
Following the beginning of the public consultation process for the MCA “Sport and Pleasure Code of Practice”, the RYA has pulled out some key background information to help provide further context for our members and stakeholders.
Only with clear and objective responses from the public can the code be revisited for change and so it is vital that everyone affected has their say.
Where can I read the new Sport and Pleasure Code of Practice?
The new MCA Sport and Pleasure Code of Practice can be found online here.
What is the Code of Practice for the Safety of Small Vessels in Commercial Use for Sport or Pleasure?
The MCA Sport & Leisure Code of Practice details the requirements that need to be followed by anyone who wishes to operate a small commercial vessel, in commercial use for sport & pleasure at sea.
A commercial vessel is one which does not meet the definition of a pleasure vessel and a small vessel is one having a loadline length of less than 24m. This has been created and will be implemented by the Maritime & Coastguard Agency (MCA). The scope of which vessels are required to be coded has not been changed from the status quo and therefore if you are not currently required to be coded you will still not be required to be coded when the new code comes into force.
What is a public consultation process?
The consultation process gives the public an opportunity to respond to the draft code of practice, and legislation over a 12-week period. Once the consultation is closed, the MCA will respond.
Typically, after this process is completed, the legislation will go before parliament to make the new code a legal document. While there is no exact timeframe as to how long it will take to go through parliament, once it has, the code would likely come into force within several months.
How can I feedback into the public consultation process?
As the 12-week public consultation process has begun, now is the time for the sector to rally to ensure further progress can be made to ensure the final code is fit for purpose, proportionate, practical and achieves the intended outcome of a safer small commercial vessel sector.
Feedback can be provided via the specific questions set out in Section 5 of the Consultation Response Form by 11:59pm on Tuesday 25 February 2025. Once the form is completed, this should be sent to Codes@mcga.gov.uk.
Following the consultation process, the MCA will consider the feedback from the public and determine what, if any, changes will be made to the draft. The final version will then be laid before Parliament prior to coming into force.
How has the RYA worked to represent our networks regarding the new changes?
When the MCA initially shared the first draft version of the code, which they originally intended to publish for public consultation in May 2024, the RYA identified major concerns and potential issues.
Adamantly calling for changes to be made by MCA through a series of meetings, the RYA has driven various improvements, though some challenges remain.

Key achievements by the RYA include:
- Acceptance of RCD/RCR for Structure & Stability: The RYA has managed to steer the MCA to ensure that a vessel which has been assessed against the Recreational Craft Directive (RCD) does not generally need to undergo further structure or stability assessments. We do however, remain concerned that some smaller vessels which are not currently coded and have been assessed against RCD Module A1 may require additional structural assessment prior to coding.
- Towing Permissions: The initial draft prohibited vessels coded under the S&P code from undertaking any kind of towing including small inflatables, which the RYA argued was restrictive. Highlighting the necessity for the S&P sector to be able to conduct towing of vessels, albeit of a restricted size, amendments were made however further changes are still needed due to ambiguity in the proposed text.
- Inspection Requirements: The MCA initially proposed more frequent inspections, but after lobbying by the RYA, reverted to a model similar to the existing system, with the addition of a one-time inspection by a different surveyor within a ten-year period.
- Sailing Vessels in Racing Events and Race Support Boats: Section A covering racing vessels brings more clarity on what the requirements are dependent on if a vessel is currently coded or not. In addition, for vessels operating further from shore, they now have more stringent requirements with self-inspections now possible for those vessels operating closer to shore. The original draft from the MCA required a renewal examination prior to any races which the RYA successfully argued was excessive. Within the original draft of Section B, it required significant checks to be undertaken for any vessel being used as a Race Support Vessel. Following comments by the RYA, it is now accepted that a vessel which complies with the RCR requirements (UKCA or CE marked) can be accepted with additional requirements for carriage of safety equipment.
- Training Requirements: The MCA’s draft originally mandated extensive training that the RYA deemed excessive and unlikely to improve safety. In response, the RYA robustly made representations to the MCA on this issue and the likely impact it would have on a sector where the majority of those working within it are not funded by shipowners to undertake the relevant training courses. The current draft shared for consultation has reduced or removed several of these requirements (such as all crew to conduct a 1 day MCA Fire Fighting course) however some elements remain unchanged, which the RYA continues to challenge where it believes they are not appropriate to the sector or likely to improve safety.
What are key examples of areas of the new proposed code that still require change?
Despite improvements made, the RYA remains vigilant about certain areas that could impact operations and safety compliance in the sector. For example these include, but are not limited to:
- Acceptance of RCD/RCR for Structure: Despite RYA objections, it remains a concern that vessels under 12m in length, even if built under the Recreational Craft Directive (RCD), require a costly post-construction assessment by a notified body or a review of all structural calculations and drawings by the certifying authority to be considered suitable for coding. This requirement places an unnecessary financial burden on vessels already built to RCD standards."
At the RYA, we believe that for vessels operating in nearshore categories (5 & 6), the structure of a vessel should be capable of being assessed by a surveyor without having to undergo costly analysis and review.
- Towing Permissions: The MCA has taken feedback on board however, there has been some ambiguity left within the text (Section 12.3). It is currently open to interpretation as to the extent to which RIBs and open boats are permitted to tow.
Some requirements which are applicable for vessels towing large objects are inadvertently being applied to operations such as a RIB towing a small keelboat. Also, the towing methodologies outlined, do not appear to include the likely scenario for the sector of utilising a bridle from the stern of a RIB.
- Sailing Vessels in Racing Events and Race Support Boats: Despite amends, in section B, there still remains a lack of clarity as to the differing roles of the MNA (i.e. the RYA) and the OA (i.e. the club running the event) in issuing certification. If the MNA’s purpose is purely to certify that the usage is exclusively for race support activities, then this would appear to be an unnecessary administrative process given that the Organising Authority will need to be satisfied that the vessel has been checked and meets the relevant requirements.
- Training Requirements: There are several areas of concern that the RYA have identified.
- Radar Training: The MCA mandates its own radar course for higher categories (Cat 2 and above), though the RYA believes its existing radar course is sufficient.
- Electronic Chart Systems: The RYA acknowledges that electronic chart system (ECS) requirements now only apply to vessels with systems complying with MGN 319, but it remains concerned that the MCA's update to MGN 319 is unsuitable for sport and pleasure (S&P) craft. This keeps the outdated requirement to carry paper charts, even though the UKHO plans to phase them out. The MCA also suggests navigational watch training on equipment irrelevant to what is commonly used on S&P vessels. The RYA argues its decade of ECS training, aligned with the Digital First initiative, already equips candidates with the skills needed to safely navigate modern S&P vessels.
- Stability Training: The current draft requires all masters of vessels with stability books to complete MCA Stability Training. While this makes sense for vessels where cargo or equipment affects stability, it unnecessarily includes sailing multihulls and category 0 & 1 vessels, where stability is more about weather limits than loading conditions. Masters have little control over stability in these cases. Instead of mandating extensive training, the focus should be on making SIBs clear, practical, and easy for Masters to use effectively.
- First Aid Training: The MCA requires an STCW first aid course for crew on vessels needing an MLC inspection, which the RYA sees as unnecessary, especially when different standards apply based on the vessel's location rather than operational conditions
- Definitions: There are a number of new and amended definitions throughout the code. It is important that these are read and understood in the context of how they will be applied throughout the code. The RYA has particular concerns around the definitions of Control position; crew; Vessel in commercial use and trainee.
For further information or enquires on the MCA “Sport and Pleasure Code of Practice", we advise you to consult the MCA website.