JWLA-035: Black Sea War Risk Listed Area Expands Across the Basin

The map above sets the two definitions side by side. On the left, the previous Listed Area covered the Sea of Azov and the northern and central Black Sea north of the prior boundary line; the southern basin off the Türkiye coast sat outside it. On the right, JWLA-035 lists almost the entire basin, leaving out only a roughly twelve nautical mile territorial belt along the coasts of Türkiye, Bulgaria, Romania and Georgia.

Trident geospatial analysis, approximate and not a Joint War Committee or Lloyd's Market Association figure, indicates the following order of magnitude. The previous bounded area, the Sea of Azov of about 39,000 square kilometres plus the enclosed northern and central Black Sea, was on the order of 170,000 square kilometres. The new area, the Black Sea of about 436,000 square kilometres and the Sea of Azov, less the excluded territorial belts of the four states, is on the order of 410,000 square kilometres. That is an expansion of roughly 2.4 times. These are Trident estimates using published basin areas and a twelve nautical mile territorial-sea width, and should be read as indicative rather than precise.

Outside the Listed Area are the territorial waters, to about twelve nautical miles, of Türkiye, Bulgaria, Romania and Georgia. This is a definitional exclusion. It is not a statement that those waters are safe, low risk or free of war risk; it means only that they fall outside this particular Listed Area.

Listed are the Sea of Azov, the Black Sea outside those four territorial belts, and the territorial waters of Russia and Ukraine, together with the specified inland waters of Ukraine, Russia and Belarus. A vessel can therefore leave the excluded territorial waters of an adjoining state and enter the Listed Area while still well away from Russian or Ukrainian territorial waters.

The change moves the geographic point at which Listed Area treatment becomes relevant for some voyages. Under the previous definition a vessel could cross much of the southern and central Black Sea before entering the listed polygon. Under JWLA-035 the listed water begins once a vessel leaves the territorial sea of an adjoining state.

Consider a departure from the Bosphorus. A passage to Constanta, Odesa, Novorossiysk or Batumi now enters the Listed Area shortly after clearing Türkiye's territorial sea, rather than only on reaching the former bounded area further north or east. The exact point, and whether it changes anything for a given ship, depends on the routeing and, for insurance, on the specific policy. Do not assume a Listed Area consequence for a particular voyage without checking the actual cover.

A Joint War Committee listing is often misread as an automatic surcharge. It is not. The circular states that the application of the list to individual contracts is a matter for specific negotiation. The Joint War Committee identifies areas of perceived enhanced risk; it does not set rates. Rating is negotiated between underwriter and broker or assured.

What a listing typically triggers, under standard war-risk terms such as the navigational limitations clause, is a set of contractual mechanics rather than a fixed charge: notice to underwriters before entering, agreement of any amended terms and any additional premium that may be required, a duty to declare breaches, and a seven-day notice of cancellation and reinstatement mechanism when the list is revised. Whether an additional premium applies, and how much, depends on the policy and the negotiation. Not every vessel entering the area automatically pays an additional premium.

JWLA-035 was published on 16 September 2026. That is the circular date, not a universal effective date for cover. Insurers implement revised Listed Areas through their own policy notice mechanisms, and the effective date varies by insurer. For example, Alandia has stated that its revised Listed Areas take effect on affected war-risk policies from 00:01 BST on 24 September 2026, following its notice process; its equivalent notice for the previous circular used a different date. Other insurers may differ.

The practical instruction for operators is straightforward: check the actual policy and the relevant underwriter or broker notice for the date and terms that apply to your cover, rather than assuming a single market date.

Before a Black Sea voyage, a short checklist helps convert the change into a decision.

1. Confirm whether the intended route enters the revised JWLA-035 Listed Area.

2. Check the applicable hull war policy wording, including any navigational limitations and notification clauses.

3. Confirm notification requirements with the broker or underwriter before entering the area.

4. Establish whether any additional premium or revised terms apply, and on what basis.

5. Check the effective date of the relevant insurer's implementation of JWLA-035.

6. Review the charterparty allocation of war-risk costs and rights, including any war-risk or trading-limits clauses, where relevant.

7. Reassess routeing against current maritime-security conditions in the Black Sea, not only the insurance position.

These are practical prompts, not legal advice; the terms that bind are those in the policy and the charterparty.

JWLA-035 is a definitional change with practical reach. By replacing a bounded polygon with a basin-wide definition, it brings a much larger area of the Black Sea within Listed Area treatment and moves the entry point earlier on many voyages. The security picture on the water did not change on 16 September; what changed is the insurance-market boundary against which voyages are notified, negotiated and priced.

The right response is specific, not general. The consequence for a particular vessel and voyage turns on the route, the policy wording and the charterparty, and on the current operational risk along the intended track. Trident supports that analysis through Black Sea voyage vulnerability assessment and high-risk area transit planning, and, where a matter turns on whether a voyage faced real danger, through maritime-security expert evidence.

Primary: Joint War Committee circular JWLA-035, 16 September 2026, published on the Lloyd's Market Association and International Underwriting Association websites (Lloyd's Market Association, Joint War Committee; IUA Joint War Committee Risk List).

The previous bounded Black Sea definition and the navigational-limitations mechanics are drawn from the standing Listed Areas and clause wording as consolidated by marine insurers, for example The Swedish Club Listed Areas. Insurer implementation example: Alandia, JWLA-035 notice. Basin areas are from standard references (Black Sea about 436,400 square kilometres; Sea of Azov about 39,000 square kilometres). This Insight is analysis and does not constitute legal, insurance or financial advice.