MLC 2006 Compliance Checklist for Shipowners: Practical Guide by Nautilus Shipping

Key Takeaways

• The maritime labour convention 2006 has applied globally since 20 August 2013 and is now recognised as the “fourth pillar” of maritime regulation alongside SOLAS, MARPOL and STCW.

• Ships must carry a maritime labour certificate if over 500 GT and engaged in international voyages, along with a valid Declaration of Maritime Labour Compliance (DMLC) issued or approved by the flag state.

• The “no more favourable treatment” clause means even ships flying flags of non-ratifying countries face MLC checks in ratifying ports, so owners cannot avoid compliance by choosing a different flag.

• Compliance with the Maritime Labour Convention ensures crew welfare and avoids vessel detention, commercial delays and reputational damage.

Introduction: Why MLC 2006 Compliance Matters for Shipowners Today

The maritime labour convention MLC 2006 came into force globally on 20 August 2013, consolidating over 37 older ILO conventions into a single, enforceable international regulatory regime for seafarer welfare. Since then, the MLC amendments were adopted in 2014, 2016, 2018, and 2022 to strengthen protections around financial security, harassment and post-pandemic working conditions.

Often called the “Seafarers’ Bill of Rights,” the Convention is no longer just a legal formality. Charterers, lenders and insurers now treat MLC 2006 compliance as a core commercial requirement when evaluating vessels for fixture or finance.

This article provides a practical MLC 2006 compliance checklist for shipowners and managers operating bulk carriers, tankers, container ships and specialised commercial vessels on international voyages. Non-compliance exposes owners to detention by port state control, costly delays, P&I coverage issues and reputational harm, especially because the favourable treatment clause ensures all ships are held to the same standard regardless of flag.

At Nautilus Shipping, we build maritime labour compliance into day-to-day operations rather than treating it as a one-off certification exercise.

Scope of the Maritime Labour Convention 2006: What MLC Covers and to Whom It Applies

The maritime labour convention is an ILO convention adopted by the International Labour Organization setting minimum standards for seafarers’ working and living conditions on board a ship. The Convention focuses on minimum requirements and employment conditions, creating global standards that apply across virtually all internationally trading fleets.

The MLC applies to most ships ordinarily engaged in commercial activities and international voyages. It generally excludes fishing vessels, warships, naval auxiliaries, traditional vessels and ships operating only in inland or sheltered waters where port regulations apply. The flag state determines borderline cases such as armed guards and offshore crews. Casino personnel and cabin and cleaning personnel working on board are typically covered, as are entertainers, cadets and all other persons who fulfil roles in any capacity on the ship concerned.

The MLC 2006 protects 1.5 million seafarers’ rights worldwide. By 2024, 111 countries ratified the MLC, covering over 97% of global tonnage, making maritime labour compliance practically unavoidable for any fleet of commercial vessels engaged in world tonnage trade.

The Convention is structured around five Titles:

• Title 1 – Minimum requirements for seafarers to work on a ship: age, medical fitness, qualifications and training.

• Title 2 – Conditions of employment: seafarer’s employment agreement, wages, hours of work and rest periods, leave and repatriation.

• Title 3 – Accommodation, recreational facilities, food and catering: cabin standards, mess rooms, ventilation, hygiene and quality shipping conditions.

• Title 4 – Health protection, medical care, welfare and social security: onboard and shore-based medical access, occupational safety and social security protection.

• Title 5 – Compliance and enforcement: flag state certification, port state control inspections, complaint procedures and sanctions.

These five Titles together define the detailed requirements and convention requirements that shipowners must meet.

Core Legal Obligations Under MLC 2006: Shipowner Responsibilities

The responsibilities imposed under MLC 2006 fall on the “shipowner” as broadly defined by the Convention. This includes registered owners, bareboat charterers or any entity (such as a ship manager) that has assumed such responsibility for the operation of the ship through a subcontracting arrangement or otherwise. Where a manager or operator accepts such responsibility, they carry the same obligations as the owner.

The primary legal obligations include:

• Seafarer’s employment agreement (SEA): Shipowners must sign all seafarers’ employment agreements before the seafarer joins. Each SEA must comply with MLC Title 2, national laws and any applicable collective bargaining agreement. Seafarers must have signed employment agreements on board, with copies accessible to them at all times. The employment agreements must cover wages, hours, leave and termination provisions.

• Manning, qualifications and age: All crew members must hold valid STCW certificates, medical fitness certificates and meet national requirements set by the flag state. The Convention prohibits forced or compulsory labour and child labour: seafarers under 16 cannot be employed, and those under 18 cannot perform night work. These fundamental principles are applicable irrespective of the vessel’s trading area.

• Accommodation and recreational facilities: Title 3 requires compliant accommodation standards covering cabin size, ventilation, lighting, noise, sanitary facilities and recreational facilities. For ships built after 20 August 2013, full construction standards apply. Older ships may have limited grandfathering for structural aspects but must meet all non-structural operational standards. This applies to all seafarers concerned on board.

• Health protection and medical care: Shipowners are liable for seafarers’ medical care and repatriation. Ships must provide adequate medical care and equipment onboard for crew members, including a compliant medical chest, medical guide and access to shore-based medical facilities. Social security obligations must align with national laws.

• Complaint procedures: Title 5 requires onboard complaint procedures that protect seafarers from victimisation. Ships need to have documented procedures for crew complaints without victimization, with contact details for the company, flag state and welfare organisations clearly posted. Seafarers have the right to complaint procedures onboard, and these must allow direct access to flag state or port state authorities where necessary.

• Financial security (Regulations 2.5 and 4.2): The 2014 amendments introduced financial security requirements for seafarers covering repatriation and abandonment. Shipowners must provide financial security for seafarers’ abandonment (unpaid wages up to four months, repatriation costs, and essential needs). Financial security certificates are required for repatriation and shipowner liability, including death or long-term disability claims. These certificates must be posted on board ships in English. The 2018 amendments require shipowners to pay wages during piracy captivity.

• Compulsory labour prohibition: The MLC explicitly prohibits compulsory labour in any form, reinforcing that all seafarers working on board must do so voluntarily under fair terms.

Shipowners must ensure compliance with MLC standards across all of these areas. Flag states must ensure compliance with MLC standards through periodic assessments and certification.

MLC 2006 Documentation and Certification: Flag State, Favourable Treatment and Key Certificates

The flag state bears primary responsibility for implementing the maritime labour convention MLC and may authorise a recognized organization (such as a classification society) to audit and certify ships on its behalf. Flag States must periodically assess national compliance systems to ensure their implementing legislation remains substantially equivalent to the Convention’s requirements.

Key certification and documentation requirements include:

• Maritime labour certificate: Ships must carry a maritime labour certificate onboard. MLC requires ships to carry a maritime labour certificate for all commercial vessels over 500 GT on international voyages. The certificate is issued by, or on behalf of, the flag state and confirms that the ship’s working and living conditions meet national requirements implementing the Convention.

• DMLC Parts I and II: The Declaration of Maritime Labour Compliance has two parts. Part I is issued by the flag state listing applicable national laws and related documents. Part II is prepared by the shipowner, describing onboard measures and procedures that ensure compliance between inspections. Both parts must be attached to the maritime labour certificate.

• Survey cycles: MLC compliance requires inspections every 36 months through intermediate surveys. The standard cycle includes an initial survey before the first certification, an intermediate survey between the second and third anniversary, and a renewal survey within five years. Inspections must occur at intervals not exceeding 36 months. Certificates and the DMLC must be posted in a conspicuous place on board, accessible to all crew members.

• No more favourable treatment clause: Under Article V, paragraph 7, port state control in ratifying States must not give more favourable treatment to ships flying flags of non-ratifying countries. This means all ships may be inspected to the same MLC standard when calling at ports of ratifying States, regardless of flag. Port State Control can detain vessels for serious MLC breaches.

• Financial security certificates: Since the 2014 and 2016 amendments (effective January 2017), ships must carry documentary evidence of financial security covering seafarer abandonment (Standard A2.5.2) and shipowner liability for death or long-term disability (Standard A4.2). These certificates must clearly identify the insurer or P&I club, the extent and duration of coverage, and be posted where seafarers concerned can access them.

Nautilus Shipping assists shipowners in preparing ships for initial and renewal MLC audits, liaising with flag states and recognised organisations, and maintaining document control across the fleet via centralised ship management systems. This ensures that ships flying under any flag can demonstrate continuous compliance.

Operational MLC Compliance Checklist: Onboard Systems Shipowners Must Implement

Beyond documentation, MLC requirements demand practical onboard systems that hold up under a detailed inspection by port state control inspectors or flag state surveyors. The following checklist groups the key operational areas that shipowners must address for day-to-day compliance.

Hours of Work and Rest

MLC requires 10 hours of rest in any 24-hour period and 77 hours in any seven-day period. Rest periods may be divided into no more than two periods, one of which must be at least six hours. Watch schedules must be posted, hours recorded daily, and records signed by both the seafarer and the master. Compensatory rest must be documented after emergency drills or exceptional circumstances. Minimum rest is 10 hours in any 24-hour period. This is one of the most frequently checked items during port state inspection.

Seafarer Employment and Payroll

All seafarers on board must hold written employment agreements meeting MLC and national requirements. Shipowners must pay wages at regular intervals with no unauthorised deductions. Overtime rules, leave entitlements, and records of payment must be accessible to the seafarer. Where a collective bargaining agreement applies, SEA terms must be consistent with the CBA. The seafarer’s employment conditions must be transparent and documented.

Onboard Accommodation and Facilities

Port state control officers typically check cabin size against MLC construction standards, ventilation and heating systems, lighting levels, noise and vibration exposure, sanitary spaces, laundry facilities and recreational areas. Recreational facilities must be adequate for the size of the crew and the length of voyages. Ongoing ship maintenance of accommodation spaces is essential-deficiencies under Title 3 are a common cause of detentions.

Food, Catering and Drinking Water

Food and drinking water must be provided free of charge and be of adequate quality, quantity and variety. Ships must carry a qualified cook where required by the flag state. Documented menus should reflect nutritional needs and, where practical, cultural and religious preferences. Food storage must meet hygiene standards, and regular inspections must be recorded by the master or designated officer.

Medical Care and Occupational Health

Ships must provide adequate medical care and equipment onboard, including a medical chest maintained to national standards, a medical guide and telemedicine or shore-based support arrangements. Onboard risk assessments, safety committee meetings and occupational accident reporting procedures must be documented. Health protection extends to access to shore-based medical care in port.

Onboard Complaint Procedures and Anti-Harassment Policies

The 2016 amendments addressed shipboard harassment and bullying guidance, reinforcing the obligation to maintain written complaint procedures posted in crew areas. Contact details for the company, flag state and welfare organisations must be visible. Crew must be trained on how to use the system without fear of retaliation. Port regulations require that these procedures also allow external escalation to port state authorities.

Nautilus Shipping integrates these elements into vessel management manuals, digital reporting tools and internal audits so that ships under our management are consistently prepared for flag state and port state control inspections.

Crew Management and Seafarer Welfare: Going Beyond Minimum MLC Compliance

Competitive shipowners increasingly treat mlc compliance as a baseline rather than a ceiling. The global nature of maritime employment means that retaining skilled seafarers requires genuine investment in welfare beyond minimum standards.

• Structured crew management: Recruitment, training and career development aligned with MLC Title 1 and national standards ensure that all persons fulfil competence and medical fitness requirements before joining. Proper vetting of recruitment agencies, including those in non ratifying countries-reduces risk of non-compliant manning.

• Mental health and wellbeing: Access to counselling services, internet connectivity for contact with families, and fatigue management programmes support seafarers’ rights and welfare beyond the minimum maritime labour convention 2006 obligations. The 2022 amendments aim to improve seafarer working conditions post-COVID-19, reflecting lessons learned during prolonged crew-change crises. Seafarers must have access to shore-based welfare facilities to support well-being.

• Fair rotation and leave: Transparent rotation plans, fair allocation of leave and proactive support during unexpected events (pandemic travel restrictions, political crises, repatriation challenges) maintain trust with crew members and reduce turnover.

Nautilus Shipping’s crew management services deliver both strict maritime labour compliance and higher seafarer satisfaction, linking welfare investment directly to lower incident rates and better commercial reliability for shipowners.

How Nautilus Shipping Supports Owners with MLC Compliance, Inspections and Continuous Improvement

Nautilus Shipping operates as a B2B ship management partner focused on regulatory compliance-including full labour convention mlc 2006 readiness-across bulk carriers, tankers, container ships and specialised vessels. Our approach treats quality shipping and seafarer welfare as inseparable from operational performance.

• End-to-end ship management: We integrate mlc requirements into Safety Management Systems, crew procedures and technical management. This means compliance is embedded in daily operations, not bolted on before surveys.

• Crew management services: We vet and train seafarers against flag state and MLC standards, manage seafarer’s employment agreements and collective bargaining agreements, and ensure recruitment from compliant agencies worldwide.

• Vessel inspections and pre-audit health checks: Before flag state or port state control visits, we conduct targeted checks on accommodation, food, medical facilities, complaint procedures and financial security documents. These detailed inspection rehearsals reduce deficiency rates significantly.

The international maritime organization and international conventions such as MLC form the backbone of maritime regulation. Partnering with an experienced ship manager like Nautilus Shipping helps owners navigate this landscape with confidence.

FAQs

Below are answers to common questions that go beyond the checklist sections above, focusing on edge cases and practical scenarios.

1. Which ships in my fleet actually need a Maritime Labour Certificate and DMLC?

As a rule, MLC applies to all commercial vessels over 500 GT on international voyages or operating between foreign ports. These ships must hold a valid maritime labour certificate and DMLC issued or approved by the flag state.

2. How does the MLC 2006 “no more favourable treatment” clause affect non-ratifying flag ships?

Ships flying the flags of countries that have not ratified the MLC can still be inspected for MLC-equivalent standards when calling at ports of ratifying States. The favourable treatment clause means port state control officers must not give more favourable treatment to these vessels. If serious deficiencies are found, the vessel may be detained until conditions are rectified.

3. What happens during a typical MLC port State control inspection?

A typical port state inspection begins with document checks: the maritime labour certificate, DMLC Parts I and II, seafarer’s employment agreements, hours of rest records and financial security certificates. If documents are in order, inspectors may proceed to a detailed inspection of accommodation, food storage and preparation areas, medical facilities, and posted complaint procedures.

4. How often should I perform internal MLC audits on my vessels?

We recommend at least an annual internal audit focused specifically on MLC requirements, plus additional checks before flag state renewal or intermediate surveys and after major crew changes or vessel conversions. MLC compliance requires inspections every 36 months as a regulatory minimum, but waiting for the survey cycle invites gaps. Nautilus Shipping incorporates MLC checks into routine vessel inspections and management reviews to maintain continuous compliance, ensuring that the ship concerned is always ready for unannounced port state inspections.

5. Can I rely entirely on my P&I Club and insurers for MLC financial security compliance?

While most P&I Clubs issue the required certificates for abandonment and shipowner liability, the shipowner retains ultimate responsibility. Financial security requirements mandate that coverage is valid, certificates are posted on board, and documentation is consistent with national implementing laws.