04 Oct 2026 · TAMA Insight
Indonesia Clarifies Double Bottom Construction Requirements for Cargo and Passenger Ships
Indonesia has issued Director General of Sea Transportation Decree No. KP-DJPL 205 of 2026 on Technical Guidelines for the Installation of Double Bottom Construction for Cargo Ships and…
Indonesia has issued Director General of Sea Transportation Decree No. KP-DJPL 205 of 2026 on Technical Guidelines for the Installation of Double Bottom Construction for Cargo Ships and Passenger Ships (Decree 205/2026). Effective from 23 April 2026, the decree provides technical guidance on the double bottom requirements under Minister of Transportation Regulation No. PM 44 of 2021 on Ship Stability (PM 44/2021).
Decree 205/2026 addresses the interpretation of vessel types and dimensions subject to double bottom requirements, the circumstances in which installation may be exempted, and the technical conditions applicable to vessels operating without double bottom construction. It also clarifies the required installation range and the approval process for bottom damage stability calculations.
1. Regulatory Framework and Scope
PM 44/2021 establishes double bottom requirements for certain newly constructed cargo ships, passenger ships, and oil tankers, while also prescribing conditions for existing vessels that are not fitted with double bottom construction.
Decree 205/2026 provides further technical guidance on the implementation of these requirements, particularly under Articles 5, 6, and 7 of PM 44/2021.
The decree is supported by the broader shipping regulatory framework, including Law No. 17 of 2008 on Shipping, as amended, Government Regulation No. 51 of 2002 on Shipping, Government Regulation No. 31 of 2021 on the Implementation of the Shipping Sector, and Minister of Transportation Regulation No. PM 54 of 2021 concerning the Approval of Ship Design Drawings and the Implementation and Supervision of Ship Construction and Work.
Its principal areas of regulation include the classification of navigation areas, vessel categories and dimensions subject to double bottom requirements, exemptions based on vessel design and operating areas, the required extent of double bottom installation, bottom damage stability requirements, and approval of the relevant stability calculations.
2. Classification of Navigation Areas
Decree 205/2026 classifies navigation areas according to their geographical and operational scope. This classification is relevant to determining the operating restrictions and stability requirements applicable to vessels that are not fitted with double bottom construction.
The decree recognises six navigation areas:
- All Seas Navigation Area, covering navigation across all seas worldwide.
- Indonesian Waters Navigation Area, covering Indonesia’s territorial sea, archipelagic waters, and inland waters.
- Local Navigation Area, covering a radius of 750 nautical miles from a destination port.
- Restricted Navigation Area, covering a radius of 100 nautical miles from a destination port.
- Port Navigation Area, covering waters within the port working area and port interest area.
- River and Lake Navigation Area, covering rivers, lakes, reservoirs, canals, waterways, and swamps.
The classification provides the basis for applying the operating limitations contemplated under PM 44/2021, particularly for vessels permitted to operate without double bottom construction under specified conditions.
3. Double Bottom Requirements for Newly Constructed Vessels
3.1. Vessels Subject to the Requirement
Under the SECOND Dictum of Decree 205/2026, double bottom construction is required for newly constructed cargo ships and passenger ships with a Length Overall (LOA) of 60 metres or more, as well as oil tankers with a deadweight tonnage (DWT) of 600 or more.
The FOURTH Dictum clarifies that the relevant length measurement is the vessel’s LOA, measured from the foremost permanent part of the bow to the aftermost permanent part of the stern.
This clarification provides a specific measurement reference for applying the 60-metre threshold under PM 44/2021.
3.2. Excluded Cargo Vessel Types
The THIRD Dictum excludes certain cargo vessel types from the double bottom requirement applicable to newly constructed cargo ships with an LOA of 60 metres or more. These are:
- landing craft;
- self-propelled barges carrying cargo other than oil, gas, and chemicals classified as Type 1 or Type 2;
- deck barges or pontoons; and
- non-self-propelled barges carrying cargo other than oil, gas, and chemicals classified as Type 1 or Type 2.
These exclusions qualify the general cargo vessel threshold by identifying vessel types that are not subject to the same structural installation requirement under the decree.
The exclusions should nevertheless be read together with the separate stability requirements applicable to vessels operating without double bottom construction.
4. Exemptions for Newly Constructed Vessels
4.1. Permitted Grounds for Exemption
Articles 5(3) and 5(4) of PM 44/2021 permit exemptions from double bottom installation for certain newly constructed cargo and passenger ships in specified circumstances.
The FIFTH Dictum of Decree 205/2026 identifies the relevant grounds as follows:
- installation is incompatible with the vessel’s design;
- the vessel is designed to operate in a restricted navigation area; or
- the vessel is designed to operate in calm waters.
These grounds define the circumstances in which a vessel may be constructed without double bottom installation under the applicable framework.
4.2. Bottom Damage Stability Requirements
A newly constructed cargo or passenger ship that is not fitted with double bottom construction under the exemption provisions must comply with bottom damage stability calculation requirements under the applicable laws and regulations.
The SIXTH Dictum further provides that, where the vessel is intended to operate in the Indonesian Waters Navigation Area or Local Navigation Area, the calculation must also comply with applicable international regulatory requirements.
Accordingly, exemption from the structural installation requirement does not, by itself, remove the vessel’s obligation to demonstrate compliance with the relevant damage stability standards.
5. Required Extent of Double Bottom Installation
Article 7(1) of PM 44/2021 establishes the general installation range for double bottom construction. The EIGHTH Dictum of Decree 205/2026 provides further clarification based on vessel length.
For vessels with an LOA of 60 to 71 metres, double bottom construction must extend from the forward engine room bulkhead to the collision bulkhead, or as close as practicable to the collision bulkhead.
For vessels with an LOA of more than 71 metres and up to 85 metres, installation must extend from the forward engine room bulkhead to the collision bulkhead, and from the after engine room bulkhead to the stern bulkhead.
For vessels with an LOA exceeding 85 metres, double bottom construction must extend from the collision bulkhead to the stern bulkhead, including the engine room.
The decree therefore specifies the relevant engine room bulkheads and installation ranges for each vessel length category.
The NINTH Dictum also addresses circumstances in which double bottom installation in the engine room or around the bow thruster area behind the collision bulkhead cannot be implemented due to vessel design considerations. The application of this provision should be assessed against the relevant design circumstances and the underlying requirements of PM 44/2021.
6. Requirements for Existing Vessels
6.1. General Requirements
Article 6(1) of PM 44/2021 addresses existing cargo and passenger ships that have been operating without double bottom construction.
The TENTH Dictum of Decree 205/2026 applies to existing cargo and passenger ships with an LOA of 60 metres or more that are not fitted with double bottom construction.
Such vessels must:
- have bottom damage stability calculations prepared in accordance with applicable regulations;
- maintain functioning emergency power sources at all times;
- maintain functioning internal lighting and communication equipment at all times; and
- be designed and operated for restricted navigation areas or calm waters.
These requirements establish the technical and operational conditions applicable to the relevant existing vessels that continue to operate without double bottom construction.
6.2. Existing Vessels Operating in Indonesian Waters or Local Navigation Areas
The ELEVENTH Dictum specifically addresses existing cargo and passenger ships with an LOA of 60 metres or more that are not fitted with double bottom construction and operate in either the Indonesian Waters Navigation Area or the Local Navigation Area.
For these vessels, bottom damage stability calculations must also comply with applicable international regulatory requirements.
The distinction is relevant because the technical requirements for vessels operating in these areas are not limited to the general national requirements applicable to vessels operating in restricted navigation areas or calm waters.
6.3. Excluded Existing Cargo Vessel Types
The TWELFTH Dictum identifies the same four cargo vessel categories excluded from the relevant double bottom requirement for newly constructed vessels: landing craft, qualifying self-propelled barges, deck barges or pontoons, and qualifying non-self-propelled barges.
However, the THIRTEENTH Dictum provides that excluded cargo vessel types operating without double bottom construction remain subject to bottom damage stability calculation requirements under the applicable laws and regulations.
The distinction is therefore between exemption from the structural installation requirement and continued compliance with applicable stability requirements.
6.4. Approval of Bottom Damage Stability Calculations
Under the FOURTEENTH Dictum, bottom damage stability calculations required under the decree must be approved by:
- a Recognised Classification Society; and
- the Director General of Sea Transportation.
This approval requirement applies to the calculations referred to in the SIXTH, SEVENTH, TENTH, ELEVENTH, and THIRTEENTH Dictums.
Consequently, the required calculations are subject to both classification society review and approval by the competent maritime authority.
7. Relationship with Oil Tanker Requirements
The double bottom requirements for oil tankers are also addressed under Article 7 of Minister of Transportation Regulation No. PM 29 of 2014, as consolidated, in addition to Article 5 of PM 44/2021.
The relevant framework includes double bottom requirements for oil tankers with DWT of 600 or more, technical requirements concerning double bottom dimensions, and damage stability requirements for oil tankers of specified tonnage operating on international voyages.
Decree 205/2026 reiterates the DWT threshold for oil tankers and refers to applicable international requirements in connection with bottom damage stability calculations.
The relevant structural and stability obligations should therefore be assessed together with the applicable tanker-specific safety and pollution prevention requirements. The decree’s treatment of double bottom construction should not be read as replacing separate requirements governing double hull construction or international tanker standards.
8. Supervision and Effective Date
The FIFTEENTH Dictum assigns the Director of Shipping and Seafarers responsibility for socialisation, guidance, supervision, and technical evaluation of the implementation of Decree 205/2026.
The SIXTEENTH Dictum provides that the decree takes effect from the date of its determination, namely 23 April 2026, and that any errors identified subsequently will be corrected as appropriate.
Based on the regulatory status information provided, Decree 205/2026 remains in effect. It operates as technical guidance under PM 44/2021, while the underlying ministerial regulation continues to provide the principal legal framework for double bottom and ship stability requirements.
9. Practical Considerations for Shipowners and Operators
Decree 205/2026 provides greater technical specificity for determining whether a vessel is subject to double bottom installation, whether an exemption may apply, and what stability and operational requirements remain relevant where the vessel is not fitted with such construction.
Shipowners, operators, naval architects, and classification societies should consider reviewing vessel classification and LOA or DWT measurements against the applicable thresholds, whether any vessel type falls within the specified cargo vessel exclusions, the intended navigation area and resulting operating restrictions, the required extent of double bottom installation, the availability and approval status of bottom damage stability calculations, and the functioning of emergency power, internal lighting, and communication equipment for relevant existing vessels.
For vessels relying on an exemption or operating without double bottom construction, particular attention should be given to the applicable navigation-area limitations and the required approval of stability calculations.
Decree 205/2026 forms part of the continuing regulatory framework governing vessel safety in Indonesia. Please feel free to contact us should you wish to discuss its implications for vessel design, construction, classification, or operational compliance.
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