On 23rd June 2026, the Deputy Ministry of Shipping (SDM) issued Circular No. 17/2026, introducing a revised regulatory framework governing the use of Electronic Log Books (e-Log Books) on board Cyprus-flagged vessels (the “Circular”). The Circular, which enters into force on 1st July 2026, reflects the SDM’s continued commitment towards the digitalisation of the Cyprus Ship Registry while ensuring compliance with the applicable national legislation and international maritime standards.
Legislative background
The Circular has been issued pursuant to section 99 of the Merchant Shipping (Masters and Seamen) Laws of 1963-2002 (Law 46/63 as amended) (the “Law”). The Law requires every Cyprus ship to maintain the prescribed log books in a form approved by the Deputy Minister of Shipping. Under this legislative framework, ships are required to keep an official log book, together with other prescribed log books, including the engine room and radio log books, to record operational, safety and legal matters occurring during a voyage. These records serve as important evidence of compliance with both national and international maritime obligations and may be relied upon during inspections, audits, investigations and legal proceedings.
Traditionally, these records have been maintained in paper format, with entries being made manually by the responsible officers on board and authenticated through handwritten signatures. The Circular aims to modernise this approach by permitting the use of approved electronic systems for the maintenance of statutory log books, subject to compliance with the requirements prescribed by the SDM.
Scope of the Circular
As part of Cyprus’ maritime digitalisation efforts, the Circular applies to Cyprus-flagged vessels and authorises the use of approved Electronic Log Books for the maintenance of statutory Deck Log Book, Engine Room Log Book and GMDSS Radio Log Book.
The introduction of Electronic Log Books represents a significant step towards the digitalisation of statutory record-keeping within the Cyprus maritime sector while ensuring that the integrity, reliability, accessibility and evidential value of statutory records are maintained throughout their lifecycle.
It is important to mention that the adoption of Electronic Log Books is not mandatory. The Circular expressly preserves the option for shipowners, bareboat charterers and ship managers to continue maintaining the prescribed statutory log books in paper format should they so elect. Accordingly, operators are afforded greater flexibility in determining the record-keeping system that best suits their operational requirements, without affecting their continuing statutory obligations under Cyprus maritime legislation.
Therefore, the Circular establishes an alternative method of compliance rather than replacing the existing paper-based regime. Regardless of whether statutory records are maintained electronically or in hard copy, operators remain responsible for ensuring full compliance with the applicable legislative requirements and the standards prescribed by the SDM.
Approval requirements
The use of Electronic Log Books is subject to strict compliance with the requirements prescribed in Annex 1 to the Circular. Electronic systems must satisfy the technical, operational and functional standards established by the SDM before they are accepted for use on board Cyprus-flagged vessels.
The approval requirements are designed to ensure that electronic records possess the same legal validity, reliability and evidential integrity as conventional paper log books. Among other matters, approved systems are expected to safeguard the authenticity of entries, maintain data integrity, ensure appropriate user access controls, preserve records against unauthorised alteration or loss, and facilitate the retrieval of information during inspections, audits and investigations. At the same time, the Electronic Log Book shall include as a minimum the information described in the Annexes of Circular No. 27/2022.
Accordingly, operators intending to implement Electronic Log Books should ensure that any proposed system has been appropriately assessed and complies fully with the requirements prescribed by the Circular before being placed into operational service.
Transitional arrangements
The Circular repeals Circular No. 25/2020 with effect from 1st July 2026, thereby establishing a revised approval framework for Electronic Log Books.
Nevertheless, the Circular incorporates transitional provisions intended to ensure regulatory continuity and minimise disruption to existing operators. Electronic Deck Log Book systems, for which a Letter of Approval has already been issued pursuant to Circular No. 25/2020, will continue to be recognised by the SDM until the expiry date specified in the relevant approval.
Upon the expiration of those approvals, any subsequent approval must be obtained in accordance with the procedures and requirements established under the Circular. This transitional approach provides certainty for existing users while facilitating the orderly implementation of the revised regulatory regime.
Practical considerations for shipowners and managers
The introduction of Electronic Log Books offers a number of practical advantages for shipowners, managers and operators. Digital record-keeping has the potential to reduce administrative burdens, improve operational efficiency, enhance the accessibility of statutory records and simplify compliance during Flag State inspections, Port State Control inspections and internal audits.
However, implementation should not be viewed solely as a technological upgrade. Successful adoption requires careful planning and the establishment of appropriate governance procedures to ensure ongoing compliance with both statutory obligations and the operational requirements prescribed by the SDM.
Companies should review their existing compliance procedures, verify that the selected Electronic Log Book Provider satisfies the applicable approval criteria and ensure that masters and crew members receive adequate familiarisation and training regarding the operation of the electronic system. Particular attention should also be given to cybersecurity, access management, data protection, record retention and business continuity arrangements so as to safeguard the integrity and availability of statutory records throughout their prescribed retention period.
Key compliance considerations
Shipowners, managers and operators contemplating the transition to Electronic Log Books should undertake a thorough and comprehensive compliance assessment prior to implementation. Such an assessment should include verifying that the proposed electronic system fully complies with the technical, operational and security requirements prescribed by the Circular and its Annexes, as well as ensuring that appropriate internal procedures, crew training and record management practices are in place.
Operators should further ensure that appropriate safeguards exist to preserve the authenticity, integrity and accessibility of statutory records, thereby facilitating inspections by the SDM, Recognised Organisations and other competent authorities. A proactive compliance strategy will significantly reduce regulatory risk and assist operators in demonstrating continuous compliance with the applicable requirements of Cyprus maritime legislation.
Assessment and declaration
Electronic Log Book systems must be assessed by Recognised Organisations duly authorised by the Republic of Cyprus to carry out statutory certification and related services. Following completion of the assessment, the relevant Recognised Organisation issues a declaration in the prescribed form set out in the Appendix to the Circular. Where appropriate, the performance evaluation may be carried out remotely in line with the Recognised Organisation’s applicable remote survey procedures. The Recognised Organisation must inform the Administration within five working days from issuing the declaration. It is also worth noting that the Recognised Organisation conducting the assessment does not necessarily need to be the vessel’s classification society. The declaration issued by the Recognised Organisation is valid for a maximum period of three months.
Once the Recognised Organisation’s declaration has been issued, the company must apply to the Shipping Deputy Ministry for the corresponding SDM Declaration within two months. The application should be submitted by email to the address specified in the Circular and should be accompanied by a copy of the Recognised Organisation’s declaration.
Contingency procedures: System’s failure or System cannot be used
Operators should also have contingency procedures in place in case an Electronic Log Book system becomes unavailable or malfunctions. In such circumstances, the Administration and the vessel’s Recognised Organisation should be notified without delay, and the operator should assess the nature and impact of the failure and implement a corrective action plan. Appropriate interim measures may include reverting temporarily to paper-based log books until the electronic system has been fully restored and its proper operation has been verified.
Re-flagging
In the context of a re-flagging to Cyprus, any existing Electronic Log Book declarations issued by, or on behalf of, the previous flag administration must be replaced by an SDM Declaration within three months, in accordance with the approval process described above.
Legal risks and mitigation
From a legal perspective, the transition to Electronic Log Books may give rise to a number of risks if not properly implemented. For example, the use of a system that has not been approved or that does not fully meet the requirements of the Circular could expose operators to regulatory findings during Flag State or Port State Control inspections. Inadequate access controls or audit trails may create uncertainty as to who made or amended an entry, while weak back-up, retention or cybersecurity arrangements could compromise the integrity, availability or evidential value of statutory records in the event of an incident, investigation or dispute. Contractual arrangements with software providers may also create exposure if they do not clearly address system performance, data security, maintenance, incident response, liability, termination assistance and access to records following a service disruption or change of provider. These risks can be mitigated through early legal and technical due diligence, confirmation of the system’s approval status, clear internal policies on user rights and record management, documented crew training, robust retention and back-up procedures, cybersecurity and business continuity controls and carefully drafted contractual protections with technology providers.
Role of legal advisers
Legal advisers can support shipowners, managers and operators throughout the transition to Electronic Log Books by helping them assess the applicable requirements, review provider arrangements and put in place practical safeguards for approval, record integrity, access controls, retention, cybersecurity and business continuity. Early legal input can help reduce regulatory and contractual risk, support the evidential reliability of electronic records and ensure that the transition is implemented in a clear, compliant and commercially practical manner.
Conclusion
The Circular represents another significant milestone in the digital transformation of the Cyprus Ship Registry and reinforces Cyprus’ commitment to embracing technological innovation within the maritime sector. By permitting the voluntary use of approved Electronic Log Books, the Circular introduces greater operational flexibility while maintaining the high regulatory standards necessary to ensure the integrity and reliability of statutory records.
Although the transition to Electronic Log Books is voluntary, operators considering their implementation should approach the process with careful planning and due diligence. Ensuring that any electronic system fully complies with the requirements of the Circular and its Annexes, together with the adoption of appropriate internal compliance procedures, will be essential in achieving a smooth transition and maintaining continued compliance with Cyprus maritime legislation.
Early legal advice can further assist operators in identifying and mitigating regulatory, contractual, data protection and evidential risks and in implementing the necessary safeguards for a compliant and commercially effective transition.
The content of this article is valid as at the date of its first publication. It is intended to provide a general guide to the subject matter and does not constitute legal advice. We recommend that you seek professional advice in relation to your specific matter before acting on any information provided. For further information or advice, please contact Andria Kouloumi, Senior Associate, at Andria.kouloumi@kyprianou.com or Myrto Karakosta, Trainee Lawyer, at Myrto.karakosta@kyprianou.com