What Is Compulsory Liability Insurance for Passenger Vessels?
Compulsory liability insurance for passenger vessels (in Turkish, Deniz Araçları Zorunlu Mali Sorumluluk Sigortası) covers, up to the sum insured stated in the policy, the operator's or shipowner's liability to pay compensation for bodily injury and property damage suffered by travelling passengers or third parties as a result of an accident, or a collision or contact with fixed or floating objects, involving a vessel carrying passengers for commercial purposes (General Conditions A.1). It also provides the insured's defence against unfounded claims.
The insurance is regulated under Article 1259 of the Turkish Commercial Code and the related Tariff and Instruction Communiqué. It differs from P&I insurance, which covers a shipowner's wider maritime liabilities, and from the voluntary liability covers bought for pleasure craft, in its legal basis, whether it is compulsory and its minimum amounts (see "How It Differs from P&I and Voluntary Covers").
This page is for general information. It is not legal advice, and it does not indicate any particular insurer's capacity, any commitment to provide cover or a price quotation.
Who Must Insure? Legal Basis
The requirement does not come from a single provision. It arises from the provisions below. Which provision applies should be confirmed from the vessel's licence and activity before a policy is arranged.
- Turkish Commercial Code Article 1259: When passengers are carried on a vessel licensed to carry more than twelve passengers, all carriers who undertake or perform all or part of the carriage must insure their liability for passengers' death or injury. A vessel that does not meet these requirements is not allowed to sail.
- Law No. 2634 Article 29 (fifth paragraph): Sea tourism vessels whose capacity in the seaworthiness certificate exceeds twelve are subject to the insurance requirements in Article 1259 of the Turkish Commercial Code. The same article provides that the use of Turkish-flag sea tourism vessels for leisure, sport and entertainment is not considered passenger transport.
- Regular services: Under Article 5 of the Regulation on Regular Voyages by Ships (22/11/2023, 32377), operators of regular services must take insurance from the clubs and insurers accepted and announced by the Ministry for the duration of the line permit, and an insurance policy is requested with the permit application (Article 7). The article was rewritten by an amendment dated 12/7/2025; the current text should be confirmed from the Official Gazette.
- Tariff and Instruction Communiqué Article 1: The Communiqué applies to vessels covered by Article 1259 of the Turkish Commercial Code, sea tourism vessels within the fifth paragraph of Article 29 of Law No. 2634, and vessels that must present policies to the supervisory authorities under Article 5 of the regular voyages regulation.
- Sea Tourism Regulation Article 51(2): Certified sea tourism vessel businesses must take insurance covering the losses their listed vessels may cause to crew and third parties. The relationship of this provision to the compulsory insurance described on this page should be assessed separately.
Minimum Cover Amounts (SDR) and Source Dates
Article 3 of the Communiqué sets the minimum cover in SDR (the IMF's Special Drawing Right). The table below follows the text as amended by the Official Gazette of 10/10/2024, No. 32688, which entered into force on publication.
Scroll the table horizontally to see all columns.
| Vessel group | Per piece of baggage | Per vehicle | Property cover, per accident | Death, disability and treatment: per person | Death, disability and treatment: per accident |
|---|---|---|---|---|---|
| a) More than 12 passengers, licensed for international voyages | 2,250 SDR | 12,700 SDR | Capacity × 2,250/12,700 SDR | 250,000 SDR | Capacity × 250,000 SDR |
| b) More than 12 passengers, not licensed for international voyages | 2,250 SDR | 12,700 SDR | Capacity × 2,250/12,700 SDR | 100,000 SDR | Capacity × 100,000 SDR |
| c) 12 passengers or fewer | — | — | Capacity × 250 SDR | 25,000 SDR | Capacity × 25,000 SDR |
- The amounts in the table apply to losses caused to both passengers and third parties (Communiqué Article 3(2), 2024 amendment).
- Capacity in the table means the passenger capacity stated in the vessel's licence (vehicle capacity for vehicle-carrying vessels); if the licence states different summer and winter numbers, the larger is used. When a policy is issued, passenger capacity is used for passenger vessels, vehicle capacity for vehicle-carrying vessels and, for vessels carrying both, the higher cover amount.
- Turkish Commercial Code Article 1259: the compulsory sum insured may not be less than 250,000 SDR per passenger per accident for a vessel licensed for international voyages, and 100,000 SDR for other vessels (the sentence was amended by Law No. 7519 of 4/7/2024).
- Communiqué Article 4: for vessels with more than 12 passengers the limits in Article 1263 of the Turkish Commercial Code are taken into account for the maximum limit of property cover. For property cover, an excess not exceeding ten per cent of the cover may be freely agreed as the basis for recourse.
- Premiums are freely set by insurers licensed in Türkiye in the water vehicles liability branch (Communiqué Article 5). This page contains no premium or insurer capacity.
- Transitional Article 2 (2024): contracts in force on the entry-into-force date for vessels with more than 12 passengers continue on existing terms until expiry; contracts in force for vessels with 12 passengers or fewer are subject to the covers in this Communiqué without any premium action.
These are minimum amounts. The sum insured in the policy may be higher and depends on the terms of the issuing insurer.
Passenger and Third-Party Losses: What Is Covered?
According to the General Conditions the following covers meet the insured's liability (A.3):
- Death cover: If the accident causes the death of injured parties, it covers compensation for loss of support for those deprived of the deceased's help.
- Disability cover: In case of temporary or permanent disability, it covers the compensation determined once medical treatment has ended and the disability has been established.
- Treatment expenses cover: It covers first aid, examination, check-up and treatment expenses of injured parties.
- Property damage cover: It covers claims for baggage and vehicles that passengers carry with them or that are in the vessel's baggage section, and for the contents carried in or on them, as well as property damage suffered by third parties other than passengers. Third-party liability cover also includes pollution and wreck removal costs.
The injured party means a passenger, a third party who suffered loss because of the accident without travelling on the vessel, or those deprived of a deceased person's support. Injured parties may claim directly against the insurer within the limits of cover in the policy. If the injured party's fault contributed to the accident, a reduction may be made in proportion to that fault.
Geographical Limit, Period and Sum Insured
- Geographical limit: Passenger carriage between ports or piers of the Republic of Türkiye and between Turkish ports and foreign ports, including vessels laid up with or without repair (A.6).
- Period: From the start date to the end date stated in the policy, at 12:00 noon Turkish time unless otherwise agreed (A.7).
- Use: The cover is for events that occur while the vessel is in use in accordance with its allocated purpose, stops included (A.1).
- Multiple injured parties: If injured parties' compensation claims exceed the sum insured, each is reduced in the ratio of the cover amount to the total of the claims (B.5).
Main Exclusions and the Insurer's Right of Recourse
Under clause A.5 of the General Conditions the following situations and losses arising from them are excluded. The list is a summary; the policy and its additional conditions govern.
- Compensation claims made by the insured or the policyholder
- Claims of crew, of other persons for whose acts the insured is responsible, and of persons without a passenger ticket (stowaways)
- War, civil war, revolution, rebellion and the policing and military action they require
- Claims for losses caused by acts of the competent public authorities concerning the vessel or maritime traffic
- Nuclear, biological and chemical risks
- Participation in strikes, lockouts, popular movements and fights
- Terrorist acts within the meaning of Law No. 3713, sabotage arising from them and losses resulting from intervention against them
- A passenger knowingly exposing themselves to grave danger (except when saving persons and property in danger)
- Claims arising from an unavoidable natural event that cannot be prevented
- Claims arising entirely from an act or omission of a third party committed with intent to cause the loss
- Claims for losses arising from piracy and kidnapping
- Indirect losses, passenger suicide and losses of persons who should have been accompanied but travelled unaccompanied
Expenses arising from criminal prosecution and any fines are outside the cover (B.4). The injured party's rights are preserved: even if the insurer is released from its performance obligation to the insured, its obligation to the injured party continues up to the compulsory insurance amount (B.7).
The insurer may in particular have recourse against the insured for compensation it has paid in these cases (B.7): the event was caused by the intent or reckless conduct of the insured or persons it is responsible for; legal obligations were not met; the vessel did not comply with technical requirements or sailed without qualified crew; required first-aid equipment was not on board; the vessel was not navigated by persons with the required qualifications; the master was under the influence of alcohol or drugs; passengers or cargo exceeded the capacity set by the authorities; theft or seizure due to fault; and increased loss caused by failure to meet notification and other obligations.
Notification and Claims Process After a Loss
- Notification period: An event giving rise to compensation is notified to the insurer without delay and within ten days at the latest from when the insured learns of it; if it occurs abroad, without delay and within twenty days at the latest (B.1).
- The insured's duties: To take rescue and protective measures as if uninsured, to provide information and documents at the insurer's request and to inform the insurer immediately of any lawsuit or criminal prosecution (B.2).
- Admission and payment: Unless the insurer gives written permission, the insured has no authority to accept any compensation claim in whole or in part and may not pay the injured parties (B.1).
- Documents that may be requested: An accident report or expert report issued by the competent public authorities; for death, the death report and the certificate of inheritance; for injury, documents showing treatment expenses; for disability, a report from a fully equipped hospital; the court decision if the matter has gone to court (B.3).
- Maturity: Compensation becomes due once the documents are fully provided and the insurer has finished its investigations, and in any case forty-five days after notification; if not paid without justification, statutory default interest applies (B.4).
- Lawsuits: If a lawsuit is filed, the insurer states within five days of notification whether it will take over the conduct of the case (B.4).
- Change of insured: If the operator or owner changes, the new operator or owner must arrange new insurance immediately; the existing contract is valid for the new operator for at most ten days (C.4).
- Termination notice: If the insurance is terminated for any reason, the insurer notifies the relevant Ministry (C.3).
When Can a Foreign Club or Insurer Policy Be Accepted?
Under Article 6 of the Communiqué, policies issued by insurance companies operating in Türkiye are valid. For a policy issued by a foreign club or insurer to be accepted as valid, it must be issued by a club or insurer on the "List of Recognised P&I Clubs and Insurance Companies" announced by the Ministry of Transport and Infrastructure and must comply with the limits in the Communiqué.
For regular services, Articles 5 and 7 of the regular voyages regulation additionally require a policy and an insurance undertaking from clubs and insurers accepted and announced by the Ministry. The list and procedures may change over time; the current position should be confirmed from the General Directorate of Maritime Affairs announcements and the relevant authority.
How It Differs from P&I and Voluntary Covers
Scroll the table horizontally to see all columns.
| Compulsory vessel liability | P&I (protection and indemnity) | Voluntary yacht/boat liability | |
|---|---|---|---|
| Legal basis | Turkish Commercial Code Art. 1259, Law No. 2634 Art. 29(5), regular voyages legislation and the Communiqué | Regulation on Insurance and Inspection of Ships for Maritime Claims, Art. 2: Turkish-flag ships of 300 GT and above, and ships, whatever their flag, calling at or leaving port facilities within Turkish maritime jurisdiction (warships and certain state ships are excluded) | The insurance contract and the policy's general conditions |
| Required? | Compulsory for vessels within the relevant provision | Compulsory for vessels within the regulation; it is a separate obligation from the compulsory insurance on this page, and neither replaces the other | Voluntary; the requirement may come from contract, financing or marina terms |
| Subject | Bodily injury and property damage to passengers and third parties from an accident | Maritime claims and a wide range of shipowner liabilities | Third-party liability and other covers in the policy |
| Amount | Minimum amounts in SDR in the Communiqué | Amounts subject to limitation under the 1976 Convention and 1996 Protocol (Regulation Art. 5) | Limit stated in the policy |
The three structures do not automatically replace one another. For P&I see the P&I Insurance page; for pleasure craft see the Yacht and Pleasure Craft Insurance page. Whether each insurance is compulsory is assessed according to the vessel's type, flag, licence and activity.
Information Needed for a Quotation and Underwriting
- Vessel name, flag, registry, type, age and tonnage
- Passenger and vehicle capacity in the licence (summer and winter) and whether an international voyage licence is held
- Type of activity: regular service, excursion or sea tourism, day trips
- Trading area, line or route and ports of call
- Operator and owner details
- Existing policies (P&I, hull, voluntary liability) and expiry dates
- Loss and incident history
- Requested sum insured and excess preference
This list is an example; the information and documents requested vary by insurer. Acceptance, requests for further information and terms rest with the insurer concerned.
Legal Sources and Currency
- Turkish Commercial Code No. 6102, Articles 1259, 1262 and 1263 (as amended by Law No. 7519, 4/7/2024)
- Tourism Incentive Law No. 2634, Article 29
- General Conditions of Compulsory Liability Insurance for Vessels (effective 13/8/2014)
- Tariff and Instruction Communiqué on Compulsory Liability Insurance for Vessels (18/10/2014, 29149; amendments 22/4/2015, 16/3/2022, 10/10/2024)
- Regulation on Regular Voyages by Ships (22/11/2023, 32377; amendment of 12/7/2025)
- Sea Tourism Regulation Article 51
The amounts on this page are based on the Official Gazette text of 10/10/2024. Later amendments should be checked in the current legislation. Last checked: 26 October 2026.
Frequently Asked Questions
Who must take compulsory liability insurance for passenger vessels?
What are the minimum cover amounts?
Does a P&I policy replace this insurance?
Are third-party losses other than passengers' covered?
When must a loss be notified?
Neolife's Role
Neolife Group helps analyse the provision under which the compulsory insurance arises and its consistency with existing policies based on vessel and activity information, researches suitable insurance solutions, arranges placement work and compares the quotations received. This does not mean that any particular insurer's or reinsurer's capacity exists, that cover will be provided or that a premium is committed; acceptance and terms rest with the insurer concerned.