General instructions
Guidance on assessment process


As the competent authority regarding the Protection of Cyprus Ships against Acts of Piracy and Other Unlawful Acts Law 2012 (the Anti-piracy Law),(1) the Department of Merchant Shipping recently issued detailed guidelines for private ship security companies (PSSCs) that hold an authorisation certificate to provide services under Article 22(1) of the Anti-piracy Law or intend to apply for such authorisation.

The guidelines are applicable as regards:

  • the submission of an initial application;
  • a supplementary submission after an examination by the Department of Merchant Shipping;
  • the submission of an application for the addition of private ship security guards or firearms on an existing certificate; and
  • a change of ownership or control of a PSSC.

Further, PSSCs must consider the guidelines when submitting amended information to the Department of Merchant Shipping, as required by Article 24(1)(c) of the Anti-piracy Law.

The guidelines cover general instructions, firearms and guidance on the assessment process.

General instructions

An application for an authorisation certificate may be submitted by the legal person (the PSSC) or its authorised representative in Cyprus, but must in either case be signed only by an authorised officer of the PSSC. A copy of the application in electronic form, including all supporting documentation, should be submitted along with the paper application. The Department of Merchant Shipping will provide guidance and clarification on the requirements of the Anti-piracy Law up to the point that an application is submitted, but not during the examination phase, which begins when the application has been submitted. Amendments to applications or the submission of any additional documentation will not be accepted unless they have been requested by the Department of Merchant Shipping.

The information to be provided in the application and the supporting documentation is prescribed in the Sixth Schedule of the Anti-piracy Law. All the prescribed supporting documentation must be provided and no further irrelevant documentation should be included or the application may be rejected.

No information relating to the application will be disclosed to any third party, unless they have been assigned by the PSSC to act on its behalf and this has been confirmed in writing by the PSSC.

The Department of Merchant Shipping may conduct oral or written examinations or interviews of at least two of the PSSC's officers during the course of examining the application. Examinations may be also conducted if the Department of Merchant Shipping considers it appropriate to re-evaluate the PSSC's performance and its key officers' knowledge of the Anti-piracy Law.

The certificate issued to a PSSC under Article 22 of the Anti-piracy Law is valid only for the provision of services to Cyprus-flagged ships. Offering services to ships of any other flags or allowing it to be used by another party for any reason other than the provision of services to Cyprus-flagged ships renders the certificate void.

No entity may hold more than one certificate of authorisation to provide services. If a certified PSSC wishes to acquire another certified PSSC, it must notify the Department of Merchant Shipping in writing regarding which of the two companies will maintain its certificate in force. The other certificate will be withdrawn when the acquisition takes effect.

Following any change of control, the PSSC that will maintain its certificate in force must also retain the majority of its managers or directors who have been actively involved in its operations for at least nine months or until the completion of five operations relating to the provision of services aboard Cyprus-flagged ships, whichever occurs first.


A certified PSSC may own only those firearms specified in the Anti-piracy Law. The relevant provisions of the Department of Merchant Shipping Circular 1/2016 must also be considered. Ownership must be proven by a valid export licence, end-user certificate or equivalent document. The firearms must be purchased through a registered firearms dealer in a UN member state and this must be proven through the necessary documentation. Full details of all firearms must be submitted in order to allow traceability.

Guidance on assessment process

During the examination process, the applicant will be given the opportunity to resubmit additional documentation to rectify any deficiencies within a timeframe determined by the Department of Merchant Shipping. The Department of Merchant Shipping will examine the additional material and make its final decision on the application. The fees for the initial examination or any additional examination must be settled before the initial examination begins. If a PSSC's application is rejected, the Department of Merchant Shipping will accept no further applications from it or any other company with which it shares more than half of its shareholders, directors or managers.

The Department of Merchant Shipping uses a standard checklist to check that an application is complete and compliant with the requirements set out in the Sixth Schedule to the Anti-piracy Law.

The guidelines include a specimen objects clause which applicants registered in Cyprus must include in their memoranda of association and a sample curriculum vitae used to provide information about key personnel. Directors or managers must have appropriate military or anti-piracy experience or have successfully completed an approved security training course. Curriculum vitae must be provided for all ship security guards, providing clear information regarding their previous military service and experience. As a general rule, guards with no previous military or police training are not accepted.

The application must nominate a single contact to handle enquiries from the Department of Merchant Shipping. A directors' resolution confirming the appointment must be provided. If the nominated person is not a director of the PSSC, he or she must provide written consent to act on its behalf.

The application must include a draft operations manual, including comprehensive details of:

  • the selection criteria for security guards;
  • training procedures;
  • pre-boarding briefings;
  • interaction with the vessel's master and crew;
  • firearms handling;
  • monitoring;
  • remote support;
  • communications; and
  • personnel evaluation.

There must be clear rules of engagement for guards covering all levels of escalation, as mandated by the situation. Only the master of the ship, or a person delegated by him or her, can authorise the deployment of firearms.

Applicants are required to submit various declarations to the Department of Merchant Shipping in the prescribed form, without any alteration. All documents submitted must be legalised, as prescribed under Article 92 of the Anti-piracy Law. As a rule, any legalisation by a Cyprus consular officer does not need to be apostilled, but legalisations by a notary public should be apostilled. Legalisations by a certifying officer in Cyprus are accepted only for Cyprus residents. If the applicant intends to legalise documents in a country which is not a party to the Apostille Convention, it should obtain approval in advance from the Department of Merchant Shipping for the proposed arrangements.

For further information on this topic please contact Costas Stamatiou at Elias Neocleous & Co LLC by telephone (+357 25 110 110) or email ([email protected]). The Elias Neocleous & Co LLC website can be accessed at


(1) Law 77(I) of 2012.