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Implementation of ISPS Code Security Level 3 for Ships Calling at Ukrainian Black Sea Ports under Wartime Conditions

Aug 2026 · Lex portus · 0 citations · 34 references

Abstract

The article examines the implementation of Security Level 3 under the International Ship and Port Facility Security Code for ships calling at Ukrainian Black Sea ports during wartime. The study analyses the legal and operational basis of the three-tier maritime security system and evaluates its applicability under conditions of prolonged armed conflict and hybrid threats. Particular attention is paid to missile strikes, unmanned aerial and surface vehicles, naval mines, cyberattacks, electronic warfare, and interference with global navigation satellite systems. The Ukrainian experience shows that Security Level 3 has shifted from a temporary emergency regime to a sustained framework for continuous threat assessment, civil–military coordination, operational information exchange, and adaptive navigation management. The article identifies regulatory gaps related to unmanned systems, electronic warfare, cyber-physical attacks, evidence preservation, and cooperation between maritime security bodies and criminal justice authorities. It is argued that maritime security measures following attacks on ships and port infrastructure should be coordinated with criminal proceedings, including incident documentation, preservation of digital and physical evidence, and interaction with competent investigative bodies. The article proposes the development of supplementary International Maritime Organization guidance on the application of Security Level 3 in armed-conflict and other high-risk environments without revising the basic structure of the SOLAS Convention or the ISPS Code.

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