ISM Code: cyber risk must be in the safety management system
IMO resolution MSC.428(98) affirms that a safety management system approved under the ISM Code has to take cyber risk into account. Companies had to address cyber risk no later than the first annual verification of the Document of Compliance after 1 January 2021. This is still the operative obligation that flag states and port state control check; the MSC-FAL.1/Circ.3 guidelines describe how to do it.
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