This year's Annual Review reports strong financial results, continued strategic progress and enhanced support for shipowners operating in an increasingly complex and uncertain global environment.
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Updates for ships operating at ports in Brazil
Brazilian Ports Consider Expanded Compliance Inspections
Brazilian authorities and industry representatives are considering a potentially more structured approach to the inspection of ballast water management documentation aboard vessels calling at Brazilian ports.
The subject was discussed in Brasília on 2 September 2026, at a meeting organised by the Parliamentary Front for Ports and Airports through the Brazilian Infrastructure Institute.
The meeting brought together representatives of port authorities, the Brazilian Navy, government agencies, the Federal Public Prosecutor’s Office, the scientific community and industry organisations. Discussions focused on the existing regulatory framework, the allocation of institutional responsibilities and the role that port authorities may play in verifying compliance with ballast water management requirements.
Importantly, the discussions have not resulted in a new nationwide obligation or an immediate change to the procedures currently applicable to vessels. They do, however, indicate that documentary scrutiny may become more structured at certain Brazilian ports.
No regulatory change — but increased scrutiny may follow
At this stage, the discussions held in Brasília do not constitute a change in Brazilian law or the creation of a new nationwide inspection requirement.
The current significance lies instead in the possible development of a more structured role for port authorities in monitoring compliance and conducting documentary checks.
What should owners and operators consider?
Pending further developments, shipowners, operators and shipping agents calling at Brazilian ports should ensure that ballast water documentation is readily available for inspection.
Although no additional nationwide obligation has yet been introduced, documentary discrepancies may give rise to questions during a port call and could affect operational planning.
Advance review of the vessel’s documentation may therefore assist in identifying and addressing inconsistencies before arrival.
Practical implications
The principal point for maritime interests is therefore not that Brazil has introduced a new ballast water inspection regime — it has not.
Rather, the recent discussions indicate that existing compliance requirements may increasingly be subject to more structured documentary verification at port level, with port authorities potentially playing a greater role alongside the Brazilian Maritime Authority.
Shipowners and operators should accordingly monitor developments at their intended ports of call and ensure that the vessel’s ballast water documentation is in proper order before arrival.
Read more correspondent Rabb Carvalho website here.
As Brazil aligns its maritime standards with the latest IMO frameworks, the Brazilian Navy’s Directorate of Ports and Coasts (DPC) has just updated its robust regulatory environmental framework under NORMAM-401/DPC. This standard integrates international conventions—such as the IMO 2004 BWM Convention and the 2001 AFS Convention—with stricter national requirements. Notably, DPC has rendered the otherwise voluntary IMO 2023 Biofouling Guidelines mandatory for all vessels exceeding 24 metres in length, with some exceptions and exemptions.
Read more on correspondent Proinde P&I website here.
To assist shipowners, masters, and operators in navigating this complex landscape, correspondent Proinde P&I has updated their free loss prevention publication: “Ballast Water and Biofouling Regulations in Brazil: Practical Guidance”. The revised practical guide now provides insights on key requirements, including:
Integrated Regulatory Framework: A detailed breakdown of NORMAM-401/DPC (updated in June 2026), which consolidates the management of ballast water (BWM), harmful anti-fouling systems (AFS), and the new mandatory biofouling regime.
The 2028 Enforcement Window: Information on the DPC’s deferral of formal biofouling fines until 10 January 2028, explaining why statutory compliance remains mandatory now, even during this advisory transition period.
Documentary Readiness: Step-by-step requirements for ship-specific documentation, including the Ballast Water Management Plan (BWMP), Biofouling Management Plan (BFMP), and the critical Biofouling Record Book (BFRB).
Biogeographical Zoning: Guidance on Brazil’s three distinct marine regions and the mandatory underwater inspection protocols required when transiting between them.
Dual-Authority Oversight: Details the concurrent jurisdictions of the Navy (marine protection and maritime safety) and ANVISA (port health authority).
Underwater Husbandry Constraints: An analysis of the practical challenges at Brazilian ports, from the lack of approved vendor frameworks to the strict 100% debris capture requirements for reactive cleaning.
Penalties & Liability: A summary of the financial exposures for non-compliance, with fines reaching up to BRL 50 million.
Download correspondent Proinde P&I publication here.
To mitigate the risks of ballast water and biofouling, the Brazilian Navy’s Directorate of Ports and Coasts (DPC) has established a robust regulatory framework under NORMAM-401/DPC. This standard integrates international conventions—such as the IMO 2004 BWM Convention and the 2001 AFS Convention—with stricter national requirements. Notably, DPC has rendered the otherwise voluntary IMO 2023 Biofouling Guidelines mandatory for all vessels exceeding 24 metres in length, with some exceptions and exemptions.
Read more on correspondent Proinde P&I website here.
To assist shipowners, masters, and operators in navigating this complex landscape, correspondent Proinde P&I has released a free loss prevention publication: “Ballast Water and Biofouling Regulations in Brazil: Practical Guidance”.
This updated publication provides a detailed roadmap of the key requirements, including:
Mandatory shipboard management plans: Practical insights into developing ship-specific Ballast Water Management Plans (BWMP), Biofouling Management Plans (BFMP), and maintaining accurate Biofouling Record Books (BFRB).
Enforcement deadlines: Essential updates on the transition period for biofouling penalties, with full enforcement of fines scheduled for 10 June 2026 (subject to changes).
Health and sanitary controls: The role of the port health authority ANVISA (National Health Surveillance Agency) in regulating ballast water to safeguard public health and grant free pratique.
In-water cleaning protocols: Clear procedures for permit applications, waste capture mandates, and port-specific restrictions, such as those enforced in the Port of Santos.
Download correspondent Proinde P&I publication here.
The Santos Port Authority has resumed enforcement of the rule requiring ships to present a certificate of compliance with international ballast water discharge inspection standards before docking. The ruling upholds the injunction filed by the state-owned company against a decision by the National Waterway Transport Agency (Antaq), which has declared the rule invalid.
Read more on correspondent Brazil P&I circular here.
The 1st Federal Court of Santos annulled the regulation issued by the Santos Port Authority (APS) that required a report on the control and treatment of ballast water as a condition for ships to dock at the Port of Santos.
Read more on correspondent Brazil P&I circular here.
The rule requiring ships docking at the Port of Santos to present a certificate of compliance with international ballast water disposal regulations, which had been suspended in December last year, was reinstated on 13 February 2025.
Read more on correspondent Brazil P&I circular here.
National Waterway Transport Agency (Antaq) ordered the annulment of the resolution by the Santos Port Authority (APS) that required ships docking at the Santos quay to present a compliance certificate for ballast water disposal.
The regulation, published in April by the state-owned company, mandated the hiring of a remote monitoring system, which represented significant additional operational costs and overlapping rules.
Read more on correspondent Brazil P&I circular here.
A new rule required all ships operating at the Port of Santos to present a certificate of compliance with international ballast water disposal regulations.
However user complaints on overlapping regulations, excessive bureaucracy, and high costs for compliance led to the National Waterway Transport Agency (Antaq) suspending the rule.
Read more on correspondent Brazil P&I circular here.
Starting 21 August 2024, Santos Port Authority requires all ships to produce a statement of compliance with the ballast water regulations issued by an accredited private company, in addition to the current requirements under the BWM Convention.
Correspondent Proinde brings us updates below:
New requirements by the Santos Port Authority
On 11 April 2024, the APS issued its new regulation titled “Standard for Control of Management and Conformity of Ballast Water from Ships Operating in the Organised Port of Santos“, coded NAP.SUMAS.OPR.023.2024. This regulation mandates that a private company accredited by the port authority must attest that a ship complies with the ballast water regulations under the BWM Convention, NORMAM-401/DPC, and ANVISA Resolution RDC 72/2009, as applicable.
In addition to statements of compliance issued by classification societies, APS now demands licensed companies to issue their statements of compliance (referred to as AC-BWM) stating whether the vessel’s BWMS has been “approved” or “disapproved”. Under the regulation, apart from the obligation to upload documents on the PSP system, the agents must email the ballast water-related documentation directly to the licensed company, which will have 24 hours to analyse the case and issue the AC-BWM for the agents to upload on the PSP, allowing the ship to obtain permission from the port authority to enter the port and berth.
Enforcement
Regulation NAP.SUMAS.OPR.023.2024 will take effect on 21 August 2024. Any ship that does not produce an approved or failed AC-BWM will not be permitted to dock at port facilities within the jurisdiction of the APS. Shipowners and operators are entitled to challenge APS’ disapproval of AC-BWM through the adversarial system, with full defence rights, either administratively or judicially.
Grace period
During the 12 months following the publication of the new regulation, vessels with failed AC-BWM will be allowed to enter the port and operate normally as long as they meet the requirements set out by other relevant authorities. As the port authority, APS will report non-conformities to the Port Captaincy for appropriate action.
Licensed service providers and price
The new regulation establishes criteria and conditions for companies to be qualified by the APS to provide ballast water compliance-checking services. The prices charged are freely agreed upon between service providers; however, the port authority may intervene to repress actions that may potentially offend the principles of free and fair competition and economic order.
Currently, only one company is authorised by the port authority to issue AC-BWM. The service cost is reported to be around USD 1,400 per document issued for agents who are members of the local union of shipping agents (Sindamar), while non-members will be charged USD 1,700 per AC-BWM.
Read more on Correspondent Proinde website here.
