One of the main tasks of the Sub-committee on Ship Design and Construction (SDC) of the International Maritime Organization (IMO) is development of the 2nd Generation Intact Stability Criteria. The paper presents the framework and the approach agreed by the Sub-committee. The framework bases on the concept of stability failure and vulnerability assessment. However, the criteria, standards and regulations developed so far have weaknesses that may prevent some IMO Member States from adoption of the regulations on the Maritime Safety Committee (MSC) level. The paper presents some of the weaknesses that are the most important from the Author’s point of view. Awareness of the weaknesses may facilitate the future work of the Sub-committee and its working groups.