It all depends on how many vessels you own and operate under Subchapter M. There is  a 4-year phase in period from July of 2018 until July of 2022, by which ALL towing vessels that  fall under Subchapter M, must hold a valid COI. For example, IF you operate ONE towing  vessel (subject to Subchapter M), you will need to hold a COI by July 20, 2020. ​ Please contact  Maritime Safety Management Services and we can discuss your COI dates and options!!