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Maritime Legal Update - January 2026

Published on 2026/01/02

Managing Compliance Risks in Shipbuilding Projects – Contractual and Practical Implications
(prepared by Marek Czernis & Co. Law Office)

1. Introduction

The global shipbuilding industry faces increasing compliance requirements arising from international sanctions, ESG obligations, and due diligence regulations.
The EU Corporate Sustainability Due Diligence Directive (CSDDD, 2025) and the OECD Guidelines for Responsible Business Conduct (2025) have direct implications for shipbuilding contracts, financing structures and supplier networks.

2. Main compliance risks in shipbuilding

  • Sanctions and export control compliance – continuous monitoring of suppliers and sub-contractors against sanction lists (EU, OFAC, OFSI).
  • Due diligence and supply chain transparency – ensuring traceability of materials and responsible sourcing under CSDDD obligations.
  • Environmental, Social and Governance (ESG) – mandatory sustainability reporting and environmental performance standards for yards and owners.
  • Anti-Bribery and AML – strict rules on anti-corruption and financial transparency for projects financed by banks or leasing institutions.

3. Contractual framework

Modern shipbuilding contracts, including NEWBUILDCON and SAJ Form, incorporate comprehensive compliance provisions such as:

  • Sanctions and Anti-Bribery Clauses;
  • ESG and Human Rights Clauses;
  • Audit Rights and Termination for Breach;
  • Extended warranties linked to sustainability compliance.

4. Practical recommendations

1️ Establish a documented Compliance Management System covering monitoring, training and audit procedures.
2️ Conduct Know Your Counterparty (KYC) checks for all contractual partners and suppliers.
3️ Review and update contractual clauses in line with CSDDD, OECD and BIMCO compliance frameworks.
4️ Implement ESG and sanctions clauses using BIMCO standard wordings.
5️ Provide compliance training to management and project staff involved in contracting and procurement.

5. Conclusion

Effective compliance management is now a key determinant of trustworthiness and risk control in shipbuilding projects.
In the view of Marek Czernis & Co. Law Office, alignment with international standards and contractual transparency will be essential to maintain competitiveness and financing eligibility in the evolving regulatory landscape of 2026–2030.