The absence of a clause about “vessels not subject to registration" - do you need rights for everything?
According to paragraph 14 of Order 263 of 05/27/2014 (now defunct), the result of the provision of public services is: “the applicant receives the right to operate small vessels used for non-commercial purposes and subject to registration in the register of small vessels,” which is a direct reference to the 36th Federal Law.
Order 565 of 08/15/2021 does not contain such a clarification. It turns out that certification is carried out both for vessels that are subject to registration and not. What follows from this and whether it follows? And who knows...! But the lack of this clarification is alarming - “This is “well, well, for a reason...!”, although it is possible that an insignificant part of the text was simply abolished.
There are many innovations and, as with every new document, with its own changes and additions to the existing order, they are perceived with hostility. Yes, many of them are significant and meaningless, some are simply meaningless, and for some I want to knock the authors on the head and ask if something has been clarified in it.… In any case, everything worked and will continue to work. We'll see how.
All this is by no means smooth even on paper, and only time and decisions of individual ranks will show how it will work live. We will keep you informed and promptly inform you about the changes.
