Biosecurity Compliance for Vessels Arriving in Indonesia: A 2026 Ballast Water and Biofouling Record-Keeping Protocol

Maintaining strict ship compliance with Indonesian biosecurity regulations requires vessel masters to log every ballast water exchange and biofouling management activity meticulously. Aligning international ballast water standards with marpol compliance protocols ensures foreign vessels meet all mandatory port health and marine environmental directives. Coordinating pre-arrival documentation with shore representatives guarantees smooth audits by port state control officers, preventing administrative holds and protecting commercial sailing schedules.

Understanding Biosecurity Compliance in Indonesian Waters

Ballast water and biofouling are two potential pathways for transferring aquatic organisms between marine environments.
Ballast water is seawater carried to maintain vessel stability. When discharged, it may introduce organisms into another marine ecosystem.
Biofouling refers to marine organisms accumulating on submerged surfaces, including the hull, propeller, rudder, and sea chests.

Indonesia ratified the International Ballast Water Management (BWM) Convention through Presidential Regulation No. 132 of 2015. The Convention establishes mandatory ballast water management requirements for applicable vessels. Meanwhile, the IMO’s 2023 Biofouling Guidelines remain voluntary internationally in 2026, unless additional requirements apply.

Pre-Arrival Documentation Review

Before arriving at an Indonesian port, confirm that your vessel carries the applicable environmental documentation and that the records reflect actual onboard operations.

Document	Compliance Check
Ballast Water Management Plan (BWMP)	Approved procedures covering ballast water operations and contingency arrangements
International Ballast Water Management Certificate (IBWMC)	Valid certificate and applicable survey endorsements
Ballast Water Record Book (BWRB)	Complete and accurate ballast water operation records
BWMS Operating Records	Treatment-system logs, maintenance history, alarms, and failures
Biofouling Management Plan (BFMP)	Recommended procedures for hull inspections, cleaning, and coating maintenance
Biofouling Record Book (BFRB)	Recommended records of underwater inspections and maintenance activities

Applicable vessels of 400 GT and above generally require an IBWMC, subject to the Convention’s exceptions. The BFMP and BFRB are recommended under IMO guidance and should not be treated as universally mandatory PSC documents.

Ballast Water Record-Keeping Requirements

The Ballast Water Record Book documents how ballast water is taken onboard, managed, and discharged. Your entries should correspond with actual operations and the vessel’s approved BWMP.

Information to Record in the BWRB
Relevant records include:

• Ballast uptake: Date, time, location, tanks, quantity, and management method.
• Ballast discharge: Discharge location, time, quantity, and relevant treatment information.
• Ballast exchange or treatment: Applicable tank details, quantities, locations, and operational information.
• Exceptional operations: Equipment failures, accidental discharges, and relevant corrective actions.
• Sediment management: Applicable tank cleaning and sediment removal activities.

Entries should follow the prescribed BWRB format and be signed by the responsible officer, with completed pages signed by the Master. The BWRB must remain onboard for at least two years after the last entry and subsequently under company control for at least three years.

Updated Record-Keeping Requirements in 2025

Two amendments remain relevant for vessels operating in 2026. From 1 February 2025, the revised BWRB format under IMO Resolution MEPC.369(80) became applicable. From 1 October 2025, additional requirements for electronic record books entered into force.

If your vessel uses an electronic BWRB, verify that the system and accompanying documentation satisfy the applicable approval requirements. Before arrival, compare BWRB entries with BWMS operating logs and ballast tank records to identify inconsistencies.

Port State Control Inspection and Ballast Water Sampling

Indonesian PSC officers may examine ballast water documentation, onboard procedures, and treatment equipment under the applicable BWM Convention requirements. The IMO’s inspection guidelines distinguish between documentation checks, more detailed examinations, and ballast water sampling.

Documentation and Equipment Inspection

During an initial inspection, the officer may review the vessel’s IBWMC, approved BWMP, and BWRB. The responsible crew should also be familiar with the ballast water management procedures and operation of the treatment equipment. Where further examination is warranted, inspectors may review BWMS alarms, maintenance history, and operating records. Unexplained discrepancies between recorded ballast operations and equipment logs may lead to additional examination.

Ballast Water Sampling Procedures

Authorized inspectors may collect ballast water samples to assess compliance with the applicable discharge standard.
Two forms of analysis may be used:
Indicative Analysis
An initial assessment of ballast water quality that helps determine whether further testing may be necessary.
Detailed Analysis
A more extensive examination to evaluate compliance with the D-2 discharge standard, which establishes limits for viable aquatic organisms and specified indicator microbes.

Sampling should follow applicable IMO procedures, including suitable collection and handling methods. Sampling is not automatically conducted during every Indonesian port call. The inspection scope depends on the competent authority’s assessment.

Biofouling Inspection and Maintenance Records

The IMO’s 2023 Biofouling Guidelines recommend maintaining a vessel-specific management plan and documenting underwater maintenance activities. Although these guidelines remain voluntary internationally, consistent records support maintenance planning and provide evidence of the vessel’s biofouling management practices.

Recommended Biofouling Documentation

Activity	Records to Maintain
Hull Inspection	Inspection dates, locations, findings, and reports
Underwater Cleaning	Cleaning methods, affected areas, contractor reports, and completion records
Anti-Fouling Maintenance	Coating applications, repairs, and maintenance history
Niche Area Inspection	Condition of sea chests, thrusters, rudders, and other areas susceptible to marine growth
Extended Inactivity	Lay-up periods and operational changes affecting fouling accumulation

Where available, retain underwater photographs, inspection videos, and before-and-after cleaning reports. These records help establish which areas have been examined and whether additional maintenance is necessary.

Underwater Cleaning Permissions in Indonesian Ports

When underwater inspection or cleaning is planned during a port call, the proposed activities should be coordinated with the relevant authorities before contractor mobilization. For vessels at Batam anchorage, this may involve confirming the work scope, contractor documentation, diving safety procedures, environmental controls, and applicable permissions.

Underwater cleaning may release marine organisms and coating particles into surrounding waters. Cleaning methods and waste-handling arrangements should therefore be considered during preparation. The voluntary status of IMO biofouling guidance does not eliminate local authorization requirements for underwater work.

Regulatory Developments in 2026

International regulations and guidance continue to develop, particularly concerning ballast water management plans and the prevention of invasive species.

Revised Ballast Water Management Guidelines

At its 84th session in April–May 2026, the IMO Marine Environment Protection Committee adopted revised Guidelines for Ballast Water Management and Development of Ballast Water Management Plans (G4), under Resolution MEPC.409(84). The revised guidelines address the preparation and implementation of vessel-specific management plans. Their adoption does not automatically invalidate existing approved BWMPs. Any updates should be assessed against applicable Convention amendments and Flag State instructions.

Developments in Biofouling Regulation

IMO continues to develop a legally binding international framework for biofouling management. As of November 2026, the 2023 Biofouling Guidelines remain voluntary internationally. Maintaining an effective biofouling management programme can support vessel maintenance and preparation for future regulatory developments.

Preventing PSC Deficiencies and Detention Risks

Before arrival, review the vessel’s environmental documentation, operating records, and equipment condition. Particular attention should be given to incomplete BWRB entries, expired certificates, inconsistent treatment-system records, and unresolved BWMS failures. If a system failure affects ballast water compliance, document the circumstances, follow the approved contingency procedures, and notify the relevant authorities where applicable.

Serious deficiencies may result in restrictions on ballast discharge, corrective measures, or further enforcement action, including detention where justified. Accurate documentation must be supported by actual compliance with the vessel’s management procedures and applicable technical standards.

Environmental and Underwater Service Coordination with Balancia Ship Agency

Environmental compliance during port calls may involve documentation coordination, surveyor attendance, and underwater maintenance arrangements. Balancia Ship Agency supports vessel operations across Indonesian ports through port documentation, husbandry services, surveyor attendance coordination, and underwater inspection arrangements.

For vessels requiring underwater inspection or cleaning in Batam, our team coordinates contractor attendance, marine transportation, and applicable local permissions. Contact Balancia Ship Agency for underwater inspection, husbandry services, and port coordination across Indonesia.

Frequently Asked Questions

References

• International Maritime Organization. (2014). Guidelines for port State control under the BWM Convention (Resolution MEPC.252(67)). https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MEPCDocuments/MEPC.252%2867%29.pdf
• International Maritime Organization. (2023). 2023 guidelines for the control and management of ships’ biofouling to minimize the transfer of invasive aquatic species (Resolution MEPC.378(80)). https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MEPCDocuments/MEPC.378%2880%29.pdf
• International Maritime Organization. (2026). Marine Environment Protection Committee (MEPC 84), 27 April–1 May 2026. https://www.imo.org/en/mediacentre/meetingsummaries/pages/temporary-mepc-84th-session.aspx
• Lloyd’s Register. (2024, September 30). New requirements for hard copy and electronic Ballast Water Record Books. https://www.lr.org/en/knowledge/class-news/19-24/
• Republic of Indonesia. (2015). Presidential Regulation No. 132 of 2015 concerning ratification of the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004. https://peraturan.bpk.go.id/Details/79053/perpres-no-132-tahun-2015