on 21 January 2010.
Civil Liability & Bunker CLC Insurance Certificates
The insurance document issued under the above conventions is commonly referred to as a Blue Card.
Blue Cards must be addressed to the Comoros Maritime Administration.
Applications for Civil Liability Certificates (CLC or Bunker CLC) should be submitted through the Maritime Registrar that processed the vessel’s registration, or directly to SKANReg Head Office for directly registered vessels.
There is no application form. Applicable fees may be obtained from a Maritime Registrar or Head Office.
Application Requirements
Requests for issuance of a CLC or Bunker CLC Certificate must include:
Name of ship
Official number
IMO ship identification number
Name and full address of the registered owner and manager
Original Blue Card confirming insurance coverage and specifying the applicable Convention
P&I insurance group details
The Blue Card must be submitted as a legible, full-colour scanned copy. Verification must be possible directly from the issuing insurer.
Certificates are normally issued within one working day, subject to receipt of payment and successful verification.
Recognition of P&I Clubs & Insurers
Insurers or P&I Clubs not currently recognized by the Registry may apply for inclusion by submitting:
- A list of countries for which Blue Cards are currently issued
- Examples of Blue Cards issued for at least three other Administrations
- Evidence of claims payment within the past 24 months
Additional financial guarantees may be requested. Reference is made to IMO Circular 3464.
Bunker CLCs for Non-Party States
In accordance with the Convention, Comoros Maritime Administration may issue CLCs to vessels registered under non-Party States.
Applications follow the standard process and must additionally include a copy of the ship’s Certificate of Registry.
Service provider registration process
Steps to Register
Review registration requirements
Download and review the applicable registration procedures and eligibility requirements relevant to the vessel type and intended registration.
Complete the required application forms
Prepare and complete the prescribed application forms together with all supporting documentation required for registration.
Submit documentation for review
Submit the completed application and supporting documents to the Comoros Maritime Administration, an authorized maritime registrar, or an approved service provider for assessment and approval.