After a collision, grounding or fire, the voyage data recorder is often the only neutral witness aboard. For a Master, the annual performance test is the proof that the witness will still speak: that it records the right inputs, survives the casualty, can run on reserve power and can be recovered. This guide explains which VDR rules apply, what the recorder must capture and how long it keeps it, how the annual performance test works step by step, and what to check so that the evidence is usable when it matters.

VDR COMPLIANCE
Prove the VDR Will Still Speak After a Casualty
The annual performance test, the data inputs and the capsule checks that keep your recorder SOLAS compliant and your evidence usable.
Free trial available. Or book a walkthrough built around your own VDR test dates.
48 hours
Fixed and float-free media
Minimum retention under MSC.333(90).
30 days
Long-term medium
At least 30 days or 720 hours.
2 hours
Reserve power
Bridge audio from a dedicated reserve source.
18 months
Longest test interval
For cargo ships, within the annual test rules.

Which VDR Rules and Standards Apply to Your Ship

Full VDR, simplified VDR and optional recorders: how the type depends on ship and build date

SOLAS Chapter V Regulation 20 sets the carriage requirement. A summary from a VDR manufacturer says a full VDR is required on passenger ships and on cargo ships of 3,000 gross tonnage and over built on or after 1 July 2002, and a simplified VDR on older cargo ships of 3,000 gross tonnage and over. Because that summary comes from a vendor, confirm the carriage rule in the SOLAS text and with your flag state.

Which VDR type and which performance standard applies
Ship or installationType or standardWhere we found it
Passenger ships and cargo ships of 3,000 GT and over built on or after 1 July 2002Full VDRDanelec summary of SOLAS V/20
Cargo ships of 3,000 GT and over built before 1 July 2002Simplified VDR (S-VDR), standard MSC.163(78)Danelec summary, MSC.1/Circ.1222/Rev.1
VDR installed before 1 July 2014A.861(20) as amended by MSC.214(81)IMO Resolution MSC.333(90), paragraph 2
VDR installed on or after 1 July 2014MSC.333(90)IMO Resolution MSC.333(90), paragraph 2
Ships not required to carry a VDROptional L-VDRDanelec summary
Standards from IMO Resolution MSC.333(90). Ship type and build date summary from Danelec, a VDR vendor, and from MSC.1/Circ.1222/Rev.1.

Why the installation date decides which performance standard your recorder was built to

MSC.333(90) says the revised standard applies to VDRs installed on or after 1 July 2014, while earlier installations follow A.861(20) as amended by MSC.214(81). That matters for the Master because the annual test checks the data items required at original commissioning, so two ships with different installation dates can be tested against different lists.

What the VDR Must Record: Twenty Data Items From the Bridge and the Ship

How twenty required inputs flow into three recording media

The diagram follows the data path in MSC.333(90): inputs from bridge equipment and ship systems enter the data acquisition unit, which writes to a fixed capsule, a float-free capsule and a long-term medium. If any input is missing or silent, the casualty record has a hole in it.

From Bridge Inputs to Casualty Evidence: the VDR Data Path
20 DATA ITEMS IN
Navigation7
Ship's position · Speed through water and over ground · Heading · Radar displays · ECDIS display · Echo sounder · AIS data
Audio2
Bridge audio · VHF communications audio
Ship control2
Rudder order and response · Engine and thruster order and response
Safety status3
Main alarms · Hull openings status · Watertight and fire door status
Structure and environment3
Accelerations and hull stresses · Wind speed and direction · Rolling motion
Records3
Date and time (UTC) · Configuration data · Electronic logbook information
VDR data acquisition unit

THREE MEDIA OUT
Fixed capsule48 hours minimum. Kept 2 years after recording ends.
Float-free capsule48 hours minimum. Kept 6 months after recording ends.
Long-term medium30 days or 720 hours minimum.
Built from the data items and retention periods in IMO Resolution MSC.333(90), paragraphs 5.2, 5.4 and 5.5. Applies to VDRs installed on or after 1 July 2014.

Which groups of inputs make up the twenty items, and where each interface lives on board

Number of Required Data Items by Group, MSC.333(90)
Navigation

7
Audio

2
Ship control

2
Safety status

3
Structure and environment

3
Records

3
Twenty items in total. Some, such as ECDIS, structure and wind, apply only where the equipment is fitted.

Navigation is the largest group, with seven items, followed by safety status, structure and environment, and records. The interfaces you can check onboard sit behind the group names: GNSS, log, gyro, radar, ECDIS and AIS feeds for navigation; microphones and VHF for audio; steering and engine order interfaces; alarm and door indication panels; and wind and acceleration sensors where they are fitted.

How Long the Data Survives: Capsules, Retention and Reserve Power

Retention periods for the fixed capsule, the float-free capsule and the long-term medium

MSC.333(90) sets minimum retention on each medium. The fixed and float-free media keep at least 48 hours, and the long-term medium keeps at least 30 days or 720 hours. The fixed medium must retain data for at least two years after recording ends, and the float-free medium for at least six months.

Retention and survival requirements for each recording medium
Medium or functionMinimum durationKept after recording endsNote
Fixed recording medium (capsule)At least 48 hoursAt least 2 yearsFire, shock, penetration and deep-sea pressure resistant, with underwater location aid
Float-free recording medium (capsule)At least 48 hoursAt least 6 monthsMust float free after sinking, with grappling and recovery features
Long-term recording mediumAt least 30 days or 720 hoursNot stated in the extractHolds the longer record
Bridge audio on reserve power2 hours, then stops automaticallyNot applicableDedicated reserve source on loss of ship's main supply
Float-free locating signalsAt least 48 hours within a period of at least 168 hoursNot applicableHelps recovery after a casualty
Source: IMO Resolution MSC.333(90), paragraphs 5.2 and 5.4. The extract we read did not state a post-recording retention period for the long-term medium.

What happens on a blackout: the two-hour reserve power rule

On loss of the ship's main supply, the VDR must record bridge audio from a dedicated reserve source for two hours and then stop automatically. That is why the annual test removes external power and checks both that the alarm activates and that the recorder runs for at least 1 hour 55 minutes and stops recording no later than 2 hours 5 minutes. Our emergency generator and black-start test guide explains the blackout test that the engine room runs on the same ship.

The Annual Performance Test Step by Step

Who carries out the test, when it is due and how long the report takes

MSC.1/Circ.1222/Rev.1 says the annual test is performed by the manufacturer or a person the manufacturer authorises. For cargo ships it may be done within three months either side of the due date, with a maximum interval of 18 months, subject to SOLAS I/14 extensions. The report must be issued within 45 days. If results are satisfactory, an Annual Performance Test Certificate is issued, valid until the next annual revalidation provided the equipment is properly maintained.

Annual Performance Test Timing for a Cargo Ship (Months Since the Last Test)



0
3
6
9
12
15
18
Window: 3 months either side of the due dateDue date (12 months)Maximum 18 months for cargo ships
Drawn from MSC.1/Circ.1222/Rev.1: cargo ships may be tested within 3 months either side of the due date, with a maximum interval of 18 months, subject to SOLAS I/14 extensions. Passenger ships have a maximum of 15 months. The report is due within 45 days of the test.

Eight checks the testing engineer must complete, and the pass condition for each

1
Check for pre-existing alarms
Confirm no alarms are present before the test starts.
PASS WHENNo alarms at the start
2
Run the power supply alarm and reserve power check
Remove external power, confirm the alarm activates, and time how long the VDR keeps running.
PASS WHENRuns at least 1 h 55 min and stops recording no later than 2 h 5 min after power loss
3
Test the acoustic beacon
Use the manufacturer's test equipment or a certified, fully operational substitute unit.
PASS WHENBeacon works
4
Inspect overall condition and battery dates
Check the equipment is satisfactory and that beacon and power supply batteries are in date.
PASS WHENSatisfactory and in date
5
Review maintenance records
Confirm accurate VDR maintenance records are available.
PASS WHENRecords complete and accurate
6
Verify data recording and storage
Confirm the required data items are stored for the full recording period used at commissioning.
PASS WHENAll required data present for the full period
7
Examine the float-free arrangements
Check arrangements are as accepted at commissioning, with batteries, release mechanisms and other datable items in date.
PASS WHENSatisfactory and in date
8
Restore normal operation
Confirm the equipment returns to normal operation after the testing.
PASS WHENNormal operation restored
Source: MSC.1/Circ.1222/Rev.1, annex paragraph 2. The manufacturer also analyses the 12-hour log against IEC 61996 and records the interfaces checked, such as GNSS, speed, heading, audio, VHF, radar, ECDIS, AIS, rudder, engine orders, alarms, hull openings, acceleration and wind.
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Float-Free Capsule and Acoustic Beacon: What the Master Should See Checked

Expiry dates and release arrangements that decide whether the capsule can be recovered

The test checks the beacon and the reserve power battery dates, the beacon function and the float-free arrangements. For capsules approved under MSC.333(90), the examination follows MSC.1/Circ.1040/Rev.1. A fixed capsule must also be highly visible in colour, marked with retro-reflective material and fitted with an underwater location aid.

Capsule and beacon items to see checked at the annual test
ItemWhat is checkedEvidence to keep
Acoustic beacon (underwater locating aid)Functional test and battery expiry dateTest result and date in the report
Reserve power sourceBattery expiry and 2-hour behaviourTime recorded when the alarm and the stop occur
Float-free capsule releaseRelease mechanism and other datable items in dateExpiry dates, examination note
Float-free capsule examinationFor MSC.333(90) capsules, the examination follows MSC.1/Circ.1040/Rev.1Examination report
Fixed capsule markingsHighly visible colour, retro-reflective marking and underwater location aid, per MSC.333(90)Visual check and photo
Fastenings and cablingSecurity of fixings, junction boxes and cable seals (our suggestion)Photo and maintenance note
Sources: MSC.1/Circ.1222/Rev.1 and MSC.333(90). The fastenings and cabling line is our suggestion.

Sensor Inputs: Why a Silent Feed Ruins Casualty Evidence

How the manufacturer checks each interface for operation and recording during the test

The test report has a section for the interfaces checked for operation and recording, each marked yes, no or not applicable. A second section records changes or repairs to sensors, and the engineer checks the maintenance records and that any defects were rectified. The table below pairs each input with what to confirm. The typical faults come from a servicing vendor's page and are not from the regulation.

Sensor inputs: what to confirm in the recorded log
InputSourceWhat to confirmTypical fault
Position, speed and headingGNSS, speed log, headingData present throughout the 12-hour logLost sensor data or serial rate mismatch (vendor-reported)
Bridge and VHF audioBridge microphones, VHFAudio clear and continuous on all channelsMicrophone degradation (vendor-reported)
Radar and ECDISRadar, ECDIS display captureFrames recorded without gapsFrame capture out of sync (vendor-reported)
Rudder and engine ordersSteering and engine order interfacesOrders and responses logged togetherInterface mismatch after refits
Alarms and hull openingsAlarm system and door statusAlarms and door status loggedReplaced panel not reconnected
Environment and structureWind, acceleration, rolling, where fittedValues logged where equipment is fittedSensor replaced without VDR update
Interfaces from MSC.1/Circ.1222/Rev.1 report section 8. Typical faults are vendor-reported and are examples, not a complete list.

What to do after a sensor is replaced, a bridge system is refitted or software is changed

A refit can break a feed silently. After any sensor replacement or bridge system change, ask for the VDR interface to be rechecked and the maintenance record updated, and keep the entry for the next annual test. The test report asks for it, and a casualty investigation will too.

The Master's Part Before, During and After the Test

Before the test: dates, records and access for the testing engineer

Confirm the due date and window, gather the maintenance records, make sure the previous certificate and report are available, and arrange access to the bridge, the capsule locations and the reserve power supply. If the beacon or battery dates are close to expiry, order replacements before the engineer arrives.

After the test: certificate on board and findings turned into tasks

A vendor summary says the certificate of compliance, with its date and applicable standards, must be kept on board. Record any observations from the report as tasks with an owner and deadline, and diarise the next window.

After an incident: protect the recording before it is overwritten

VDRs record continuously, and the media hold a minimum retention period, so older data can be overwritten by newer recordings. Agree with the manufacturer and your company, in advance, how the data is saved after an incident and who is notified. Follow flag state and investigating authority instructions. This is our suggestion, and the exact steps depend on your recorder model.

Mistakes That Make a VDR Test Pass on Paper and Fail in a Casualty

Six gaps that leave the recorder compliant on the certificate but thin on evidence

1
Letting the test date drift
Cargo ships have a window of 3 months either side of the due date and a maximum of 18 months. Missing it puts the certificate at risk.
2
Treating the test as paperwork
The test checks reserve power, beacon, float-free arrangements and the recorded data. A signature without evidence proves nothing.
3
Not noticing a sensor swap
If a sensor is replaced or repaired, the VDR feed must be rechecked and the maintenance record updated.
4
Expired batteries and beacons
Battery and beacon dates are on the test checklist. Expired items mean a failed test.
5
No on-board certificate
Keep the Annual Performance Test Certificate or certificate of compliance on board, where it can be shown.
6
No procedure after an incident
Agree a data-save procedure with the maker and company before an incident, because recordings are continuous.

Systems That Keep VDR Test Dates, Expiries and Findings in One Place

How certificate, battery and beacon dates, test reports and tasks stay connected

A VDR test depends on dates that are easy to lose: the test window, the battery and beacon expiries, the certificate and the follow-up from the report. Marine Inspection supports certificate and equipment tracking, a dated photo repository and observations turned into tasks with owners, deadlines and evidence, as described in its dry docking guide for project work. For a Master, that means every test window and expiry is visible, and every finding has an owner.

Frequently Asked Questions About the SOLAS VDR and the Annual Performance Test

What does SOLAS require for a voyage data recorder?

SOLAS Chapter V Regulation 20 requires a VDR on passenger ships and on cargo ships of 3,000 gross tonnage and over built on or after 1 July 2002, and a simplified VDR on older cargo ships of 3,000 gross tonnage and over, according to a vendor summary of the rule. Check the regulation text and your flag state for the details that apply to your ship.

How often must the VDR annual performance test be done?

Annually. For cargo ships, MSC.1/Circ.1222/Rev.1 allows the check within 3 months either side of the due date, with a maximum interval of 18 months, subject to SOLAS I/14 extensions. Passenger ships may be tested up to 3 months before the due date, with a maximum of 15 months.

Who performs the VDR annual performance test?

The manufacturer or a person authorised by the manufacturer, according to MSC.1/Circ.1222/Rev.1. The report is due within 45 days.

How long must a VDR store data?

Under MSC.333(90), at least 48 hours on the fixed and float-free media and at least 30 days or 720 hours on the long-term medium. The fixed medium keeps data for at least two years after recording ends, and the float-free medium for at least six months.

What happens to the VDR if the ship loses power?

On loss of the main supply, MSC.333(90) requires the VDR to record bridge audio from a dedicated reserve source for 2 hours and then stop automatically. The annual test checks this behaviour.

What data does a VDR record?

Twenty items under MSC.333(90), including date and time, position, speed, heading, bridge audio, VHF audio, radar, ECDIS, echo sounder, main alarms, rudder and engine orders, hull openings, watertight and fire doors, accelerations, wind, AIS and rolling, with some recorded only where equipment is fitted.

Does the annual test check the float-free capsule?

Yes. The test checks that the float-free arrangements are as accepted at commissioning and that batteries, release mechanisms and other datable items are in date. For capsules approved under MSC.333(90) the examination follows MSC.1/Circ.1040/Rev.1.
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