Electronic Biofouling Management Platform

Subsee together with Smart Nautilus have launched an electronic platform for managing biofouling on merchant vessels, which brings together underwater inspection data, coating monitoring and regulatory requirements in a single working environment. The solution is already being rolled out across vessels in an international fleet and targets the moment when biofouling management stops being a minor ISM annex and becomes a real requirement enforced by ports and administrations.

From dead plan to a live operational platform
A classic Biofouling Management Plan is a static document that describes assumptions but poorly reflects the real history of a hull, its routes and cleanings. Smart Nautilus in cooperation with Subsee reverses this logic. The starting point is a digital platform that receives data from ROV inspections, port stays, cleaning operations and coating information, and only then builds plans and reports from this base. As the Smart Nautilus team stresses, the goal is a biofouling management plan that actually lives with the ship instead of lying in a binder on the bridge. Subsee adds interactive ROV operator training based on precise underwater inspection technology tested among others in controlled conditions at CTO in Gdańsk, which allows repeatable, comparable inspections and long‑term hull condition archiving.

Regulatory background: biofouling as invasive species risk
International Maritime Organization (IMO) updated its biofouling management guidelines in 2023 (Resolution MEPC.378(80)), but at the global level, they remain recommendations rather than hard law. At the same time, some states and port authorities have already moved from guidelines to mandatory requirements for ships entering their waters.

Biofouling is no longer just a problem of hull drag and fuel consumption, but is becoming a key vector for the transfer of invasive species between waters, as directly reflected in the updated IMO guidelines. In practice, this means that hull condition and fouling management are increasingly linked to port access and the scope of operations in specific jurisdictions.

At the national and regional levels, regulations go a step further. Brazil is implementing one of the most restrictive regimes in the world under NORMAM 401, with full enforcement of sanctions (including fines and potential detention) from June 10, 2026, and a requirement for ships over 24 meters to have a BFMP and BFRB. Australia is implementing the Biosecurity Amendment (Biofouling) Regulations 2021, which, after an “education phase,” are fully enforced from December 2023, and shipowners must demonstrate an implemented biofouling plan and record or alternative cleaning measures. New Zealand has required a clean hull, confirmed by evidence of inspection or cleaning before arrival, since 2018, with the possibility of ordering ships to leave New Zealand waters in the event of excessive fouling. In the US, the state of California enforces its own Marine Invasive Species Program (MISP) for ships ≥300 GT, and Canada and Singapore are developing similar regimes, combining requirements for hull cleaning plans, records, and inspections with the protection of sensitive ecosystems.

Shift from a voluntary model to a globally binding one is also on the horizon. The IMO is working on a legally binding instrument on biofouling, which aims to transform the current guidelines into a convention similar in logic to the Ballast Water Management Convention, which in the coming years will translate into a mandatory BFMP and Record Book for all ships, regardless of their shipping routes.

For shipowners this means not only having a plan but also demonstrating a consistent history of activities. This includes when and where the hull was cleaned, its condition in key ports, how coatings were selected, and the maintenance schedule to mitigate the risk of transferring foreign organisms. In practice, this means that a well-written biofouling management plan is no longer sufficient. Ports and authorities expect a consistent picture and clear answers about inspection results, corrective actions taken, and how this relates to the declared biofouling management strategy.

As the Subsee Smart Nautilus team emphasizes, “the growing challenge for shipowners is not biofouling itself, but proving that it was managed in a manner consistent with growing regulatory requirements.” It is this gap between documentation and evidence that the Electronic Biofouling Management Platform fills.

How does the Electronic Biofouling Management Platform work?
In practice the solution can be described in three layers.​

• Data acquisition layer. ROV inspections carried out by trained crew members deliver repeatable photos and video, combined with an assessment of coating condition, fouling level and precise location on the hull.

• Analytical layer. Smart Nautilus specialists analyse collected materials, assess the impact of biofouling on vessel performance and regulatory risk, and translate the results into clear reports and recommended actions.

• Documentation and compliance layer. All inspections, reports and corrective actions are archived and trended in the Smart Nautilus platform so that the shipowner has a complete biofouling history in one place, ready to show port authorities and insurers.

What does the Electronic Biofouling Management Platform actually bring?
Subsee contributes experience in underwater inspections using advanced ROV systems tested among others at the CTO S.A. facilities, where the precision of hull inspection and documentation quality was verified in controlled biofouling scenarios. Smart Nautilus specialises in early fouling detection, coating monitoring and a data‑driven approach to maintaining underwater hull areas. The joint electronic platform ties these capabilities into a single working environment for shipowners.

It provides:

• A training platform for ROV inspections.
• A digital register of the Biofouling Management Plan with the ability to update it on an ongoing basis.
• Systematic collection of inspection data (ROV, divers, cleaning robots) with georeferencing, coating condition and fouling classification.
• A full history of hull and propeller cleanings, including methods, locations, environmental parameters, and links to vessel routes.
• Mechanisms for generating documents and reports required by port authorities, class societies and insurers.

“Our goal is that a shipowner can present a port with a coherent biofouling history for a given vessel from plan to inspections to corrective actions in just a few clicks”  this approach runs consistently through Smart Nautilus’ communication.

Innovation: from product to data ecosystem
For shipowners the innovation does not lie in yet another gadget carried on board, but in moving away from a reactive model where intervention starts only once hull coverage and hydrodynamic drag have already increased significantly, towards a system that allows maintenance to be planned in advance, before a clear speed loss or fuel increase appears. A data‑based model makes it easier to plan work in port windows, match coating and cleaning strategies to actual routes, and reduce hull resistance, fuel consumption and emissions, while also limiting the spread of invasive species.

Relevance for the merchant fleet
The global merchant fleet is now under parallel pressure from decarbonisation, tighter environmental rules, rising fuel prices and increasingly detailed port inspections. Biofouling, long treated as a side cost of operations, is becoming one of the points where authorities demand hard data instead of empty declarations. The Electronic Biofouling Management Platform, now being deployed on vessels, fits this trend well. It allows operators to demonstrate that biofouling management is a continuous, measurable and documented process rather than a one‑off exercise prepared only for inspections. As a result, compliance stops being a pure cost and starts to translate into lower fuel use, reduced risk of delays and a real contribution to limiting the spread of non‑native species between sea areas

More information about the platform, fleet implementation options and practical use cases can be found on the project partner websites:

Subsee: www.subsee.pl,

Smart Nautilus: https://smartnautilus.com,

and on the Electronic Biofouling Management Platform page: https://app.easy.tools/pages/electronic-biofouling-managment-com.