MLC 2006

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. As checked on 15 September 2026, it is ratified by 113 Member States, representing 96.6 per cent of world gross tonnage.

The five Titles of the Convention and what each contains, with the key dates and figures.

Table 1.1 — The five titles of MLC 2006.

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.

Read MLC by Title and legal level. Articles, Regulations and Part A contain obligations; Part B guides implementation and must receive due consideration. This distinction helps interpret the DMLC and national provisions.

The four levels of the Convention’s text, the parallel numbering and the substantial equivalence of Article VI.3.

The four levels of the text

Table 2.1 — The four levels of the text and their legal force.

Numbering connects Regulations and the Code: Regulation 2.5 on repatriation now corresponds to Standards A2.5.1 (repatriation) and A2.5.2 (financial security), as well as Guideline B2.5. The letter distinguishes Standards and Guidelines; also check the subparagraph and amended version.

Substantial equivalence, and why it must be read before every inspection

Who is a seafarer

Article II.1(f) covers people employed, engaged or working in any capacity on a ship subject to the Convention. This includes hotel and catering roles and does not require an STCW qualification. For doubtful categories, such as some temporarily embarked technicians, the competent authority decides after consultation with shipowners’ and seafarers’ organisations (II.3); presence on board alone does not resolve every case.

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 is not removed when others perform tasks on their behalf.

Which ships it covers

Table 2.2 — The scope of application of the Convention.

Title 1 requires a minimum age of sixteen; hazardous work and, subject to specific authorised training exceptions, night work are prohibited under eighteen. Medical certificates last at most two years, or one under eighteen; colour-vision certification lasts at most six. Check qualifications and safety familiarisation. Recruitment entails no seafarer fees except the national medical certificate, seafarer’s book and passport; visas are the shipowner’s cost (A1.1, A1.2, A1.4.5(b)).

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.

The two parts of the DMLC and the five-year life of the Maritime Labour Certificate.

Table 3.1 — The two parts of the DMLC.

Validity, intermediate inspection and extension

The certificate lasts at most five years (A5.1.3.1). Where there is only one intermediate inspection and a five-year validity, it takes place between the second and third anniversaries and leads to endorsement (.2). If renewal is completed within three months before expiry, the new certificate runs from completion and expires no later than five years after the previous expiry; if completed earlier, the maximum runs from completion (.3). An authorised endorsement may extend validity up to five months from the old expiry where renewal was satisfactorily completed before expiry but the new document cannot immediately be issued and available on board (.4). Extension does not restart the five-year cycle. Keep the certificate and DMLC on board and post accessible copies; an English translation is required if they are not in English, except on ships not engaged on international voyages (.12).

An interim certificate may last at most six months for new delivery, flag change or a new shipowner assuming the ship, after the prescribed checks. No further interim certificate follows the initial six months; full inspection must precede expiry. A DMLC is not required for this interim period (A5.1.3.5-8).

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 SEA also identifies the parties, the seafarer’s birth details, place and date of signature, capacity, health and social benefits, termination and notice, and applicable collective agreement. Seafarer and shipowner hold a signed original; examination and advice must be possible before signing (A2.1). Repatriation circumstances follow A2.5.1 and national implementation; more detailed examples including shipwreck, insolvency and war zones appear in Guideline B2.5.1. The ILO wage reference concerns monthly basic pay for an able seafarer, not every rank’s total remuneration.

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 of Standard A2.3, the three constraints of form, and the two regimes of exceptions, STCW and MLC compared.

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.

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.

Table 5.2 — The two regimes of exceptions.

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.

Assess limits in any rolling 24-hour and seven-day window. The chart’s example provides ten hours of rest: repeated for seven days, it gives seventy hours and fails the normal seventy-seven-hour minimum. STCW covers watchkeepers and personnel with designated safety, security and pollution-prevention duties; MLC protects all relevant seafarers. Drills and call-outs must minimise disturbance and provide applicable compensatory rest; after an emergency the master ensures adequate rest for seafarers who worked during scheduled rest (A2.3.7-9, .14). Provide the seafarer with a record copy endorsed by them and the master or authorised person.

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

Table 6.1 — Typical areas regulated by Title 3 of MLC 2006.

Accommodation construction requirements: which date matters

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 (A3.2.5).
• 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). Documented inspections were already required before the 2022 amendments.

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

• Medical treatment, medicines, board and lodging are covered until recovery or declaration of permanent sickness or incapacity. Any national time limit for these costs cannot be less than sixteen weeks from injury or onset of sickness (A4.2.1.2). Also check permitted exclusions and public authorities assuming costs under A4.2.1.5-6.
• For incapacity due to sickness or injury, the shipowner pays full wages while the seafarer remains on board or until repatriation (A4.2.1.3(a)). After repatriation or landing, full or partial wages follow national law or collective agreement until recovery or earlier entitlement to cash benefits (.3(b)). Any national time limit for wages off board must be at least sixteen weeks from injury or onset of sickness (.4).
• Repatriation at the shipowner's expense if unable to continue serving on board for health reasons.

The ship’s doctor

A qualified doctor is required with at least one hundred persons on international voyages ordinarily exceeding three days (A4.1.4(b)). Other ships need at least one seafarer in charge of medical care and medicines or competent in medical first aid; STCW qualifications, voyage duration and nature, and persons on board determine the required level (A4.1.4(c)).

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.

The nine branches do not mean automatic flag-State coverage for every seafarer. A4.5.3 places primary responsibility on the State of ordinary residence, alongside bilateral or multilateral agreements and other relevant provisions. Verify the individual’s covered branches, contributions, benefits and access.

The onboard complaint-handling system

Module objectiveHandle MLC complaints while ensuring accessibility, representation, non-retaliation and direct access to external authorities.

Every ship subject to MLC must have a fair, effective and expeditious complaint procedure. The internal route does not restrict direct access to the master or appropriate external authorities.

The on-board complaint chain, the two rights of direct access, and the onshore complaint channel.

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).

MLC inspections and their relationship with PSC

Module objectiveConnect flag certification, the sixteen MLC areas, PSC inspection and onshore complaint handling.

The flag State must ensure MLC inspections at intervals not exceeding three years (A5.1.4.4), including where mandatory certification does not apply. Port State control complements rather than replaces flag supervision. Article V.7 prevents more favourable treatment of ships from non-ratifying States.

The sixteen areas of Appendices A5-I and A5-III, grouped by Title.

The sixteen areas and the scope of inspection

Appendices A5-I and A5-III list sixteen certification and detailed-inspection areas. Standard A5.2.1.2 says a detailed inspection covers them in principle; this does not prohibit other relevant MLC inquiries. A complaint may limit detailed inspection to its subject unless clear grounds justify widening the inspection (.3).

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

When reading PSC statistics distinguish inspections, individual deficiencies, detained ships and MLC categories. Title 4 does not represent all MLC deficiencies and a deficiency share is not a share of non-compliant ships. Use official annual reports with explicit year, denominator and classification; frequency alone does not determine the severity of an individual case.

The second channel: the onshore complaint

Standard A5.2.2 allows a seafarer to complain to the authorised officer in the port of call. Initial investigation considers use of the onboard procedure where appropriate; exhausting it is not an absolute prerequisite. Clearly hazardous conditions or serious or repeated breaches engage A5.2.1.6: prevent departure until rectified or an expeditious implementation plan is accepted. Other unresolved cases are referred to the flag for advice and a corrective plan; confidentiality remains protected. The broader definition of complaints from other interested parties belongs to A5.2.1.3.

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 arrival home (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

Seafarers abandoned and ships involved from 2022 to 2025, and the minimum cover of the financial security. For 2025: data compiled by the ITF and published on 22 January 2026; the joint ILO/IMO database remains the institutional case register. Series may differ because of update dates and methodology.

The ITF 2025 data describe cases compiled by the union; the institutional ILO/IMO register may differ by update date and methodology. Abandonment conditions are alternatives: there is no need to wait for two months of unpaid wages where repatriation or maintenance already fails. The four-month cap concerns wages and other entitlements covered by financial security, not every assistance cost or the shipowner’s entire debt. Essential needs are covered until arrival home; access to security must be direct and assistance expeditious (A2.5.2).

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.

Article XV provides a simplified procedure for updating the Code. The STC adopts proposed amendments and the International Labour Conference approves them; the Conference still has a role. Distinguish approval, acceptance and entry into force, and check the flag State’s position.

The Article XV tacit acceptance procedure and the five rounds of amendments to the Code, from 2014 to 2025.

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 notifies ratifying States. The normal disagreement period is two years; the Conference may set another period of at least one year (XV.6).
• At the deadline, the amendment is deemed accepted unless more than 40% of ratifying Members representing at least 40% of ratifying Members’ gross tonnage formally disagree (XV.7). Both conditions must be met.
• Normal entry into force follows six months after acceptance. Check individual declarations of disagreement, express acceptance or deferral under Article XV.8-11.

For the amendments approved in 2025, NORMLEX gives 23 June 2027 as the end of the disagreement period and 23 December 2027 as expected entry into force. They are not in force on 15 September 2026: prepare implementation without treating them as current MLC requirements.

The five rounds

Table 11.1 — The five rounds of amendments to the Code.

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.

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.

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.
• Monitor ILO text, amendment status and flag implementation. For the 2025 amendments, the next expected entry into force is 23 December 2027; verify further proposals or STC schedules when published.