Learning objectives
- Describe the structure of the five titles of MLC 2006 and the four levels of the text, distinguishing binding Standards from Guidelines.
- Identify which ships and which people the Convention covers, and what a substantial equivalence is.
- Understand the function of the Declaration of Maritime Labour Compliance (DMLC), Parts I and II.
- Correctly manage a complaint according to the procedure set out in the Convention.
- Apply the minimum hours of rest requirements and understand their relationship with STCW.
- Recognise the typical areas checked in an MLC inspection, including within PSC.
- Reconstruct the five rounds of amendments to the Code and the tacit acceptance mechanism that governs them.
- Contribute to a welfare culture that goes beyond mere formal compliance.
Genesis and structure of MLC 2006
Module objectiveUnderstand why MLC 2006 consolidates maritime labour instruments, recognise its five Titles and connect substantive rights with compliance and enforcement.
The Maritime Labour Convention 2006 was adopted by the International Labour Organization (ILO) on 23 February 2006, at the 94th (Maritime) Session of the International Labour Conference, and entered into force on 20 August 2013, twelve months after the double threshold was met: thirty ratifications representing at least 33 per cent of world gross tonnage. It consolidates and updates 68 earlier instruments — 37 Conventions and 31 Recommendations adopted from 1920 onwards — into a single text, which is why it is described as the «fourth pillar» of international maritime regulation alongside SOLAS, MARPOL and STCW. It is today ratified by 113 Member States, representing 96.6 per cent of world gross tonnage.
| Title | Content |
|---|---|
| 1 | Minimum requirements to work on board (minimum age, medical certificate, training, recruitment) |
| 2 | Conditions of employment (contract, pay, leave, repatriation, minimum manning) |
| 3 | Accommodation, recreational facilities, food and catering |
| 4 | Health protection, medical care, welfare and social security |
| 5 | Compliance and enforcement (inspections, certification, complaints) |
Table 1.1 — The five titles of MLC 2006.
MLC 2006 does not only introduce substantive rights for seafarers, but also a verification and enforcement system (Title 5) that makes it, in practice, an instrument with concrete and verifiable effects at every port call, not merely a declaration of principles.
Key takeaways
- MLC 2006 combines maritime labour rights and mechanisms for verifying them.
- The five Titles move from individual eligibility to compliance and enforcement.
- Ratification and tonnage coverage show global reach but do not replace flag-State implementation checks.
How the Convention is built, and which ships it covers
Module objectiveDistinguish Articles, Regulations, Standards and Guidelines and determine the persons, ships, responsible shipowner and permitted flexibility.
The previous module describes the five Titles. But the MLC is not read by Title: it is read by level. It is the only maritime convention in which the same subject appears three times, in three forms of differing legal force — and without that architecture you cannot read a DMLC Part I, nor understand why two flags implement the same obligation differently.
The four levels of the text
| Level | What it contains | Legal force |
|---|---|---|
| Articles | General obligations, definitions, scope, entry into force, amendment procedure | Binding. Amendable only by a new Conference |
| Regulations | The objective of each subject, in summary form | Binding |
| Code, Part A Standards | The mandatory detail: figures, deadlines, procedures | Binding. To be implemented in national law |
| Code, Part B Guidelines | Suggestions on how to implement Part A | Not binding, but to be given «due consideration» (Art. VI.2) |
Table 2.1 — The four levels of the text and their legal force.
Regulations and Code are arranged under the five Titles with parallel numbering: Regulation 2.5 on repatriation has Standard A2.5 and Guideline B2.5. That is why references read at a glance — the letter tells you whether it is mandatory, the number tells you what it is about.
Substantial equivalence, and why it must be read before every inspection
A State may implement a Part A Standard through a measure different from the one described, provided it satisfies itself that the measure is conducive to the full achievement of the general object and purpose of the provision and gives effect to it. This is substantial equivalence; it must be declared in DMLC Part I, and it must be read before every inspection: it is the reason the same ship, with the same crew, may be compliant under one flag and not under another. A deficiency raised in PSC is very often defended precisely there.
Who is a seafarer
The definition in Article II.1(f) is the broadest in maritime law: any person who is employed or engaged or works in any capacity on board a ship to which the Convention applies. It requires no crew rating, no STCW qualification, no employment relationship with the shipowner. It therefore takes in hotel, catering and entertainment staff and concessionaires on cruise ships, technicians embarked for a particular job, and catering personnel. In case of doubt the competent authority decides, after consultation with the shipowners’ and seafarers’ organisations (Art. II.3).
Who is the shipowner
Article II.1(j) defines the shipowner as the owner or another organisation or person — the manager, the agent, the bareboat charterer — who has assumed responsibility for the operation of the ship and who, on assuming it, has agreed to take over the duties and responsibilities imposed on shipowners by the Convention, regardless of whether any other organisation or person fulfils certain of them on their behalf. This is the central point for ship management: MLC responsibility follows whoever assumed the operation, and cannot be divided up by contract.
Which ships it covers
| It applies to | It does not apply to (Art. II.4) |
|---|---|
| All ships, public or private, ordinarily engaged in commercial activities, of any tonnage | Ships engaged in fishing or similar pursuits |
| Ships on international voyages and ships in domestic trade, subject to the exclusions opposite | Ships of traditional build, such as dhows and junks |
| Ships navigating exclusively in inland waters or in sheltered waters, or in areas where port regulations apply | |
| Warships and naval auxiliaries |
Table 2.2 — The scope of application of the Convention.
The 500 GT threshold determines, in the cases specified by Regulation 5.1.3, whether a Maritime Labour Certificate and DMLC are mandatory; it is not the Convention’s general application threshold. A 400 GT ship engaged on international voyages must therefore comply with the applicable MLC requirements even though mandatory certification is not required, unless the shipowner requests voluntary certification. For ships below 200 GT not engaged on international voyages, Article II.6 permits the flag State, after consultation, limited flexibility regarding certain details of the Code where application would not be reasonable or practicable and the matter is otherwise regulated. Flag-State law and the applicable national implementation must therefore always be checked.
Key takeaways
- Part A Standards are binding; Part B Guidelines must be given due consideration.
- The seafarer definition is broad, but doubtful cases are determined by the competent authority after consultation.
- Application and certification are different; Article II.6 provides only limited flexibility below 200 GT.
Certification: MLC Certificate and DMLC
Module objectiveExplain when the certificate and DMLC are required, distinguish Parts I and II and verify the five-year certification cycle.
Ships of 500 GT or over engaged in international voyages, or flying the flag of one country and operating from a port or between ports in another country, must hold a Maritime Labour Certificate and a Declaration of Maritime Labour Compliance (DMLC), the latter structured in two parts with distinct functions (Regulation 5.1.3.1). Below 500 GT certification is not mandatory — but the applicable MLC requirements continue to apply, subject to the limited flexibility under Article II.6, and that is the distinction most often misunderstood.
| Part | Content and responsible party |
|---|---|
| Part I | Drawn up by the competent authority of the flag State. It lists the national requirements implementing the sixteen items of Appendix A5-I, and identifies any substantial equivalences adopted and exemptions granted |
| Part II | Drawn up by the shipowner and approved by the competent authority or the recognised organisation. It describes the measures adopted to ensure ongoing compliance between inspections |
Table 3.1 — The two parts of the DMLC.
Validity, intermediate inspection and extension
The certificate has a maximum validity of five years (Standard A5.1.3.1) and is subject to an intermediate inspection which, in most cases, falls between the second and third anniversary dates of the certificate (A5.1.3.2): once the inspection is passed, the certificate is endorsed. The 2016 amendments added an extension of up to five months for cases where the renewal inspection has been passed but the new certificate cannot immediately be issued and made available on board; the replacement certificate runs from the renewal-inspection date (A5.1.3.4). Certificate and DMLC must be kept on board and posted in a conspicuous place accessible to seafarers (A5.1.3.12).
While Part I is largely standardised on a national basis, Part II reflects the real commitment of the individual company: it describes how, in concrete terms, the shipowner verifies that MLC conditions continue to be met in daily practice, not only at the time of initial certification.
Key takeaways
- Part I records national requirements, equivalences and exemptions; Part II describes the shipowner’s continuing measures.
- The certificate is valid for a maximum of five years and requires an intermediate inspection.
- The five-month extension is conditional on a completed renewal inspection and is not an ordinary extension.
Conditions of employment: contract and pay
Module objectiveIdentify SEA content, apply pay, leave and repatriation rules and distinguish a recommended wage from a binding obligation.
Title 2 of the Convention governs the contractual and financial aspects of the maritime employment relationship, with minimum requirements that every seafarer employment agreement must meet.
Essential elements of the Seafarer Employment Agreement (SEA)
- Duration of employment and terms of early termination.
- Remuneration, payable at no greater than monthly intervals (Standard A2.2.1), with a monthly account and the possibility of an allotment, that is a periodic transfer of part of the pay to family members (A2.2.2-4).
- Entitlement to paid annual leave: the minimum is 2.5 calendar days per month of employment, that is thirty days a year (Standard A2.4.2). Any agreement to forgo it is prohibited, save in cases expressly provided for by the competent authority (A2.4.3).
- Entitlement to repatriation at the shipowner's expense (expiry of the agreement, illness or injury, shipwreck, insolvency or cessation of the shipowner's business, deviation of the ship to a war zone). The maximum period of continuous service on board after which the entitlement arises is less than twelve months (Standard A2.5.1.2(b)), and the shipowner may not recover the cost from wages save where the seafarer is found in serious default of employment obligations under national law (A2.5.1.3).
The ILO wage benchmark
The Convention sets no mandatory minimum wage: it is recommended by Guideline B2.2.4, and the figure is negotiated by the Subcommittee on Wages of Seafarers of the ILO Joint Maritime Commission. The benchmark for the able seafarer rises to USD 690 from 1 January 2026, 704 from 1 January 2027 and 715 from 1 January 2028, up from 673. It is not binding in itself — it applies where the flag State adopts it or the collective agreement incorporates it — but it is the figure around which bargaining in fact revolves.
The right to repatriation, including the circumstances in which the shipowner remains liable regardless (for example in the event of ship abandonment), is one of the most practically significant aspects of MLC, and has been strengthened through amendments subsequent to the original 2006 text, precisely in response to cases of crews left without assistance.
Key takeaways
- Pay, monthly accounts, leave and repatriation are Title 2 rights implemented through applicable law.
- The maximum service period after which repatriation entitlement arises must be less than twelve months.
- The ILO able-seafarer minimum is a recommendation unless implemented by law or agreement.
Hours of work and rest
Module objectiveApply MLC limits, recognise rest-splitting constraints and assess MLC and STCW exceptions separately.
Management of working and rest hours is one of the most heavily checked areas in MLC and PSC inspections, and one of the most delicate to manage realistically on board, especially on ships with reduced manning.
The two regimes, and the figures that define them
Standard A2.3 leaves the flag State to choose between two alternative regimes. Which one applies must be checked in DMLC Part I, because the two are not equivalent.
| Regime | Limits |
|---|---|
| Minimum hours of rest | No less than 10 hours in any 24-hour period and 77 hours in any seven-day period |
| Maximum hours of work | No more than 14 hours in any 24-hour period and 72 hours in any seven-day period |
Table 5.1 — The two alternative regimes of Standard A2.3.5.
Within the hours-of-rest regime three further constraints of form apply, and it is on these that deficiencies concentrate: rest may be divided into no more than two periods, one of which of at least six hours, and the interval between consecutive periods of rest may not exceed fourteen hours.
Why «aligned with STCW» is only half true
The figures do coincide: the STCW Code, section A-VIII/1, also requires ten hours in twenty-four and seventy-seven in seven days, with the same constraints of form. What differs is the exceptions — and that is where the disputes arise.
| Instrument | How exceptions work |
|---|---|
| STCW Code section A-VIII/1.9 | The Administration may allow exceptions: weekly rest may fall to 70 hours, but for no more than two consecutive weeks, and the interval between two exception periods may not be less than twice the duration of the exception. Rest may be divided into three periods — one of at least six hours, the others of at least one hour — for no more than two 24-hour periods in any seven days |
| MLC 2006 Standard A2.3.13 | The competent authority may permit exceptions through national laws or regulations or authorised or registered collective agreements. As far as possible, exceptions must follow the Standard and may take account of more frequent or longer leave periods or compensatory leave. An STCW exception does not automatically establish MLC compliance: the flag-State legal basis and any applicable collective agreement must be checked |
Table 5.2 — The two regimes of exceptions.
That is the practical consequence, and it still surprises many. A watchkeeping officer working under a duly authorised STCW exception, at seventy hours of weekly rest for two weeks, complies with STCW but falls outside the MLC’s seventy-seven hours — unless that same derogation is also covered on the MLC side, that is, under the applicable MLC regime, which may include compensatory leave. In inspection the two are checked by different people against different lists. It pays to know which of the two applies before the inspector asks.
Recording of hours
The Convention requires accurate records to be kept of each seafarer's working or rest hours, verifiable at inspection. A systematic discrepancy between the records and actual practice (so-called «fictitious hours») is one of the most frequent and most serious deficiencies found by PSC inspectors in this area.
Rest-hour records that are formally correct but do not correspond to actual operational practice expose the company to a double risk: on one hand detention if discovered, and on the other, above all, unmanaged real crew fatigue, with direct consequences for operational safety.
Key takeaways
- The flag chooses a maximum-work or minimum-rest regime; the applicable regime must be identified.
- The rest regime uses 10 hours in 24 and 77 in seven days, with specified splitting constraints.
- An STCW exception does not automatically establish MLC compliance: the applicable flag-State basis and collective regime must also be verified.
Accommodation, recreation and catering
Module objectiveDistinguish transitional accommodation construction requirements from operational duties for food, water, hygiene and cooks.
Title 3 of the Convention sets detailed requirements on accommodation, recreational spaces and catering on board, recognising that the crew's daily quality of life directly affects wellbeing and, indirectly, operational safety.
Typical regulated areas
| Area | Typical requirements |
|---|---|
| Accommodation | Minimum cabin dimensions, lighting, ventilation, sound insulation |
| Recreational spaces | Common areas for leisure time, access to personal communications |
| Catering | Quality and variety of food, hygiene requirements for the galley, qualification of catering staff |
Table 6.1 — Typical areas regulated by Title 3 of MLC 2006.
Accommodation construction requirements: which date matters
Standard A3.1.2 provides that Code requirements relating to the ship’s construction and equipment apply to ships constructed on or after the date on which the Convention enters into force for the flag State. Earlier ships remain subject, where relevant, to ILO Conventions Nos 92 and 133 or applicable national law. This transitional rule does not disapply the other Title 3 obligations: food, drinking water, hygiene, cook qualifications and inspections of supplies must still be verified. Before assessing a construction-related measurement, check the construction date, the Convention’s entry into force for the flag and any national requirements.
Food, water and the ship’s cook
- Food and drinking water are supplied free of charge for the whole period of engagement, of appropriate quantity, nutritional value, quality and variety, having regard to the number of seafarers on board, their religious requirements and their cultural practices (Standard A3.2.2).
- The ship’s cook must be trained and qualified for the post (A3.2.3). On ships with a prescribed manning of fewer than ten, the competent authority may not require a fully qualified cook, but whoever cooks must still have received training in food and personal hygiene and food handling and storage (A3.2.6).
- No seafarer under the age of eighteen may be employed as ship’s cook (A3.2.8).
- Food stores and drinking water must be inspected at frequent and documented intervals, by or under the authority of the master (A3.2.7). The 2022 amendments tightened precisely this check.
The quality and variety of food on board is often underestimated as a wellbeing factor, but it directly affects crew morale and retention, as well as being a frequently checked inspection area. Investing in this area often produces a return disproportionate to its relatively modest cost.
Key takeaways
- Construction date matters for Code requirements relating to accommodation construction and equipment.
- The transitional rule does not suspend food, water, hygiene or supply-inspection duties.
- Crew numbers, religious requirements and cultural practices affect catering adequacy.
Medical care and social security
Module objectiveAssess medical care, shipowner liability, doctor carriage requirements and minimum social-security protection.
Title 4 requires every seafarer to have access to adequate medical care on board and ashore, and governs the shipowner's liability in the event of illness or injury, as well as setting minimum social security coverage requirements.
Shipowner's liability in the event of illness or injury
- Coverage of medical expenses — treatment, medicines, board and lodging away from home — until recovery or until the sickness or incapacity has been declared of a permanent character. National law may limit this liability to a period not less than sixteen weeks from the day of the injury or the commencement of the sickness (Standard A4.2.2): that is the figure actually negotiated.
- Continuation of remuneration, in whole or in part, while the sick or injured seafarer is on board and until repatriation; after repatriation, within the limits set by national law (Standard A4.2.1(c)-(d)).
- Repatriation at the shipowner's expense if unable to continue serving on board for health reasons.
The ship’s doctor
Ships carrying 100 or more persons and ordinarily engaged on international voyages of more than three days’ duration must carry a qualified medical doctor (Standard A4.1.4(b)). On all others, at least one seafarer must be placed in charge of medical care and the administering of medicine, trained in accordance with STCW.
The nine branches of social security
Standard A4.5.1 lists nine branches: medical care, sickness benefit, unemployment benefit, old-age benefit, employment injury benefit, family benefit, maternity benefit, invalidity benefit and survivors’ benefit. At the time of ratification each State must provide at least three of them (A4.5.2), and Guideline B4.5 recommends that these include medical care, sickness benefit and employment injury benefit. This is why the effective coverage of a multinational crew depends on each seafarer’s State of residence more than on the flag of the ship.
Growing attention to crew psychological wellbeing, driven also by the prolonged isolation typical of life on board, is broadening the practical interpretation of medical care obligations beyond the purely physical component, an area of growing attention in more recent inspections.
Key takeaways
- National law may limit shipowner sickness or injury liability, but not below sixteen weeks.
- A doctor is required when the ship carries one hundred or more persons on international voyages normally exceeding three days.
- The Convention lists nine social-security branches and requires at least three on ratification.
The onboard complaint-handling system
Module objectiveHandle MLC complaints while ensuring accessibility, representation, non-retaliation and direct access to external authorities.
The Convention requires every ship to have a clear and effective procedure for handling seafarers' complaints, with an escalation path that guarantees the possibility of approaching external authorities if the complaint is not resolved on board.
The principles of an effective procedure
- Accessibility: the seafarer must know the procedure and how to invoke it, in a language they understand.
- Non-retaliation: no negative consequences for anyone filing a complaint in good faith.
- Clear escalation: the Convention sets out a defined path — head of department or superior officer → the master, who deals with the matter personally → the shipowner ashore → the competent authority of the flag State (Guideline B5.1.5).
This is the safeguard that makes the procedure effective, and the one missing from most shipboard manuals. Standard A5.1.5 gives the seafarer the right to complain directly to the master and to complain directly to the appropriate external authorities — the flag administration, a PSC officer in the port of call, their own union — bypassing the whole chain, at any point. The seafarer is also entitled to be accompanied or represented, and any form of victimisation is prohibited and penalised. Each seafarer must be given a copy of the procedure, with the contact details of the flag authority and the name of a person on board who can provide impartial advice in confidence. Note, finally, that the DPA is a creature of the ISM Code, not of the MLC: nothing prevents a company from designating them as the point of contact, but the Convention does not require it.
As already seen for safety reporting, a consistently zero number of MLC complaints may genuinely reflect an excellent working environment, or a widespread fear of reporting problems. Distinguishing between the two situations requires direct attention, not just reading the aggregate figure.
Key takeaways
- The internal chain is an organisational route, not a mandatory exhaustion requirement.
- A seafarer may complain directly to the master or appropriate external authorities.
- Procedure copies, correct contacts, confidential advice and protection from victimisation are inspectable elements.
MLC inspections and their relationship with PSC
Module objectiveConnect flag certification, the sixteen MLC areas, PSC inspection and onshore complaint handling.
MLC inspections may be conducted as dedicated verifications or, more often in practice, as a component of routine Port State Control inspections, with growing weight in recent years within the PSC framework seen in the dedicated course.
The sixteen areas, which are not «typical» but exhaustive
Appendix A5-III lists the areas subject to detailed inspection by a port State officer, and they coincide with those of Appendix A5-I that the DMLC must cover. There are sixteen, and it is a closed list.
| Title | Areas |
|---|---|
| 1 | Minimum age · Medical certification · Qualifications of seafarers · Use of licensed or certified or regulated private recruitment and placement services |
| 2 | Seafarers' employment agreements · Payment of wages · Hours of work or rest · Manning levels · Financial security for repatriation |
| 3 | Accommodation · On-board recreational facilities · Food and catering |
| 4 | Health and safety and accident prevention · On-board medical care · Financial security relating to shipowners' liability |
| 5 | On-board complaint procedures |
Table 9.1 — The sixteen items of Appendices A5-I and A5-III. The two in italics were added by the 2014 amendments: material predating 2017 lists fourteen.
How much MLC deficiencies actually weigh
The Paris MoU Annual Report 2025 gives the figures: 16,474 inspections, 51,797 deficiencies recorded, 688 ships detained, with a detention rate of 4.18 per cent, up from 4.03 in 2024 and 3.86 in 2023. MLC Title 4 is the third-largest deficiency category overall, with 5,225 findings, 10.1 per cent of the total: only SOLAS chapter II-2 on fire protection (16.8 per cent) and chapter II-1 (11.6 per cent) rank above it. Life-saving appliances and safety of navigation come below.
The second channel: the onshore complaint
Alongside the on-board procedure there is a second route, which general material almost always omits. Regulation 5.2.2 requires every port State to have an onshore complaint-handling procedure: a complaint may be lodged with a PSC officer in the port of call — by a seafarer, but also by anyone else with an interest in the safety of the ship, including an interest in safety or health hazards to seafarers. The officer carries out an initial investigation, seeks first to have the matter resolved on board and, if it remains unresolved, notifies the flag State, seeking advice and a corrective plan of action. The complainant's identity may not be disclosed to the master or to the shipowner. This is the channel that makes the rights effective when the shipboard chain does not work — and the reason a complaint mishandled on board does not stay on board.
It is a common mistake to regard MLC deficiencies as purely bureaucratic matters compared with technical or safety ones. The Paris MoU figures refute that on their own: one tenth of every deficiency recorded in Europe concerns Title 4 alone. And the link is not abstract — inadequate working conditions have a direct, measurable impact on fatigue, motivation and, ultimately, the ship's operational safety.
Key takeaways
- Appendices A5-I and A5-III organise the sixteen DMLC and detailed-inspection areas.
- A valid certificate normally limits inspection, but complaints or evidence may justify a deeper examination.
- Onshore complaints enable an initial PSC investigation while protecting the complainant’s identity.
Repatriation and abandonment of crew
Module objectiveRecognise the three alternative abandonment conditions and verify financial security, cover and early operational indicators.
Amendments to MLC 2006 since the original text have specifically strengthened protections against the abandonment of seafarers, a phenomenon that has occurred with particular severity in cases of shipowner insolvency or ship arrest.
When a seafarer is deemed to have been abandoned
The definition is in Standard A2.5.2.2 and is alternative: any one of the three limbs suffices. The shipowner
- (a) fails to cover the cost of the seafarer’s repatriation; or
- (b) has left the seafarer without the necessary maintenance and support — adequate food, accommodation, drinking water, essential fuel for survival on board, necessary medical care; or
- (c) has otherwise unilaterally severed their ties with the seafarer, including failure to pay contractual wages for a period of at least two months.
What the Convention provides in cases of abandonment
- Obligation on the shipowner to provide financial security (typically through P&I insurance) covering repatriation and essential expenses in the event of abandonment.
- Minimum coverage of the security: outstanding wages and other entitlements for up to four months, the cost of repatriation, and essential needs until actual disembarkation (Standard A2.5.2.9).
- Certificate of financial security to be kept on board and posted in a conspicuous place, verifiable at inspection.
- Reporting mechanisms to the Flag Administration and to the competent international organisations in confirmed cases of abandonment.
The scale of the phenomenon
In 2025 6,223 seafarers were abandoned on 410 ships, with USD 25.8 million in unpaid wages, of which the ITF reports recovering USD 16.5 million; the difference is the amount not reported as recovered at the report date, not an amount proven definitively unrecoverable. In three years the number of abandoned seafarers has more than tripled. The financial security introduced in 2014 is therefore not a safeguard for a residual scenario: it is the mechanism holding up the most exposed part of the whole system. Checking it at inspection — certificate on board, in force, posted, and naming the right registered owner — is anything but a formality.
An abandoned crew, often without provisions, fuel or wages, in a foreign port, is the hardest scenario the Convention addresses — and it rarely arrives suddenly: almost always it is preceded by weeks of late wages, thinning supplies and communications that grow scarcer. The two months of unpaid wages test exists precisely to fix a certain moment on a situation that degrades by degrees. Anyone managing ships should read it as a leading indicator, not as a threshold to be reached.
Key takeaways
- Failure to repatriate, lack of necessary support or unilateral severance are alternative abandonment tests.
- Financial security covers up to four months of wages and entitlements, repatriation and essential needs.
- The 2025 ITF figures show exceptional growth but must be distinguished from the joint ILO/IMO case register.
How the Convention is updated: five rounds of amendments
Module objectiveReconstruct Article XV tacit acceptance, distinguish the five amendment rounds and separate current from future requirements.
None of the great maritime conventions changes as readily as the MLC, and that is deliberate: Article XV provides a tacit acceptance procedure allowing the Code — Standards and Guidelines — to be updated without reconvening a Conference. For anyone managing ships this means one thing: the text you held three years ago is not the one in force today.
The Article XV mechanism
- A Special Tripartite Committee (STC), made up of government, shipowner and seafarer representatives, adopts the amendment to the Code.
- The International Labour Conference approves it.
- The Director-General of the ILO notifies ratifying States: two years run from that day.
- After the two years the amendment is deemed accepted, unless more than 40 per cent of ratifying Members, representing at least 40 per cent of gross tonnage, formally express their disagreement.
- The amendment enters into force six months after the date of acceptance.
The 2025 cycle illustrates it exactly: adoption by the STC on 11 April 2025, approval by the Conference on 6 June 2025, notification by the Director-General on 23 June 2025, deemed acceptance on 23 June 2027, entry into force on 23 December 2027. The calendar is therefore known more than two years ahead: there is no reason to be caught out.
The five rounds
| Round | In force from | What it introduced |
|---|---|---|
| 2014 | 18 January 2017 | The two financial securities: for abandonment (Standard A2.5.2) and for shipowners’ liability in the event of death or long-term disability from an occupational cause (A4.2.1-2). Both certificates must be carried on board and posted |
| 2016 | 8 January 2019 | Non-binding Guidelines B4.3.1 and B4.3.6, which must be given due consideration, include bullying and harassment in occupational safety and health policies; limited extension for up to five months after the renewal inspection in the circumstances of Standard A5.1.3.4 |
| 2018 | 26 December 2020 | Piracy and armed robbery: the employment agreement does not expire and wages continue to accrue while the seafarer is held captive, until release and repatriation or death (A2.1.7 and A2.2.7) |
| 2022 | 23 December 2024 | PPE of appropriate size; free drinking water and documented inspection of stores; social connectivity and internet access on board, where reasonably practicable and at reasonable cost; prompt disembarkation for medical care ashore and repatriation of remains; annual reporting to the ILO of all seafarer deaths; the registered owner’s name on financial security documents |
| 2025 | 23 December 2027 (expected) | Requirements expected from 23 December 2027, subject to Article XV acceptance: visa-free and non-discriminatory shore leave, non-discriminatory repatriation, shipowner-borne costs including carriage of 30 kg of luggage, an express prohibition of violence, harassment and sexual assault, fair treatment, strengthened complaints and menstrual-hygiene products. Recognition of seafarers as key workers is set out in the future Guidelines |
Table 11.1 — The five rounds of amendments to the Code.
The 2022 amendments have been in force since 23 December 2024. Items to verify include properly fitting PPE, free drinking water and documented inspections of food and water. On connectivity, the Convention requires States to take account of the need for reasonable access to ship-to-shore communications, while the Guidelines refer to Internet access where available, with any charges being reasonable. This does not create guaranteed free Internet on every ship or a textual requirement for a particular written policy; the company and ship must show how the applicable flag-State implementation has been met.
Read in sequence, they trace a clear line. 2014 secures the money; 2018 protects those who fall into pirates’ hands; 2022 recognises that a ship without a connection is a place of isolation; the 2025 amendments, expected in force from 23 December 2027, strengthen shore-leave rights and protection from violence and harassment. None of these was a theme in 2006. The Convention is moving from the material minimum — how much space, how much food, how much rest — towards the dignity of the person on board, and the direction is now clear enough to be anticipated rather than absorbed.
Key takeaways
- STC adoption, Conference approval, notification, acceptance and entry into force are separate legal steps.
- The 2022 amendments have applied since 23 December 2024.
- The approved 2025 amendments are expected in force on 23 December 2027 and are not yet an MLC inspection basis in August 2026.
The role of crewing management
Module objectiveTranslate MLC requirements into recruitment, contracting, rotation planning and welfare monitoring processes.
The crewing management function plays a central role in ensuring MLC compliance over time, from crew selection and training to contract management, through to the planning of embarkation rotations, which directly affects fatigue and wellbeing.
Crewing management levers relevant to MLC
- Realistic planning of embarkation rotations, systematically avoiding unplanned extensions.
- Selection and training that ensure linguistic understanding of procedures, including complaint procedures.
- Monitoring of turnover and crew satisfaction indicators as early signals of welfare problems.
A high turnover rate, read together with a low number of formal complaints, can indicate that seafarers prefer not to return rather than report a problem. Crewing management should read these two indicators together, not separately.
Key takeaways
- Crewing affects MLC compliance before, during and after service on board.
- Realistic rotations, language comprehension and complaint access reduce documentary and substantive risk.
- Turnover, extensions and complaints should be read together as early indicators.
Beyond compliance: a welfare culture
Module objectiveDistinguish documentary compliance from real welfare and identify organisational practices supporting dignity, health and operational reliability.
As with safety, crew welfare is built through a genuine organisational culture, not merely through documentary compliance with the Convention's minimum requirements.
What distinguishes an authentic welfare culture
- Real, not merely formal, access to communication with family, internet connectivity and psychological support.
- Active listening to crew needs, beyond the minimum set out in the Convention.
- Investment in training and professional growth, not just contractual compliance.
Companies that treat MLC requirements as a ceiling not to be exceeded, rather than as a minimum floor to build upon, tend to have greater retention difficulties and a more fragile safety culture: genuine crew welfare is an investment that pays off in operational reliability, not merely a compliance cost.
Key takeaways
- MLC provides a floor; a welfare culture requires effective access and support.
- Zero complaints do not prove a healthy environment where trust and reporting freedom are absent.
- Connectivity, mental health and development affect retention and safety, although their legal status is not identical.
Emerging trends
Module objectiveMonitor MLC developments without confusing proposals, approved amendments, entry into force and current duties.
The framework of MLC 2006 and crew welfare management continues to evolve, driven by greater attention to mental health and growing integration with the other control systems seen in previous courses.
Directions to watch
- Growing attention to mental health and prolonged isolation, particularly for crews engaged on long voyages or routes with infrequent port calls.
- Greater integration between MLC data and vetting/PSC data, with a combined reading of the ship's overall operational quality.
- New rounds of amendments to the Code, at the pace and by the mechanism described in Module 11: the next expected milestone is 23 December 2027, and the round after that will be discussed by the Special Tripartite Committee before it even enters into force.
Just as mechanical reliability has proven connected to decarbonisation, crew welfare is increasingly proving connected to operational safety: a fatigued, isolated or dissatisfied crew makes more errors, regardless of how well designed the written procedures are.
Key takeaways
- Mental health, violence and harassment, connectivity and fair treatment are expanding the welfare agenda.
- The 2025 changes remain future requirements until their expected entry into force on 23 December 2027.
- Updates must be checked against current ILO text, flag implementation and effective date.
Recurring mistakes
From the Mistake Library of SuperbaKnowledge, filtered to the subjects this course covers. This view selects and organises content published in SuperbaKnowledge; it does not modify or replace it. The linked Knowledge page remains the reference version, while official texts remain authoritative.
| Topic | Mistake | Typical consequence | Topic sheet |
|---|---|---|---|
| Crew Fatigue | Rest hour logging treated as a mere documentary formality, without reflecting real fatigue management on board | Formal compliance that fails to prevent chronic fatigue build-up in the crew | See the topic sheet |
| MLC Complaint Handling | Complaint procedure not clearly explained to the seafarer on joining | MLC deficiency in a PSC inspection | See the topic sheet |
| Prevention of Violence and Harassment | PSSR training renewed without checking that it includes the new competency required from 2026 | Certification formally completed but not compliant with STCW requirements in force from 2026; the 2025 MLC amendments remain future until their expected entry into force | See the topic sheet |
Glossary of acronyms
| Acronym | Definition |
|---|---|
| AB | Able Seafarer, the rating to which the ILO benchmark wage refers |
| CBA | Collective Bargaining Agreement |
| DMLC | Declaration of Maritime Labour Compliance |
| DPA | Designated Person Ashore — a creature of the ISM Code, not of the MLC |
| ILC | International Labour Conference, which approves amendments to the Code |
| ILO | International Labour Organization |
| ITF | International Transport Workers' Federation |
| JMC | ILO Joint Maritime Commission, whose Subcommittee on Wages sets the pay benchmark |
| MLC | Maritime Labour Convention 2006 |
| P&I | Protection and Indemnity (shipowners' mutual insurance) |
| PSC | Port State Control |
| RO | Recognized Organization, to which the flag delegates inspection and certification |
| SEA | Seafarer Employment Agreement |
| STC | Special Tripartite Committee, the body that adopts amendments to the Code |
| STCW | Standards of Training, Certification and Watchkeeping for Seafarers |
References and sources
Consolidated list of the sources cited. Updated as of August 2026; always consult the official text in force, including the most recent amendments.
| Source | Scope |
|---|---|
| Maritime Labour Convention, 2006, as amended (ILO) | Consolidated text: Articles, Regulations and the Code, Part A (Standards) and Part B (Guidelines) |
| 2014, 2016, 2018, 2022 and 2025 amendments to the Code | In force respectively from 18 January 2017, 8 January 2019, 26 December 2020, 23 December 2024 and (expected) 23 December 2027 |
| Appendices A5-I and A5-III | The sixteen items covered by the DMLC and by detailed inspection in PSC |
| ILO, Guidelines for port State control officers carrying out inspections under the MLC, 2006 | Inspection practice and detention criteria |
| STCW Code, section A-VIII/1 | Hours of rest for watchkeeping personnel and the regime of exceptions |
| ILO Joint Maritime Commission, Subcommittee on Wages of Seafarers | Benchmark minimum wage for the able seafarer |
| Paris MoU, Annual Report | Inspection and detention statistics, deficiencies by category |
| ILO/IMO database on seafarer abandonment; ITF reports | Abandonment cases, seafarers affected, unpaid wages |
| Flag Administrations | Applicable national requirements and substantial equivalences (DMLC Part I) |
This course is educational material for training purposes and does not constitute a professional certification or qualifying credential. Read the full disclaimer.