A prospective client asks why their proposed 90-metre yacht, intended to carry 12 guests, can be coded under the REG Yacht Code rather than complying with full SOLAS passenger ship rules. Explain the regulatory logic.

A. WHY CODED YACHTS DO NOT NEED FULL SOLAS COMPLIANCE: SOLAS's most onerous passenger ship requirements (full structural fire protection to passenger-ship standard, extensive subdivision, large-capacity lifesaving appliances) are calibrated for ships carrying large numbers of passengers with limited individual safety briefing and no realistic full evacuation rehearsal for every voyage. A 12-passenger yacht with permanent professional crew, mandatory safety briefings for all guests, and a low passenger-to-crew ratio presents a materially different risk profile, which the Code's framers (MCA originally, now the Red Ensign Group jointly) recognised by building a proportionate, yacht-specific code rather than forcing megayachts into full passenger-ship SOLAS compliance. SIZE ALONE DOES NOT TRIGGER SOLAS: a coded yacht remains coded under the Yacht Code regardless of length/tonnage provided it stays within the ≤12 passenger, no-cargo scope — this is precisely why LY3 removed the earlier 3,000GT ceiling, recognising that very large yachts with few passengers do not need passenger-ship-scale SOLAS treatment. IF THE CLIENT WANTS MORE THAN 12 PASSENGERS: the vessel would need to be coded as a passenger yacht (Part B of the REG Yacht Code, broadly the PYC successor) with its own more demanding requirements, or comply with full SOLAS as a true passenger ship — a materially different, more expensive build and operating proposition.

B. SOLAS never applies to any private vessel regardless of size or passenger numbers, so the question of which code applies is purely a matter of owner preference.

C. Only yachts under 500GT can be coded under the Yacht Code; any yacht over 500GT, regardless of passenger numbers, must comply with full SOLAS.

D. The Yacht Code and SOLAS are interchangeable terms for the same regulatory standard and a yacht complying with one automatically complies with the other.

A. THE LARGE (COMMERCIAL) YACHT CODE — LY3: Issued by the UK MCA, came into force 20 August 2013. SCOPE: commercially operated yachts that are 24 metres or over in load line length, carry no cargo, and carry no more than 12 passengers. LY3 removed the earlier 3,000GT ceiling, so megayachts of any tonnage can be coded as commercial yachts provided the 12-passenger limit is respected. CURRENT STATUS: since 1 January 2019, LY3 has been formally superseded on Red Ensign Group (REG) flags by the REG YACHT CODE, which merged LY3 and the Passenger Yacht Code (PYC) into a single document — Part A is the large-yacht successor to LY3, Part B covers passenger yachts (charter with more passengers under the relevant licence). The REG Yacht Code has since had further editions (most recently July 2024). PRACTICAL POINT: "LY3" remains common industry shorthand for "the large yacht code," even on vessels now actually coded to the REG Yacht Code — a candidate should recognise both terms refer to the same regulatory lineage, not confuse it with SOLAS (which applies to trading cargo/passenger ships, not coded yachts).

B. LY3 is a private insurance standard with no legal force — yachts may choose to follow it or not, and flag states have no role in enforcing it.

C. LY3 applies to all yachts regardless of size, including private (non-commercial) yachts under 24 metres, and to ships in commercial cargo trade.

D. LY3 has been replaced by SOLAS for all yachts over 500GT and no longer exists as a separate regulatory framework at any tonnage.

A. CODE COMPLIANCE CERTIFICATE (CCC) — PURPOSE AND DISTINCTION: The CCC confirms the yacht has been surveyed and found to comply with the applicable edition of the Large Yacht Code / REG Yacht Code in its construction, stability, fire protection, life-saving appliances, and equipment. It is the Code-specific equivalent of a SOLAS Safety Certificate for a coded commercial yacht. OTHER CERTIFICATES SERVE DIFFERENT PURPOSES: (1) TONNAGE CERTIFICATE — confirms gross and net tonnage, which determines which provisions of the Code (and other regulations) apply, since several Code requirements scale by GT band (e.g. crew accommodation equivalence bands at 200GT and 500GT); (2) LOAD LINE CERTIFICATE — verifies the yacht's freeboard/draught marks and confirms hull/freeboard integrity against the applicable Load Line rules; (3) SAFETY CERTIFICATE — where issued separately, covers specific safety equipment scope. WHO ISSUES/SURVEYS: typically a Recognised Organisation (classification society) acting on behalf of the flag state, not the MCA directly for most flags. A yacht operating commercially without a valid CCC is not lawfully coded — it cannot carry fare-paying charter guests or operate to the Code's reduced-passenger commercial basis.

B. The Code Compliance Certificate and the Tonnage Certificate are the same document under a different name — either may be presented to a surveyor or Port State Control officer.

C. The CCC only needs to be obtained once at build and never expires or requires renewal regardless of changes to the vessel.

D. A yacht can operate commercially with guests on board without a CCC as long as the crew hold valid certificates of competency.