1. Introduction

Pilotage of autonomous and remotely-controlled ships might seem, at first sight, to be a relatively unimportant topic, an afterthought compared to the fundamental issues relating to maritime safety and security presently being considered as part of the IMO’s (International Maritime Organization) “scoping” exercise in relation to what it calls “MASS” (Marine Autonomous Surface Ships). The IMO Maritime Safety Committee’s “scoping” exercise is considering: the Safety of Life at Sea Convention (SOLAS)1; the Collision Regulations (COLREGs)2; ship loading and stability (Load Lines)3; training of seafarers and fishers (STCW,4 STCW-F5); search and rescue (SAR)6; tonnage measurement (Tonnage Convention)7; safe containers (CSC)8; and special trade passenger ship instruments (SPACE STP, STP).9 The IMO Legal Committee and Facilitation Committee are conducting similar “scoping” exercises in relation to instruments under their purview, including some for which the IMO shares joint responsibility with other UN bodies such as UNCTAD.10 Although pilotage may seem to be much less important than the issues dealt with by these IMO conventions, the regulation of pilotage may actually prove to be a profound legal obstacle to the introduction of autonomous and remotely-controlled ships.