Whalewatching has grown into a major tourist activity, yet there are many concerns about its negative impacts. This has stimulated the development of a large number of codes of conduct. This paper presents the results of a manifest content analysis of 58 such codes from around the world. The analysis revealed considerable variation among them, not least in terms of the detail of the various guidelines they contain. This variation is not considered to be propitious for the sustainable development of whalewatching, particularly given how little is currently known about the nature of human-cetacean interactions and the complex and highly fragmented regulatory context in which this activity tends to take place.