In quarter 3 of 2025, the Directorate General of Sea Communication has issued Decree No. A.796/AL.308/DJPL of 2025 on the Technical Guidelines for the Application of Description Letters Without Pilotage (Pilot Exemptions) for Master of vessel Operating Crossing Transportation Vessels (“The Decree”). Pilotage Exemption is a dispensation granted to vessel captains to sail in waters that require pilotage without using pilotage services. This means that Master are given permission to navigate their vessels themselves in these areas, even though pilotage services are normally required.

This Decree also referred to previously enacted Ministerial Regulation No. 57 of 2015 on Pilotage and Delay of Vessels (PM 57/2015) on Article 42 Paragraph (1) which regulate that vessels sailing in waters that require regular and constant pilotage and commanded by a Master who is competent and meets the requirements may be considered by the local pilotage supervisor for exemption from pilotage services in the form of a pilot exemption certificate.

Master of vessel operating crossing transportation vessels of at least 500 GT within designated pilotage waters may apply. Applicants must demonstrate sufficient competence and the ability to meet operational requirements specific to the vessel, route, and time period covered. The pilotage exemption could be granted to a Master with certain specification such as:

1. Holding a Seafarer Certificate at the very least on the level of Ahli Nautika Tingkat III (“ANT-III”);
2. A Seafarer Certificate of Competency with the capacity of Master in accordance with the restrictions specified in the Seafarer Certificate of Competency;
3. Seafarer’s logbook with sailing experience as a Master on vessels of at least 500 GT for a minimum of 3 (three) years; and
4. Health certificate from a government hospital designated by the Director General of Maritime Transportation through a medical check-up.

The Pilotage Exemption certificate also limited to the specific vessel which fulfil certain criteria such as:

1. Valid vessel documents in accordance with laws and regulations;
2. Vessel seaworthiness documents issued by the Directorate General of Sea Communication;
3. Letter of Approval for Vessel Operation Plans on Fixed and Regular Domestic Sea Transportation Routes from the Director General of Sea Communication c.q. Director of Sea Traffic;
4. A sailing plan for the next 6 (six) months with an average destination covering the mandatory pilotage waters submitted (at least 8 (eight) times in 1 (one) month); and
5. Vessel and Crew insurance.

After the Master and Vessel specification has been fulfilled, Applicant then could lodge an Application for Pilotage Exemption with the attachment of administrative requirements, including:

1. Application letter from a shipping company or transportation company;
2. A statement letter from the Master stating his willingness to carry out pilot exemption training and examinations and to take responsibility for the movement of the vessel in waters requiring pilotage.
3. A statement letter from the Applicant stating that they are legally responsible for the validity and/or authenticity of the documents and information submitted in fulfilling the requirements, and in the implementation of shipping services that obtain a pilot exemption certificate, as well as guaranteeing and waiving any legal claims and/or other legal actions against the Ministry of Transportation for any legal issues that may arise in the future.

After all documents verified then the Master need to wait for the date of orientation and examination, after passing the examination then the pilotage exemption certificate would be published and reported The Directorate General of Sea Communication. If the Applicant failed the examination, then the applicant could re-take the examination limited to 4 (four) times.

The pilotage exemption certificate could be suspended due to adverse weather conditions that cause fluctuating changes in waters requiring pilotage, with consideration that could be found in the attachment of the Decree. The Master of a vessel who does not use pilotage services in waters where pilotage is mandatory without being equipped with a Pilot Exemption Certificate shall be subject to administrative sanctions, in the form of:

1. A written warning; or
2. Suspension of the maritime certificate.

We at Pro Alliance, are closely monitoring regulatory developments that impact the maritime and shipping sectors, our team knowledge, research, and extensive experience in advising and handling vessel operator and shipping company on compliance and certification process, ensuring a smooth and lawful voyage. If your operations may be affected by this new Decree, we are ready to assist in navigating the application process, maintaining eligibility, and mitigating potential compliance risks.