JWLA-035 Expands the Black Sea JWC Listed Area Across the Basin
16 Sept 2026· Published 19 Sept 2026
Key judgement
JWLA-035 materially expands the geographic scope of the Black Sea Listed Area; the security picture on the water did not change, but the insurance-market boundary did, and the consequences are policy-specific.
The Joint War Committee's JWLA-035 (16 September 2026) replaces the previous bounded Black Sea Listed Area with a basin-wide definition, listing almost the entire Black Sea and Sea of Azov except the territorial waters of Türkiye, Bulgaria, Romania and Georgia. Russian and Ukrainian territorial waters remain listed.
Situation
On 16 September 2026 the Joint War Committee, a joint Lloyd's Market Association and International Underwriting Association body, issued circular JWLA-035, amending the Black Sea entry to 'Black Sea excluding territorial waters of adjoining countries other than Russia and Ukraine.' The previous bounded coordinate area is replaced by a basin-wide definition; the Sea of Azov and the inland-waters provisions for Ukraine, Russia and Belarus are unchanged.
What has changed
Listed Area treatment now begins once a vessel leaves the territorial sea of an adjoining state, rather than on reaching the former bounded polygon further north or east. Trident geospatial analysis, approximate, puts the change at roughly 170,000 to 410,000 square kilometres, about 2.4 times the previous area; these are Trident estimates, not JWC or LMA figures.
Operational relevance
For some Black Sea voyages the point of entry into the Listed Area moves materially earlier. The Joint War Committee lists areas but does not set premiums: a listing triggers notification and negotiation of terms under the policy, not an automatic surcharge. Excluded territorial waters are outside this definition, which is not a statement about their safety.
Trident assessment
The consequence for a specific vessel and voyage depends on the route, the policy wording and the charterparty, and on current operational Black Sea risk, and should be assessed case by case rather than from the listing alone.
What to watch
Insurer implementation notices and effective dates (for example Alandia from 00:01 BST on 24 September 2026), any further Joint War Committee revisions, and changes in operational Black Sea risk conditions.
Related analysis
War Risk Analysis · 19 September 2026
JWLA-035: Black Sea War Risk Listed Area Expands Across the Basin
Read the analysisSource
Joint War Committee circular JWLA-035 and open-source insurance material
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