Navigating Change: Our Response to the New MCA Sport & Pleasure Code
The Maritime and Coastguard Agency (MCA) has been working on a new “Sport and Pleasure Code of Practice”, its effects could be devastating.
The Maritime and Coastguard Agency (MCA) has been working on a new “Sport and Pleasure Code of Practice”, its effects could be devastating.
The Maritime and Coastguard Agency (MCA) has been working on a new “Sport and Pleasure Code of Practice” to meet the rapidly changing needs of the small commercial vessel sector. It details the potential requirements for anyone wishing to operate a UK-flagged small commercial vessel, of which Helen Mary R, our boat, is classed.
The proposed code is now in a 12-week public consultation period ending on 25th February, allowing those affected to voice their opinions and highlight areas they feel require change.
While we acknowledge the improvements the code of practice brings, concerns remain. This blog is in no way intended to apportion any criticism to any person or organisation, particularly the MCA; it is meant as a reflection of how we feel the code may affect us. Any negatives should be viewed as our passion for Sail Training and the effect this code will have on us in its current form.
For those unfamiliar with the regulations governing small commercial vessels, the Codes of Practice set out the legal and safety requirements that vessels must follow to operate (you can download MGN-280, our current code of practice, here). They apply to commercially used boats and cover everything from construction standards and stability to fire safety, equipment, and crew training.
These regulations are significant for organisations like Morvargh Sailing Project, where our work is focused on providing life-changing experiences for young people at sea. We gladly operate and follow these rules to ensure our vessel, Helen Mary R, is safe, seaworthy, and compliant. Keeping young people and our volunteers safe is our highest priority and affects everything we do.
The UK Sail Training fleet comprises over 50 vessels, from traditional tall ships to modern yachts. These vessels safely sail thousands of miles every year, providing young people with challenging and transformative experiences at sea. In 2024 Sail Training organisations recorded 49,678 sailing days with young people aged 12 to 25 or people of all ages with additional needs. The sector has a proven safety record, with very few incidents—demonstrating that Sail Training operators take safety seriously and already operate and hold themselves to high standards.
A well-designed code should strike a balance between safety and practicality, ensuring high standards without placing unnecessary burdens on operators. The current code (MGN-280) has successfully provided this framework for years, allowing Sail Training organisations, charter yachts, and adventure sailing providers to operate safely and sustainably.
However, with the introduction of the new Sport & Pleasure Code, we are concerned that the proposed changes fail to reflect the realities of running a small sailing vessel. Instead, they appear to be directly adapted from the Workboat 3 regulations designed for tugs and workboats, poorly suited to small commercial vessels.
For Sail Training providers like us, these changes present significant operational and financial challenges that could impact the affordability, accessibility, and long-term sustainability of our work. In this blog, we’d like to highlight our key areas of concern and advocate for a collaborative approach to ensure that the new code supports rather than undermines the future of UK Sail Training. This blog and our consultation response aim to raise awareness about how the draft changes could heavily impact Morvargh Sailing Project and the wider UK Sail Training fleet.
While it is suggested that the financial impact of these changes is minimal, the reality is that the cumulative effect of multiple new requirements places a significant strain on small organisations. The compliance costs add up quickly, and the risk is very real for an organisation like Morvargh Sailing Project, which operates on tight budgets and limited reserves. Some of these changes could make it financially impossible for us to continue operating.
That said, we fully support changes that genuinely enhance safety. Keeping young people and volunteers safe is at the heart of everything we do, and we will always strive to meet the highest standards. However, regulations must be proportionate, practical, and achievable.
We urge the MCA to work collaboratively with the Sail Training sector to ensure that the new code strengthens safety without unintentionally forcing small organisations out of operation. By striking the right balance, we can continue to provide transformative experiences at sea, giving young people opportunities that would otherwise be out of reach.
One of the most concerning aspects of the new code is its impact on volunteers, particularly in the Sail Training sector, where organisations rely heavily on unpaid crew members. While Morvargh Sailing Project is a small organisation with 15–20 active volunteers, others in the sector have over 400 volunteers supporting their operations. Under the proposed code, “Anyone employed or engaged in any capacity onboard a vessel shall complete the required Administration-approved mandatory training courses”, significantly increasing the barriers to participation.
At Morvargh, volunteering is more than just lending a hand; it is a pathway into maritime careers. We actively promote young people who show leadership potential, inviting them back as Watch Leaders at just 15 or 16 years old. Though unqualified, these young volunteers give their time freely, supporting and mentoring the next group of trainees while developing their own skills. Over time, with experience and dedication, they can work up to Mate or even Skipper if they choose to pursue a professional maritime career.
The first step on this journey is the RYA Day Skipper qualification, which already represents a significant financial commitment of at least £694 (£295 for theory and £399 for practical training). However, under the new code, even these young volunteers—who are still in school—would now be required to complete additional courses, including:
An additional cost of £658!
These added requirements present a substantial financial and logistical challenge for a 15- or 16-year-old just beginning their journey in the sector. Many will be unable to afford them, cutting off a vital entry point for young people seeking maritime experience. The new code risks excluding the very individuals who would benefit most from Sail Training, removing a key pathway into the industry and reducing the volunteer base that makes these programmes possible.
To encourage youth engagement in maritime careers, reasonable exemptions or alternative pathways must be provided to young Sail Training volunteers. This will ensure they progress naturally through experience and structured training rather than being burdened with excessive certification costs early on.
Beyond our young Watch Leaders, the new code also presents significant challenges for our adult volunteers, who are essential to the safe and effective running of our voyages. At Morvargh Sailing Project, our Skipper must hold a Yachtmaster Offshore Certificate of Competency, which is commercially endorsed. Our Mate—depending on the type of voyage—must hold qualifications ranging from Day Skipper (for day sails within 11 miles of the coast in favourable weather) to Yachtmaster (for expeditions and longer offshore voyages).
To ensure a high standard, we ask our adult volunteers to have:
Once aboard, volunteers undergo significant internal training, developing the skills, confidence, and experience needed to become a practical and safety-critical part of the crew. This progression pathway allows us to build and retain a strong team, even as volunteers balance their sailing with careers, families, and other commitments.
We normally sail with a Skipper, Mate, two Watch Officers, and two young Watch Leaders, followed by 10 Trainees.
However, under the new code, as with our young Watch Leaders, adult volunteers will potentially need to complete another £658 worth of training over four days to volunteer.
Finding suitable volunteers is already challenging, and the new code threatens to make it even harder. By requiring additional qualifications for all crew, including volunteers, the code risks excluding capable and experienced individuals who are willing to give their time. Many sailors won’t have the financial resources or free time to complete the extra certification requirements, meaning fewer volunteers and a shrinking pool of skilled crew.
If the aim is to strengthen safety, we urge the MCA to recognise the existing high standards of Sail Training organisations and ensure that volunteer pathways remain accessible. A more pragmatic approach—allowing organisations to train their volunteers to meet safety standards but requiring the Skipper and Mate, as always, to have professional qualifications—would be far more effective in upholding safety while preserving the future of Sail Training.
While we fully support efforts to improve safety at sea, the financial burden of the new Sport & Pleasure Code cannot be overlooked. The MCA suggests minimal compliance costs, but the cumulative impact of multiple new requirements places a significant financial strain on small organisations like ours. Each additional regulation adds another expense, making it increasingly challenging to operate sustainably. We already subsidise the cost of a berth for a trainee, the fee we pass on is around 62% less than the actual cost of running it. Most of our trainees come from Cornwall, an area significantly affected by levels of deprivation.
One of the most significant cost increases comes from changes to the survey regime. Under the new code, the frequency of out-of-water surveys increases from every five years to every 36 months, taking a survey cost of £550 to over £2600! Additionally, the requirement for annual rigging and rudder inspections instead of periodic checks will cost at least £280 annually. These inspections are essential, and we can understand why the new code requires them, but the increased frequency adds up over time, stretching the budgets of small operators.
Several equipment upgrades will also be required, including but not limited to:
For older vessels like Helen Mary R, there are even more substantial costs. The requirement for stability reassessment for vessels over 20 years old could cost upwards of £20,000, an expense that could put us out of operation. The current system already ensures safe and stable operations, and this additional financial burden could force some sail training providers to cease operations entirely.
To comply with the new requirement, we would need to:
This is a vast and unnecessary undertaking, particularly for vessels like ours that already meet stability requirements. Helen Mary R has a current, approved stability book, reassessed with a lightship check last year and approved by the Certifying Authority. This means the vessel's stability has been formally evaluated, verified, and confirmed as compliant with safety standards.
Forcing small organisations to undergo this expensive and redundant process does not improve safety—it simply adds an impossible financial burden. Stability does not naturally degrade with time if a vessel is well-maintained and periodically checked, as ours is. Instead of imposing a blanket reassessment for all older vessels, a more sensible approach would be to require reassessment only if a ship has undergone significant structural modifications or if there is clear evidence of instability.
For sail training providers operating on tight budgets, the financial impact of this requirement could be crippling. It could push well-maintained, safe vessels out of operation if enforced as written.
The cost of mandatory new equipment also adds up quickly:
The issue is not just any single cost but the combined effect of these new rules. Each additional requirement chips away at financial sustainability, making it increasingly difficult for small organisations to continue operating.
We wholeheartedly support any new regulation that genuinely enhances safety. The safety of our trainees, volunteers, and Helen Mary R is at the core of everything we do, and we will always work to meet the highest standards. However, regulations must be proportionate, practical, and based on the realities of small commercial sailing vessels. There are very few grandfathering rights or phase-in of additional costs.
It is always difficult to argue the commercial impact of regulation against safety—after all, safety should always come first. But the reality is that this code, as written, puts Morvargh Sailing Project at real risk of closure. The cumulative financial and administrative burden is too great, while some changes add little or no tangible safety benefit. The approach appears to force workboat regulations onto small Sail Training vessels, disregarding our sector's operational differences and proven safety record.
Morvargh Sailing Project is not a large organisation with full-time staff and significant financial reserves. It is run by just two people, in their spare time, while also working to support the project. Since 2010, we have fought to keep operating—navigating the financial burden of a complete rigging replacement in 2013, four years of continuous fundraising to get going again, and the immense challenges of COVID-19. We have persevered through everything because we believe in the power of Sail Training to change young lives. But this new code, in its current form, threatens to undo all of that work.
Sail Training organisations across the UK have demonstrated exceptional safety records, successfully operating under existing standards for years. The additional regulatory and financial burdens proposed in this code risk undermining the entire sector without delivering proportional safety benefits.
As an ASTO / UK Sail Training (Association of Sail Training Organisations) member, we support measures that enhance the safety of our operations, provided they are evidence-based and proportionate. We also appreciate the clarifications and improvements made to the new code. However, further refinements are needed to clarify specific points.
Once these clarifications are made, we strongly advocate for an additional opportunity to review the Code before it is presented to Parliament. As ASTO members, we would welcome our representative body, ASTO, to provide final comments before the Code is formally submitted.
We are committed to working constructively with the MCA to develop regulations that enhance safety while ensuring the long-term sustainability of small organisations like ours. By working collaboratively, we can create a framework that protects lives at sea without unintentionally driving vital youth development organisations out of operation.
If you can support our points and Morvargh, please do take the time to read the consultation here or email Codes@mcga.gov.uk with your thoughts.
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