I don't know the answer to that, but our pontoon is rated for 13 people (over a dozen) and btw we fish on it, has two livewells working; (one more not hooked up and right now used for storage) several rod holders on board , and at least a dozen rods rigged right now ...
I'll admit we've never had a dozen people on it but IF we had it would not be "legally overloaded" FWIW
It's my guess that F&W already KNOW what person capacity that most pontoons are rated for, and most who own pontoons make sure to SHOW (out in the open) enough PFD for each person onboard....




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