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What is an acknowledgement of compliance?

An acknowledgement of compliance (AoC) is a declaration we issue to express our confidence that petroleum operations can be pursued by a mobile facility in compliance with the regulations.

We base this decision on information provided in a separate AoC application about the technical condition of the facility and the applicant’s organisation and safety management systems.

These details are verified by us through selected supervisory activities and other administrative routines.

An AoC is only awarded after all safety-critical nonconformities have been rectified, and the facility must also have secured maritime certificates from the relevant flag state.     

The facility’s owner is responsible for ensuring that its organisation and management, as well as the unit’s technical condition, comply with the regulations at all times.

We have opportunities to verify that this is the case, not least by conducting audits.

The purpose of the AoC scheme is to clarify responsibility, make the consent process more efficient and provide greater predictability for the players in the industry.

Facilities requiring an AoC
All mobile facilities entered in a national ship register must have an AoC in order to participate in petroleum operations on the Norwegian continental shelf.

An AoC is mandatory for:

  • drilling units
  • accommodation units (flotels)
  • floating production, storage and offloading (FPSO) units
  • well intervention units.

Exceptions include mobile facilities operated directly by the operator and storage ships. These do not need an AoC, only a consent.

Use in consent applications
An AoC forms part of the documentation submitted when the government is to consider a later consent application from the operator involving use of the facility.

This has particular significance for the facility-specific part of a consent application – in other words, the facility’s technical condition and its owner’s organisation and management system.

Application for an AoC
The AoC applicant will be the owner of the facility or the entity responsible for its day-to-day operation.

The normal case-processing time is three months for facilities to be used for drilling, assuming that the application has the requisite content and quality. For facilities intended for other activities, the case processing time may be longer. For an application for an extended AoC, where a facility is to be used for a new type of activity that requires a new AoC to be issued, the case-processing time may be shorter than three months.

The estimated case-processing time presupposes that the applicant has performed adequate measurements of compliance with relevant regulatory requirements, with the requisite analyses and checks. Complete non-conformity lists must be available, with references to the regulations.

It is fully possible for an operator to request consent for an activity involving use of a mobile facility while AoC processing for that facility is in progress.       

Non-transferability on sale
An AoC is the property of the applicant, and cannot be transferred to others in the event of a possible sale of the facility. The new owner must accordingly submit a new AoC application.

Collaboration with other regulators
We collaborate with other regulators in connection with an AoC. These include the Norwegian Maritime Authority (NMA), which provides technical maritime expertise.

The work undertaken by the authorities for the AoC will be invoiced to the applicant at the hourly/daily rates as dictated by the regulations relating to reimbursement of expenses for the auditing of safety, the working environment and resource management in the petroleum activity, laid down by Royal Decree no. 652 of 27 June 1997.

Regulatory provisions concerning the AoC are set out in section 25 of the framework regulations.

AoC guidelines withdrawn
Our 2004 guidelines for applying for an AoC, updated in 2011, have been withdrawn since most of the content is covered in the current HSE regulations.

The Handbook for Acknowledgement of Compliance (AoC), Revision 05, August 2015, cf. download below, contains an overview of the AoC application process and can be used as a recognized norm in this respect, cf. the guidelines to the framework regulations section 25 on application  for acknowledgement of compliance for certain offshore mobile facilities.