The International Group of P&I Clubs (“The Group”) has announced a significant policy update: starting 20 February 2025, paperless trading systems that meet specific criteria will be ‘deemed approved’ without requiring a separate approval process.
Criteria for ‘Deemed Approval’
For a system to qualify as ‘deemed approved,’ it must:
- Use only ‘compliant’ electronic bills of lading (E-bills) – These must be governed by a legal framework that recognizes them as equivalent to paper bills of lading.
- Be reliable – Reliability must be demonstrated through:
- An independent audit, or
- A declaration by a regulatory or accreditation body, or
- Compliance with applicable industry standards.
Streamlined Approval Process
- Any system provider that meets these criteria and seeks recognition can apply to be listed on The Group’s website.
- The Group will no longer issue individual circulars for each approved system.
- The status of previously approved systems remains unchanged.
Background & Industry Developments
The update follows legislative changes such as the UK’s Electronic Trade Documents Act (2023), which aligns with the UNCITRAL Model Law on Electronic Transferable Records (MLETR). This shift has encouraged the adoption of E-bills and distributed ledger technology across international trade.
Club Cover Considerations
While the update expands acceptance of E-bills, members are reminded that P&I cover exclusions still apply, including:
- Discharge at an unauthorized port.
- The use of ante/post-dated electronic documents.
- Liabilities under an ad valorem bill.
- Terms less favorable than the Hague-Visby Rules, unless mandatory.
- Cargo delivery is not by the system’s rules.
Next Steps for System Providers
- Existing approvals remain valid and will be listed on The Group’s website.
- Providers seeking listing under the ‘deemed approval’ process should contact secretariat@internationalgroup.org.uk with supporting evidence.
- Systems that do not meet the ‘deemed approval’ criteria must still undergo the existing approval process.
This policy change represents a major step toward modernizing trade documentation while ensuring legal certainty and risk mitigation for shipping operators.
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Source: JAPAN P&I CLUB