Cyber Regulatory Landscape and Industry Responses in the Shipbuilding and Maritime Sector – Part 6: Structural Causes of Supplier Documentation Variability and the Direction the Industry Must Take

The question “Why is the quality of E27 documents so poor?” has become one of the most frequently raised concerns across shipyards, classification societies, and vessel owners. Many stakeholders express frustration: “Supplier documentation is too inconsistent,” or “Even when we ask for E27, every supplier delivers something different.”

At first glance, it may seem easy to attribute this problem to supplier capability. But field observations across multiple shipyards, integrators, and system vendors reveal a different reality: the variability is not caused by supplier skill gaps but by structural gaps in the maritime industry itself.

Below is a detailed examination of why E27 documentation varies so widely and what the industry must do to solve it.


E27 Variability Is Not a Supplier Capability Problem

Across shipyards and owners, the assumption is common:
“Suppliers are not trained enough.”
“Their documentation quality is poor.”

However, the truth uncovered in actual marine projects points to four structural causes:

  1. There are no unified standards.

  2. Roles are unclear.

  3. Schedules do not allocate time for E27 work.

  4. No integrating authority ensures alignment across all documents.

Although E27 exists as a regulation (UR E27), there is no operational industry standard for how to implement or interpret it.

Therefore, the issue is not that suppliers are unwilling or incapable—they are operating in a system that does not allow them to succeed consistently.

1. Lack of Standards: Suppliers Do Not Know What Level Is Expected

One of the most common questions suppliers ask is:

“What level of detail do you actually want in this document?”

Without an Owner Policy or shipyard-specific guidance, suppliers have no choice but to:

  • Reuse parts of existing IEC documents

  • Paste generic corporate technical descriptions

  • Guess what class societies might want

  • Draft documents based on the engineer’s personal experience

This naturally produces massive variability.

2. Lack of Expertise: E27 Is an Architecture Document, Not a Cybersecurity Note

A widespread misunderstanding is that E27 is a cybersecurity declaration or a compliance report.
In reality, E27 requires the supplier to articulate a system-level architectural description, including:

  • Network boundaries

  • Interface structure

  • Data flows

  • Control scenarios

  • Identified risks

  • Security functions

  • Patch/log/account management frameworks

Over 90% of suppliers have never written this type of document before, because traditional automation and equipment vendors historically document functionality—not architecture.

When an entirely new document type is suddenly required without training, variability is inevitable.

3. Lack of Time: E27 Is Treated as “Additional Work”

Supplier engineers already carry major responsibilities:

  • Proposal development

  • System engineering

  • FAT preparation

  • Technical drawing generation

  • Class and owner responses

  • Sea trial and commissioning support

E27 is added on top of all existing work, without:

  • Additional budget

  • Additional schedule

  • Additional resources

The result is predictable: suppliers submit the minimum viable document, not because they lack skill but because the industry does not allocate resources for E27 work.

4. Lack of an Industry Integrator: Documents Do Not Align

Shipyard engineering documents, supplier E27 submissions, SI network diagrams, and class expectations are all created independently.

Without a central integrator (e.g., CRSI):

  • Suppliers follow supplier logic

  • Shipyards follow shipyard conventions

  • Class societies evaluate based on class rules

  • SIs design based on their network philosophy

During SCARP(E26), these documents must be integrated—
and that is where the conflicts explode.

This conflict is not caused by supplier shortcomings but by the absence of a harmonizing authority.

E27 Variability Is an Industry-Made Problem

In short, the root cause of variability is a set of structural absences, including:

  • No Owner Policy

  • No industry standard

  • No CRSI oversight

  • No design-based documentation model

  • No supplier education

  • No governance for integration

The issue is the structure, not the supplier.

Industry-Level Solutions: What Must Change

Suppliers alone cannot fix this problem.
The maritime industry must restructure how E27 documentation is governed.

Solution 1 — Establish Owner Policy

Owners must provide:

  • Clear documentation templates

  • Architecture and design criteria

  • RA/RM methodology

  • Zone & conduit rules

  • Account/log/patch policies

  • Class alignment guidelines

Standards eliminate ambiguity and reduce variability dramatically.

Solution 2 — CRSI Must Supervise and Harmonize Documentation

CRSI should perform quality assurance by:

  • Correcting mismatches

  • Redefining boundaries

  • Harmonizing interfaces

  • Aligning risk assessment standards

  • Ensuring network topology consistency

This is not “policing suppliers”—
it is helping suppliers succeed.

Solution 3 — Supplier Training and Manuals

Most suppliers still do not fully understand:

  • What E27 actually requires

  • How deep the description must go

  • What technical terminology is expected

Training, sample documents, and clear guidance are essential.

Solution 4 — Industry-Wide Standardization

Long-term improvement requires:

  • Common templates

  • Common checklists

  • Shared quality benchmarks

  • Frameworks aligned with SCARP(E26)

Without standardization, variability will persist indefinitely.

Conclusion: E27 Quality Reflects Industry Maturity, Not Supplier Skill

The variability in E27 documentation is not a supplier problem—it is an industry problem.

But the path forward is clear:

  • Owner Policy

  • CRSI

  • Standard templates

  • Supplier education

  • Governance for alignment

  • SCARP-based frameworks

With these structures in place, documentation variability will decrease sharply, and the quality of SCARP(E26) will improve significantly.

The Shipjobs series will continue sharing practical strategies to help the industry evolve toward this direction.




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