The structure
The Maritime Labour Convention is often described as the fourth pillar of maritime regulation, alongside SOLAS, MARPOL and STCW. In inspection terms it is more consequential than that description suggests: seafarer welfare deficiencies under MLC Title 4 accounted for 10.1% of all Paris MoU deficiencies in 2025 — the third largest category of any kind.
| Title | Subject |
|---|---|
| Title 1 | Minimum requirements to work on a ship — age, medical fitness, training, recruitment |
| Title 2 | Conditions of employment — agreements, wages, hours, leave, repatriation, manning |
| Title 3 | Accommodation, recreational facilities, food and catering |
| Title 4 | Health protection, medical care, welfare and social security protection |
| Title 5 | Compliance and enforcement — DMLC, certification, inspection, complaints |
Two documents carry the compliance story on board: the Maritime Labour Certificate and the Declaration of Maritime Labour Compliance (DMLC Part I from the flag, Part II from the shipowner setting out the measures adopted).
What inspectors actually check
In practice, the recurring findings cluster in a short list:
- Seafarer employment agreements — missing, unsigned, in a language the seafarer does not read, or inconsistent with the wage actually paid
- Hours of rest records — incomplete, implausible, or showing non-conformances with no corrective action
- Wages — payment not monthly, no written account, allotment facility absent
- Accommodation and catering — cleanliness, ventilation, provisions quality and quantity, potable water testing
- Medical — expired medical certificates, medicine chest deficiencies, missing medical guide
- Financial security certificates — abandonment and death/disability certificates not posted
- Complaint procedure — not posted, or the named contact is the person most likely to be complained about
- Recruitment and placement services — evidence that agencies do not charge seafarers fees
Item 8 is worth emphasising: MLC prohibits charging seafarers fees for obtaining employment. Managers are expected to be able to evidence that their manning agency network complies — assumption is not evidence.
The 2025 amendments
Amendments adopted at the ILO in June 2025 strengthen several areas. Entry into force is expected in late December 2027, which means fleets should be preparing now.
| Amendment area | Substance |
|---|---|
| Key worker recognition | Governments to recognise seafarers as key workers and facilitate safe movement — shore leave, repatriation, crew changes, medical care |
| Shore leave | Seafarers to be able to take shore leave without a visa or special permit and without discrimination; refusals on health or safety grounds require written reasons |
| Repatriation | Strengthened obligation to facilitate repatriation without discrimination, with shipowner bearing specified costs |
| Violence and harassment | Governments and shipowners to prevent shipboard violence, sexual harassment, bullying and sexual assault, aligned with the Violence and Harassment Convention, 2019 |
| Fair treatment | Application of ILO/IMO guidelines on fair treatment of seafarers detained in connection with alleged crimes |
The violence and harassment provisions have the widest practical implications. A compliant response requires a written policy, training that reaches every rank, a reporting route that does not run through the alleged perpetrator, investigation capability, and evidence that reports are acted upon.
The manager's checklist
Documentation
- [ ] Maritime Labour Certificate valid and posted
- [ ] DMLC Part I (flag) and Part II (shipowner) on board, current, and matching actual practice
- [ ] Seafarer employment agreements: signed, in an understood language, copy held by seafarer
- [ ] Applicable collective bargaining agreement on board where relevant
- [ ] Financial security certificates for abandonment and for death/long-term disability posted
Employment and hours
- [ ] Monthly wage payment with written account
- [ ] Allotment facility available, charges reasonable, exchange rate fair
- [ ] Hours of rest recorded, reviewed, and non-conformances actioned
- [ ] Manning level appropriate to the actual trading pattern, not the minimum safe manning document alone
- [ ] Maximum service period tracked; no seafarer over 12 months continuous
Accommodation, food and health
- [ ] Accommodation inspections carried out and recorded at required intervals
- [ ] Provisions quantity, quality and variety; potable water testing records
- [ ] Cook qualified as required
- [ ] Medical certificates current for all seafarers
- [ ] Medicine chest, medical guide and medical reporting form present and current
Welfare and complaints
- [ ] Onboard complaint procedure posted, with an off-ship contact
- [ ] Violence and harassment policy in place, communicated, and training delivered
- [ ] Connectivity provision documented
- [ ] Shore leave facilitated wherever port conditions permit
Recruitment
- [ ] Manning agencies audited on a defined cycle
- [ ] Evidence that no fees are charged to seafarers
- [ ] Agency compliance with MLC recruitment and placement requirements documented
Building it into the system rather than the file
The reason MLC findings persist is that compliance is stored as documents rather than enforced as process. Practical fixes:
- Rest hours captured electronically with automatic non-conformance flagging
- Employment agreements generated from the wage scale, not typed
- Certificate expiries in structured fields with blocking at assignment
- Complaint cases tracked with ageing and outcome
- Agency audit dates tracked like any other certificate
MLC, 2006 as amended; amendments adopted June 2025 with entry into force expected late December 2027. Deficiency data from the Paris MoU Annual Report 2025. General information, not legal advice. Reviewed by the Zeaclub Editorial Team, 24 August 2026.
Frequently asked questions
Which ships does MLC apply to?
Broadly, ships engaged in commercial activities, other than those excluded such as fishing vessels, ships of traditional build, and warships — subject to each flag state's implementation.
What is a DMLC?
The Declaration of Maritime Labour Compliance: Part I sets out national requirements; Part II sets out the measures the shipowner has adopted to meet them. Inspectors compare Part II to what they observe.
What happens if a ship fails MLC inspection?
Deficiencies are recorded and must be rectified; serious or repeated breaches can result in detention. MLC welfare items were the third largest deficiency category in the Paris MoU in 2025.
When do the 2025 amendments take effect?
Entry into force is expected in late December 2027. Preparation — particularly on violence and harassment prevention — should start well before that.