In the absence of enacted appropriation or continuing resolution, the Coast Guard is required to execute an orderly suspension of some operations and activities. In general, the Coast Guard will continue operations authorized by law that provide for national security, or that protect life and property. However, certain administrative functions will be limited. The following guidance is provided to assist vessel owners, operators, and other affected parties during the lapse in appropriations.
Certificates of Financial Responsibility:
The National Pollution Funds Center (NPFC) will process Certificate of Financial Responsibility (COFR) applications during the lapse in appropriations as an Excepted Activity. Captains of the Port (COTPs) will continue to verify that vessels maintain a COFR, as applicable (see 33 CFR 138.15) via NPFC ECOFR Active Vessel Status. If the COTP determines that a vessel does not have a COFR, but is required to, the COTP may contact the NPFC Command Duty Officer. The Vessel Certification Division of the NPFC will assist the COTP in determining COFR validity.
Vessel Response Plans:
To date, there are no direct Vessel Response Plan (VRP) impacts to industry due to the lapse in appropriations. However, continued delays in government funding may cause future delays in VRP review and approval.
Certificates of Documentation:
Processing commercial vessel documentation requests including renewals cannot be accomplished without violating the Anti-Deficiency Act. Certificates of Documentation (COD) for commercial vessels will not be processed, except for those COD requests for initial issuance (such as re-flag or new construction) necessary to meet national defense requirements (e.g., vessels enrolled in the Maritime Security Program (MSP) or those vessels actively carrying Department of Defense (DoD) cargo). However, vessel owners and operators should continue to submit renewal applications to the National Vessel Documentation Center (NVDC) prior to the expiration of the COD. In such cases, the following additional guidance is provided:
- Vessels Engaged on Domestic Voyages Only (Coastwise/Fisheries): Vessel owners and operators with a COD that expired after October 1, 2025, may continue to operate domestically on the previously issued trade endorsements provided a renewal application has been submitted to the NVDC. Vessel owners should be prepared to present evidence, upon request, to the Officer in Charge, Marine Inspection (OCMI) or the Office of Commercial Vessel Compliance (CG-CVC), that a renewal application was submitted. There will be no written dispensation granted for U.S. flag vessels operating on domestic voyages only.
- New Construction/Initial Certification (All Trade Endorsements): In accordance with the Marine Safety Manual, Vol. II, an initial Certificate of Inspection may be completed before the COD is issued provided the NVDC has received the application for documentation. Vessel representatives should be prepared to present evidence that the application was submitted to the NVDC, upon request, from the OCMI. There will be no written dispensation granted for U.S. flag vessels operating on domestic voyages only.
- Engaged on International Voyage (Registry Endorsement): Vessel owners and operators with a COD that expired after October 1, 2025, and which actively engage in international voyages necessary to meet national defense requirements (e.g., vessels enrolled in the Maritime Security Program (MSP) or those vessels actively carrying Department of Defense (DoD) cargo) subject to Port State Control, may request a dispensation from CG-CVC to allow for continued operation. Dispensation requests related to CODs should be sent to FlagStateControl@uscg.mil and include objective evidence that a renewal application has been submitted to the NVDC.
Merchant Mariner Credentials (MMCs):
The National Maritime Center (NMC) and all Regional Exam Centers (RECs) are closed. Merchant Mariner Credentials (MMC) and Mariner Medical Certificates will NOT be processed during the lapse in appropriations. For updates on NMC and REC operating status and credentialing related extensions please monitor the NMC website. For questions, including questions regarding credentialing issues related to National Defense, mariners and marine employers are advised to contact the NMC Customer Service Center via the NMC online chat system, by e-mailing IASKNMC@uscg.mil, or by calling 1-888-IASKNMC (427-5662).
- National Endorsements: Merchant Mariner Credentials (National Endorsements only) and Mariner Medical Certificates (National and Pilot expiration dates only) that expire in October 2025 remain valid until December 31, 2025. Mariners who are actively working on expired credentials that meet the expiration criteria must carry the expired credential AND a copy of the extension letter from the NMC while sailing under the authority of the credential. The NMC will not issue separate or replacement MMCs or Medical Certificates reflecting the extension.
- Standards of Training, Certification, and Watchkeeping (STCW) Endorsements: Mariners operating on STCW endorsements that expired on or after October 1, 2025, may continue to sail on their endorsements provided that a renewal application has been submitted to the NMC and the company has applied to the Coast Guard for dispensation in accordance with STCW Article VIII and the guidance provided on the NMC website. STCW dispensations that are approved will expire March 31, 2026. Mariners shall carry a copy of their dispensation letter, a copy of this bulletin and the expired MMC.
- Standards of Training, Certification, and Watchkeeping (STCW) Medical Certificates: The Coast Guard considers the lapse in appropriations to be an urgent situation. Mariners holding STCW medical certificates that expired on or after October 1, 2025, may continue to work under the certificate in accordance with the standards of STCW Regulation I/9.
A list of cognizant OCMI / COTP contacts is available on the Office of Commercial Vessel Compliance webpage..
For any questions, please email FlagStateControl@uscg.mil.
####