The Commercial Yacht Code 2025: What Owners Need to Know

Malta published a new Commercial Yacht Code on 30 May 2025. It took effect on 1 July 2025 and replaced the 2020 edition.

It is the fifth edition of the code, and it is not a light refresh. It changes which yachts are covered, how far they may sail, what happens when a yacht is rebuilt, and what private yachts above a certain size have to do.

As of May 2025 there were 424 commercial yachts over 24 metres on the Malta flag. Every one of them is affected.

This article sets out what changed and what an owner has to do about it.

First, which code applies to your yacht

This is the change that catches people, because it is a change to the boundary rather than to a rule.

Only yachts of 24 metres and over fall under the main code. Yachts between 12 and 24 metres now sit under a separate Small Commercial Yacht Code, brought in during April 2024.

So an owner who read the 2020 code and assumed it still applied may be reading the wrong book. The first question is not what the rules say. It is which set of rules the vessel is in.

The deadline, plainly

Existing yachts must comply by their first renewal survey after 31 December 2025.

That makes 2026 the transition year. There is no single date when everybody has to be ready, which sounds generous and is actually the trap. Your deadline is your own survey date, and it is already in the diary.

If that survey is coming up and the work has not been scoped, this is the item to move first.

Sailing range is now a formal choice

The code sets three navigational notations. That is the official term for how far from a safe port the yacht may operate.

Short range covers 60 nautical miles. Extended short range covers 150. The third notation is unrestricted.

Extended short range is the new one. It has been formalised in this edition, and it fills a real gap. A yacht working the central Mediterranean often needs more than 60 miles and does not need full unrestricted equipment and manning.

The notation is a commercial decision as much as a technical one, because it sets where the yacht can earn. Choose it against the intended cruising and charter pattern, not against the yacht’s theoretical capability.

Private yachts over 500 gross tonnes

This is the change most likely to surprise someone.

Gross tonnage is a measure of a vessel’s enclosed volume, not its weight. A private yacht above 500 of them now has to comply with the code as far as is reasonable and practicable. It also faces an initial survey judged against commercial yacht criteria.

Under the old position that was voluntary. It is not any more.

The wording leaves room for judgement, and that room is where the argument will happen at survey. An owner in this bracket should not assume the private register keeps the code out. It no longer does.

Rebuilds no longer inherit the old rules

Under the old position, a yacht having major work done largely kept the standards it was built to. That is finished.

A yacht going through a large conversion now has to meet the full new-build standards of the 2025 code.

For anyone planning a serious refit, this changes the sum. A job that looked cosmetic and mechanical may now bring structural and safety upgrades with it. Price the code into the refit before the yard quote is agreed. Not after the yacht is opened up.

Crew, and the people who are not crew

The code lines up with the Maritime Labour Convention. That is the world agreement setting the lowest standards for how seafarers work and live.

Three areas moved.

Crew living space standards were updated. Rest and working hours are now dealt with directly. And safety training became a must for people on board who are not crew.

Read that last one twice. Staff who are not seafarers used to sit outside the crew rules. Now they need training. Think of permanent security, a nanny, a chef brought in for the season, or a technician aboard for one passage. That is real paperwork, with names attached to it.

Equipment and environmental provisions

Three more changes matter.

Asbestos is banned in anything newly fitted. Lightning protection is now a must. And the code covers hybrid and electric drive, which the 2020 edition did not.

Separately from the code, a new fuel rule arrived on 1 May 2025. The whole Mediterranean became a low-sulphur zone. The limit on sulphur in fuel fell from 0.50% to 0.10%. That should cut sulphur emissions by about 80%. Transport Malta answered with lower registration fees and other rewards for cleaner vessels.

For an owner, the two arrive together. Fuel now sits in the same conversation as safety.

What this actually costs an owner

The code publishes no price, so anyone who quotes you a figure is guessing. The cost lands in four places.

Survey and paperwork. That part is direct and easy to predict.

Equipment or structural upgrades. This depends on the yacht’s age and state.

Crew papers and training, including the non-crew people above.

And yard time, which is usually the big one, because it competes with the season.

Yard time is the one owners get wrong. Do the work in a planned winter period and it is ordinary maintenance spending. Do the same work in a hurry in June and you pay the yard bill and lose the charter.

What the code does not do

It is worth being clear about the limits, because the code gets blamed for things it has nothing to do with.

The code is about safety and operation. It sets how the yacht is built, equipped, crewed and surveyed. It does not decide your tax.

So it does not tell you whether to register the yacht privately or commercially. That choice turns on what the yacht will lawfully do, and on the ownership plan behind it. It does not set your VAT rate either. VAT follows how the yacht is actually used, and the records that prove it.

What the code does is change the cost and the duties attached to one side of that choice. Commercial registration was always more work. Since July 2025 it is more work again, and private yachts above 500 gross tonnes no longer sit fully outside it.

That is why the code belongs in the same conversation as the structure. Not because it changes the tax rules, but because it changes the price of the option you were leaning towards.

What to do now

Five steps, in this order.

Find out which code applies to the vessel, main or small. Find the date of the first renewal survey after 31 December 2025, because that is the real deadline. Get a gap assessment against the 2025 code from a competent surveyor. Decide the navigational notation against how the yacht will actually be used. Then schedule the work into a yard period you choose rather than one forced on you.

If a large refit is already planned, do all of that before the yard contract is signed.

How Zenco Partners can help

We put yachts on the Malta flag. We also run the company behind them: setting it up, directors, company secretary, registered office, accounts, tax returns and VAT.

On the code, we do the part that sits between the technical and the commercial.

Which register the yacht belongs on. Which sailing range matches how it will earn. How the survey timetable fits the charter season. And whether the ownership set-up still suits what the yacht is about to become, because a big refit often changes that.

For a confidential talk about a specific vessel, email info@zencopartners.com or message us on WhatsApp at +356 7921 2598.

This article is for informational purposes only and does not constitute legal, tax, or financial advice. Professional advice should be obtained before taking any action based on the contents of this article.