The regulatory change stems from amendments adopted in 2024 to the International Health Regulations, the binding international legal instrument governing public health security across borders. Article 35, as amended, stipulates that health documents may be issued in either non-digital or digital format, provided their authenticity can be ascertained . These amendments entered into force for most States Parties on 19 September 2025, creating a legal basis for digital health documentation that had not previously existed under the IHR framework.
In parallel, since 1 January 2024, the Convention on Facilitation of International Maritime Traffic has required public authorities to establish, maintain, and use Maritime Single Window systems for the electronic submission of information required on the arrival, stay, and departure of ships in ports . This created an expectation of digital information exchange at ports, but the two regulatory tracks—maritime facilitation and public health—have not been synchronized, leaving a gap that WHO’s guidance now addresses.
The core problem WHO identified is uneven digital capacity across States Parties. Many countries currently lack the systems, technical infrastructure, or interoperability arrangements needed to issue digital health documents or to verify the authenticity of digital documents received from vessels arriving at their ports . A digital certificate is not inherently authenticated simply because it appears on a screen; without cross-border interoperability, port authorities cannot reliably confirm that an electronic document is genuine and unaltered. WHO’s guidance acknowledges that this gap is widespread enough that no vessel can currently assume universal digital acceptance at every port of call .
The practical consequence is that the Ship Declaration of Health and Ship Sanitation Certificates must remain physically accessible on board for inspection at any port of call, regardless of whether digital versions also exist . Competent authorities responsible for issuing SSCs and shipmasters responsible for completing and submitting SDHs are directed to ensure that such documentation remains accessible in non-digital format to authorities in any port of call for their review . WHO framed this not as a temporary workaround but as a practical operational baseline during the transition to digitalization, intended to prevent the widening of the digital divide between States Parties and avoid unnecessary interference with international traffic .
The operational burden falls on shipmasters and the documentation chain, not on port-state systems. Digital health documentation workflows cannot yet replace physical documents at port, and vessels relying on digital-only health documentation at ports with limited verification infrastructure are operating on an assumption WHO has explicitly flagged as unsound . The obligation rests with the shipmaster, but the systems that support it—document version control, print workflows on board, crew awareness of dual-format requirements—fall within the operational scope of shipping lines and their technology managers.
WHO’s guidance also has implications beyond the immediate compliance question. It signals that the transition to fully digital health documentation will be gradual and dependent on port-state capacity development, not merely on regulatory permission. The organization encourages competent national authorities responsible for border health, port authorities, shipowners, and ship agents to continue supporting the availability and accessibility of SDHs and SSCs in non-digital format alongside any digital format, facilitating a smooth transition while preserving continuity of maritime operations and mutual trust among States Parties .
For shipping lines operating multi-region itineraries, the exposure is immediate and uneven. Ports in regions with established Maritime Single Window infrastructure, such as parts of the European Union, are further along in digital readiness, while many ports in Southeast Asia, West Africa, the Pacific islands, and parts of South America present higher risk of digital verification failure . Until WHO or the International Maritime Organization establishes a technical trust framework for digital health document authentication that port states can adopt without building bespoke national systems, the dual-format requirement is likely to remain the operational standard for global shipping .