The Maritime Labour Convention, 2006 (MLC 2006) is the International Labour Organization's single rulebook for seafarers' working and living conditions, in force since 20 August 2013. For a DPA or fleet manager, it shows up in three places: the certificate and declaration carried aboard, the records an inspector asks to see, and the amendments that keep changing what "compliant" means. The next round of amendments, adopted in 2025, is expected to take effect in December 2027.
What Is the Maritime Labour Convention (MLC 2006)?
MLC 2006 consolidates dozens of older ILO maritime labour instruments into one convention, often called the seafarers' bill of rights. According to the ILO, it has been ratified by flag states covering nearly all of the world's gross tonnage.
The convention is organized into five titles:
| Title | Subject |
|---|---|
| 1 | Minimum requirements to work on a ship: age, medical certificate, training, recruitment |
| 2 | Conditions of employment: employment agreements, wages, hours of work and rest, leave, repatriation |
| 3 | Accommodation, recreational facilities, food, and catering |
| 4 | Health protection, medical care, welfare, and social security |
| 5 | Compliance and enforcement: flag state, port state, and labour-supplying state duties |
Each title has three layers. Regulations set the principle, Part A of the Code sets mandatory standards, and Part B of the Code gives non-mandatory guidance that flag states must still give due consideration.
What Does MLC Certification Require?
Two categories of ships must carry a Maritime Labour Certificate and a Declaration of Maritime Labour Compliance (DMLC), as set out in the ILO's MLC FAQ:
- Ships of 500 GT or more engaged on international voyages
- Ships of 500 GT or more operating from a port, or between ports, in another country
Smaller ships and domestic-only ships may request certification voluntarily. The DMLC comes in two parts. Part I, issued by the flag state, lists the national requirements. Part II, drawn up by the shipowner, explains how the ship meets them. The certificate is valid for up to five years, with an intermediate inspection between the second and third anniversary dates.
Hours of rest and work
Standard A2.3 lets each flag state set limits on one of two bases:
| Basis | Limit |
|---|---|
| Maximum hours of work | No more than 14 hours in any 24 hours and 72 hours in any 7 days |
| Minimum hours of rest | At least 10 hours in any 24 hours and 77 hours in any 7 days |
Rest may be split into no more than two periods, one of at least six hours, and the gap between consecutive rest periods must not exceed 14 hours. Hours of rest records, signed by the seafarer, are among the first documents an inspector checks.
Living conditions and accommodation standards
Title 3 sets detailed standards for ships built after the convention entered into force for the flag state. Key examples include:
- Minimum headroom of 203 centimeters where full and free movement is needed
- Sleeping rooms on cargo ships located above the load line, amidships or aft, except in exceptional cases
- Protection from noise, vibration, heat, and chemical exposure
- Adequate food and drinking water, free of charge, with qualified catering staff
The 2022 amendments, in force since December 2024, added requirements on drinking water quality, appropriately sized personal protective equipment, and social connectivity aboard.
MLC Port State Control Inspections
Port state control officers in MLC-ratifying countries inspect foreign ships against the convention, starting with the certificate and DMLC and moving to a detailed inspection when they find clear grounds. Under the convention's "no more favorable treatment" clause, ships flagged in non-ratifying states are inspected to the same standard.
MLC issues are a major share of detentions and deficiencies. According to Gard, maritime labour deficiencies accounted for more than 20% of all deficiencies recorded by the Paris MOU between 2021 and 2023, with seafarer employment agreements the most frequently cited item. The Paris and Tokyo MOUs ran a joint Concentrated Inspection Campaign on crew wages and employment agreements from September 2024.
Items inspectors check most often:
- Maritime Labour Certificate and DMLC Parts I and II
- Seafarer employment agreements, signed and matching the collective agreement
- Wage records and evidence of payment
- Hours of rest records
- Medical certificates and minimum age
- Onboard complaint procedure
- Accommodation, galley, and provisions
The ANS guide to port state control inspections covers the wider inspection process.
A note for US-flag ships
The United States has not ratified MLC 2006, so the US Coast Guard cannot require MLC compliance. US-flag ships of 500 GT or more on international voyages can instead obtain a Statement of Voluntary Compliance under USCG NVIC 02-13, issued by the Coast Guard or an authorized classification society. Without one, a US ship calling at ports in ratifying countries can face port state control action. The ANS USCG port state control publications checklist covers the US side of inspections.
MLC Amendments: What Has Changed Since 2013
| Amendments | Main changes | In force |
|---|---|---|
| 2014 | Financial security for abandonment, death, and long-term disability | In force |
| 2016 | Harassment and bullying guidance; certificate extension of up to five months | In force |
| 2018 | Wages continue while seafarers are held captive by pirates or armed robbers | In force |
| 2022 | Drinking water, sized PPE, social connectivity, repatriation, medical care, death reporting | December 2024 |
| 2025 | Seafarers as key workers, shore leave, repatriation costs, fair treatment after accidents, violence and harassment prevention | Expected December 2027 |
The 2025 amendments, adopted after the ILO Special Tripartite Committee met in April 2025, are expected to enter into force in December 2027, according to DNV. Flag states will apply them through national rules, so DMLC Part I and Part II will need updating.
Official MLC Guidelines and Publications
Three references cover most compliance needs:
- Guidelines on the Application of the ILO Maritime Labour Convention, 5th Edition 2026, published by the International Chamber of Shipping, prepares shipowners and managers for the 2025 amendments, including key worker designation, repatriation, and harassment prevention, and supersedes the 4th Edition 2023, which covers the 2022 amendments.
- Guidelines for Port State Control Officers Under the MLC, 2nd Edition is the ILO's guidance to inspectors, updated to reflect the 2014, 2016, and 2018 amendments. Reading it shows exactly what a PSC officer is told to check.
- The earlier ILO guidelines for flag state and port state inspections remain in the International Labour Office collection for reference.
Shop MLC Compliance Publications
MLC compliance is a records exercise as much as a standards one. Current guidance, a DMLC Part II that reflects the latest amendments, and complete hours of rest and wage records are what carry a ship through inspection.
Shop MLC compliance publications in the ANS International Labour Office collection, or contact ANS at +1 (954) 522-3321 or sales@amnautical.com for the current editions.
Frequently Asked Questions
What is an MLC certificate and who needs one?
The Maritime Labour Certificate confirms a ship has been inspected and meets MLC requirements. Ships of 500 GT or more on international voyages, or operating from ports in another country, must carry one along with a DMLC.
How often are MLC inspections conducted?
The certificate is renewed at least every five years, with an intermediate inspection between the second and third anniversary dates. Port State Control can also inspect MLC compliance at any port call in a ratifying country.
Where can I buy the official ILO MLC guidelines?
ANS stocks the ICS Guidelines on the Application of the MLC, 5th Edition 2026, the ILO Guidelines for Port State Control Officers, 2nd Edition, and the ILO's earlier inspection guidelines.
What are the MLC hours of rest?
At least 10 hours in any 24 hours and 77 hours in any 7 days, split into no more than two periods, one of at least six hours. Flag states may instead set maximum hours of work of 14 hours a day and 72 hours a week.
When do the 2025 MLC amendments take effect?
The 2025 amendments are expected to enter into force in December 2027, covering seafarers as key workers, shore leave, repatriation, fair treatment after accidents, and violence and harassment prevention.
Does the MLC apply to US-flag ships?
The United States has not ratified MLC 2006. US-flag ships of 500 GT or more on international voyages can obtain a USCG Statement of Voluntary Compliance to show compliance at foreign ports.
