Legal Updates

Decree of the Director General of Sea Transportation Number KP-DJPL 205 of 2026 Stipulating Mandatory Double Bottom Installation and Exemptions for Cargo and Passenger Ships

8/5/2026
Ivonnie Wijaya & Steven Aristides Wijaya
Legal Updates
Keputusan Direktur Jenderal Perhubungan Laut Nomor KP-DJPL 205 Tahun 2026 Menetapkan Kewajiban dan Pengecualian Pemasangan Dasar Ganda (Double Bottom) pada Kapal Barang dan Penumpang

Introduction

On April 23, 2026, the Directorate General of Sea Transportation (Direktorat Jenderal Perhubungan Laut, “DJPL”) issued Decree of the Director General of Sea Transportation Number KP-DJPL 205 of 2026 on Technical Guidelines for the Installation of Double Bottom Construction for Cargo and Passenger Ships (“DJPL Decree 205/2026”). DJPL Decree 205/2026 regulates the criteria, vessel size, ship types, and installation requirements for double bottom construction, as well as exemptions for certain commercial vessels operating within Indonesian territory.

DJPL Decree 205/2026 was issued to implement Article 5, Article 6, and Article 7 of Minister of Transportation Regulation Number PM 44 of 2021 on Ship Stability. DJPL has determined the types of Cargo Ships and Passenger Ships that must be equipped with double bottom construction, including exemptions based on ship type, ship design, and sailing areas. DJPL Decree 205/2026 also stipulates the guidelines for double bottom installation and bottom damage stability calculations in accordance with ship characteristics and operational areas.

Key Provisions

Classification of Operational Sailing Areas

The First Dictum classifies sailing areas based on ship operational areas for the application of ship safety and stability requirements. These sailing areas consist of:

  1. All Oceans Sailing Area: Encompassing all sea waters in the world;

  2. Indonesian Waters Sailing Area: Encompassing territorial seas, archipelagic waters, and Indonesian inland waters;

  3. Local Sailing Area: A radius of 750 nautical miles from the port of destination;

  4. Restricted Sailing Area: A radius of 100 nautical miles from the port of destination;

  5. Port Sailing Area: Areas within the working and interest zones of a port; and

  6. River and Lake Waters Sailing Area: Encompassing rivers, lakes, reservoirs, canals, channels, and swamps.

Criteria for Mandatory Double Bottom

The Second Dictum mandates the installation of double bottom construction for Newbuild Ships of certain sizes and types, specifically Cargo Ships and Passenger Ships with a length of 60 meters or more, as well as Oil Tankers with a deadweight of at least 600 Deadweight Tonnage (“DWT”). In applying these measurements, the Fourth Dictum stipulates that the ship length measurement shall use the Length Over All (“LOA”), measured from the foremost permanent bow point to the aftermost permanent stern point.

Exemptions Based on Ship Type

The installation of double bottom construction is exempted for Newbuild Cargo Ships with a length of 60 meters or more that fall into the following categories under the Third Dictum:

  1. Landing Craft;

  2. Self-propelled barges transporting cargo other than oil, gas, and chemicals (type 1 and 2 cargo);

  3. Pontoons; and

  4. Non-propelled barges transporting cargo other than oil, gas, and chemicals (type 1 and 2 cargo).

Owners of Landing Craft and self-propelled barges that obtain such exemptions remain obligated to possess bottom damage stability calculation documents in accordance with statutory provisions as regulated in the Seventh Dictum.

Exemptions Based on Design and Operational Area

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The installation of double bottom construction may be exempted if the ship's design does not permit such installation or if the ship is operated only in Restricted Sailing Areas and Calm Waters as regulated in the Fifth Dictum. Despite obtaining this exemption, ship operators remain obligated to fulfill bottom damage stability calculations based on the Sixth Dictum. If the ship is operated in Indonesian Waters or Local Sailing Areas, the bottom damage stability documents must be calculated using international standards.

Technical Specifications for Construction Installation

The scope of double bottom construction installation is differentiated based on ship length as regulated in the Eighth Dictum, with the following provisions:

  1. Ships 60 m - 71 m: Installed extending from the forward engine room bulkhead to the collision bulkhead or as close as possible to the collision bulkhead;

  2. Ships > 71 m - 85 m: Installed extending from the forward engine room bulkhead to the collision bulkhead, and from the aft engine room bulkhead to the stern bulkhead; and

  3. Ships > 85 m: Installed extending from the collision bulkhead to the stern bulkhead, including the engine room area.

The installation of double bottom construction in the engine room and bow thruster areas may be exempted if technically unfeasible based on the ship's design as regulated in the Ninth Dictum.

Validation, Supervision, and Dissemination

Bottom damage stability calculation documents must be certified by a Recognized Organization and approved by the Director General of Sea Transportation as regulated in the Fourteenth Dictum. Furthermore, based on the Fifteenth Dictum, the Director of Marine Safety and Seafarers carries out dissemination, guidance, supervision, and technical evaluation of the implementation of DJPL Decree 205/2026.

Transitional Provisions

Old Ships with a length of 60 meters or more that do not yet have double bottom construction may continue to operate as long as they meet the following requirements based on the Tenth Dictum:

  1. Possess bottom damage stability calculation documents;

  2. Possess emergency power sources that are functional at all times;

  3. Possess lighting and internal communication equipment that are functional at all times; and

  4. Operate in Restricted Sailing Areas or Calm Waters.

If the ship is operated in Indonesian Waters or Local Sailing Areas, the bottom damage stability calculation must use international standards as regulated in the Eleventh Dictum. Exemptions for double bottom construction also apply to Old Landing Craft, Pontoons, and Barges based on the Twelfth Dictum, with specific provisions for Landing Craft and self-propelled barges requiring certified bottom damage stability calculation documents as regulated in the Thirteenth Dictum.

Closing

DJPL Decree 205/2026 classifies sailing areas into six categories based on ship operational areas and mandates the installation of double bottom construction for Newbuild Cargo and Passenger Ships with a length of 60 meters or more, as well as Oil Tankers with a deadweight of at least 600 DWT. Ship length is measured using Length Over All (LOA), while the range of double bottom installation is differentiated by ship length dimensions, with specific exemptions for the engine room and bow thruster areas if the ship design does not permit it. DJPL Decree 205/2026 also exempts the mandatory installation of double bottom construction for several ship types, including Landing Craft, Pontoons, and certain barges, as well as ships with specific designs or ships operated only in Restricted Sailing Areas and Calm Waters. Nevertheless, owners and operators of Landing Craft and self-propelled barges remain obligated to possess bottom damage stability calculation documents, including for such vessels in the Old Ship category that do not yet have double bottom construction, and must fulfill requirements for emergency facilities, lighting, and internal communication. In the event the ship operates in Indonesian Waters or Local Sailing Areas, the bottom damage stability calculation must use international standards. Furthermore, all bottom damage stability calculation documents must be certified by a Recognized Organization and approved by the Director General of Sea Transportation, while the Director of Marine Safety and Seafarers carries out dissemination, guidance, supervision, and technical evaluation of the implementation of DJPL Decree 205/2026, which has been effective since April 23, 2026.

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