TL;DR: MLC 2006 is the International Labour Organization’s Maritime Labour Convention, an international treaty that sets minimum living and working standards for seafarers. It entered into force on 20 August 2013 and is built around five Titles covering entry to the profession, conditions of employment, accommodation and food, health and welfare, and enforcement. Ships of 500 gross tonnage or more on international voyages must carry a Maritime Labour Certificate and a Declaration of Maritime Labour Compliance (DMLC). For a tanker owner, the practical test is not owning the certificate. It is whether the crew’s contracts, rest hours, wages, and cabins would survive a port state control officer looking behind the paperwork.
Most owners meet MLC 2006 the day the certificate is issued and then quietly drift out of compliance over the following months, usually on hours of rest and wage records. This article explains what the Convention actually requires, how the certification works, what changed in the recent amendments, and what a port state control officer checks first. It is written for owners, operators, and DPAs running tanker and bunker tonnage who carry the detention risk when something on board does not match the file.
What is MLC 2006?
MLC 2006 is a single international convention adopted by the International Labour Organization (ILO) in 2006 that consolidates seafarers’ rights into one instrument. It entered into force on 20 August 2013 and is often called the “fourth pillar” of international maritime regulation, sitting alongside SOLAS, MARPOL, and STCW. Where those three govern safety, pollution, and competency, MLC 2006 governs the human side: who may work at sea, on what terms, in what conditions, and with what recourse when things go wrong.
The Convention sets minimum standards across minimum age, seafarers’ employment agreements, hours of work and rest, payment of wages, paid leave, repatriation, medical care, recruitment practices, accommodation, food, and complaint handling, as the ILO’s own summary of what MLC 2006 does sets out. It applies to almost all commercial ships, with narrow carve-outs for vessels on inland or sheltered waters, fishing vessels, ships of traditional build, and warships. For the tanker and bunker fleets we manage, it applies in full. If you are unsure how the labour side fits into the wider job of running crew for a vessel, the pillar guide on Maritime Crew Management Services for Tankers sets out where MLC sits in the overall scope.
The five Titles of MLC 2006
The Convention is organised into five Titles, each covering one stage of a seafarer’s working life. According to Lloyd’s Register’s guidance on the Maritime Labour Convention, they run as follows.
Title 1 sets the minimum requirements to work on a ship: a minimum age (16, with tighter restrictions on night work and hazardous work under 18), a valid medical certificate, the required training and qualifications, and access to a properly run recruitment and placement service. Title 2 covers conditions of employment: the seafarers’ employment agreement, wages, hours of work and rest, entitlement to leave, repatriation, and manning levels. Title 3 governs accommodation, recreational facilities, food, and catering. Title 4 deals with health protection, medical care on board and ashore, shipowner liability, welfare, and social security. Title 5 is the enforcement machinery: flag state inspection, the certification regime, on-board complaint procedures, and port state control.
The structure matters because compliance is judged Title by Title. A ship can be fully certified and still get written up under Title 2 for rest-hour breaches while Titles 1, 3, 4, and 5 are clean. The certificate is a snapshot; the Titles are the standing obligation.
The seafarers’ employment agreement (SEA)
Every seafarer must have a signed seafarers’ employment agreement, and each seafarer keeps a signed original. The SEA is the contract that anchors most of the rest of the Convention. It sets out the terms of engagement, wages, hours, leave, repatriation entitlement, and the notice period for termination. Under Standard A2.1, the seafarer must have a chance to review and seek advice on the agreement before signing, and a copy stays on board in English for inspection.
For a manning agent placing crew on tankers, the SEA is where MLC exposure usually starts. A vague wage clause, a missing repatriation provision, or a mismatch between the SEA and the collective bargaining agreement is the kind of gap a port state control officer or a vetting inspector finds quickly. This connects directly to how crew are sourced and contracted in the first place, which the guide on Seafarer Recruitment and Manning for Tanker Fleets covers in detail.
Hours of work and rest
MLC 2006 caps working hours by setting one of two limits, and flag states choose which to apply. The maximum hours of work are 14 in any 24-hour period and 72 in any seven-day period. The alternative, and the more commonly applied on tankers, is a minimum-rest standard: at least 10 hours of rest in any 24-hour period and 77 hours in any seven-day period. Rest may be split into no more than two periods, one of which must be at least six hours, and the interval between consecutive rest periods cannot exceed 14 hours.
These figures overlap with the STCW rest-hour requirements, and the two are read together on board. The detail of the competency side sits in the guide on STCW Requirements: What Tanker Crew Must Hold. Here is the catch that trips owners: the master may suspend rest schedules for the immediate safety of the ship, but that exception is meant for genuine emergencies, not for routine cargo operations. On a busy bunker vessel doing several deliveries a day, rest-hour records are the single most common MLC deficiency, and they are the first thing a well-briefed inspector cross-checks against the cargo log.
Wages, accommodation, and medical care
Wages must be paid at no greater than monthly intervals and in full, with a monthly account given to each seafarer, and seafarers must be able to transfer earnings home. Accommodation under Title 3 sets minimum standards for cabin size, headroom, heating and ventilation, sanitary facilities, lighting, and hospital accommodation, with the stricter requirements applying to ships built after the Convention entered into force. Food and drinking water must be provided free of charge, of appropriate quality and nutritional value, and a qualified ship’s cook is required on vessels with a prescribed manning level.
Title 4 requires medical care on board comparable, as far as possible, to that available ashore and free of charge to the seafarer. Ships carry a medicine chest, medical equipment, and a medical guide, and vessels with 100 or more persons on an international voyage over three days must carry a doctor. Shipowner liability covers sickness, injury, and death arising from employment, which is where MLC intersects with P&I cover. In practice, accommodation and catering are where older bunker tonnage struggles most, because a cabin that met an earlier standard does not automatically satisfy the post-2013 requirements.
Financial security and abandonment
Two of the most important additions to MLC 2006 deal with money reaching seafarers when an owner fails. The 2014 amendments, in force from 18 January 2017, require ships to carry certificates of financial security covering seafarer abandonment and covering contractual claims for death or long-term disability. The abandonment cover must be able to pay outstanding wages and entitlements, repatriation, and essential needs such as food, accommodation, and medical care.
Abandonment remains a live problem. The joint IMO and ILO database on seafarer abandonment records cases every year, and the financial security certificate is the mechanism that gets a stranded crew home and paid. For a reputable manager this is rarely tested, but the certificate has to be on board and valid, and the underlying insurer has to be one that will actually respond. When a manager handles a crew getting stuck, this cover sits behind the operational response, which the guide on Crew Change and Repatriation: How Managers Handle It explains from the crewing side.
The DMLC and the Maritime Labour Certificate
Ships of 500 gross tonnage or more on international voyages, or operating from a port in another country, must carry two documents: a Maritime Labour Certificate and a Declaration of Maritime Labour Compliance (DMLC). Together they are prima facie evidence that the ship meets the Convention. The DMLC comes in two parts, and confusing them is a common error.
Document | Who produces it | What it does |
|---|---|---|
DMLC Part I | The flag state (or a recognised organisation on its behalf) | Lists the national laws and requirements that give effect to the 14 inspection areas of MLC on that flag |
DMLC Part II | The shipowner | Sets out the specific measures the ship uses to meet each item in Part I, and is verified on board |
Maritime Labour Certificate | The flag state or its recognised organisation | Issued after inspection confirms the ship complies; valid for a maximum of five years |
The Maritime Labour Certificate is valid for up to five years, subject to at least one intermediate inspection between the second and third anniversary of issue. DMLC Part II is the document owners most often get wrong. It is meant to describe what the ship actually does, in specific terms an inspector can check. A Part II that simply restates the regulation without saying how the ship meets it is a weak document, and inspectors treat it as a signal to look harder.
What changed: the MLC amendments
The Convention is amended through the ILO’s Special Tripartite Committee, and the Code has been updated several times since 2013. The 2014 amendments brought in the financial security requirements described above. The 2016 amendments, in force from 8 January 2019, addressed harassment and bullying on board and allowed certificate validity to be extended in defined circumstances. The 2018 amendments, in force from 26 December 2020, keep a seafarer’s employment agreement in effect and wages flowing while a seafarer is held captive as a result of piracy or armed robbery, until release and repatriation.
The most recent set, the 2022 amendments, entered into force on 23 December 2024. As the ILO’s announcement of the 2022 amendments sets out, they require personal protective equipment to be appropriately sized for all seafarers, including the growing number of women at sea, strengthen provisions on free drinking water and repatriation, and require recording and annual reporting of seafarer deaths. If your DMLC Part II and PPE inventory have not been reviewed since 2024, they are now behind the current text.
Inspection and PSC readiness: the operator’s view
Port state control inspects MLC compliance against 14 areas, from minimum age and medical certification through hours of rest, accommodation, food, medical care, complaint procedures, and payment of wages. The starting point is the certificate and the DMLC, but the ILO’s port state control guidelines make clear that a valid certificate does not stop an officer looking further where there is a clear ground to believe conditions on board fall short.
Here is what actually happens in our experience. An inspector arrives, checks the certificate and DMLC are on board and valid, then picks two or three areas and tests them against reality. Rest-hour records get cross-checked against the cargo and watch logs. Wage accounts get checked against the SEA and, if there is one, the collective bargaining agreement. A seafarer might be asked, privately, whether they have a copy of their contract and whether they know how to make a complaint. The paperwork gets you past the first five minutes. What survives the next thirty is whether the ship’s day-to-day practice matches what Part II claims. The same discipline that keeps a tanker ready for a SIRE vetting keeps it ready for an MLC inspection, which is why the approach in SIRE 2.0 Compliance: Beyond Checklists transfers directly, and the mechanics of handling the visit itself are covered in How Ship Managers Handle PSC Inspections.
Our stated view, and it is an opinion rather than a rule: most MLC deficiencies are administrative, not humanitarian. The crew are usually well treated and the ship is usually a decent place to live. What fails is the record-keeping that proves it. An owner who invests a few hours a month in honest rest-hour and wage records will pass almost any MLC inspection, while an owner who treats the certificate as the finish line will eventually get caught by a discrepancy that had nothing to do with how the crew were actually looked after.
A worked compliance scenario
Consider a 6,000 GT bunker tanker on a Singapore flag, running four to six deliveries a day. The Maritime Labour Certificate is valid and the DMLC is on board. On a routine port state control inspection, the officer asks for the last month of hours-of-rest records for two ratings and the duty officer.
The records show clean 10-hour rest days. The cargo log, requested next, shows deliveries running late into the night on eight of those days. The two do not reconcile: the crew could not have taken the rest the sheet claims while also working the cargo the log records. That single inconsistency turns a documentary check into a substantive one, and the officer issues a deficiency for hours of rest under Title 2. The certificate did not prevent it, because the certificate was never the problem. The record was.
The fix is not more paperwork. It is accurate paperwork plus a manning level and rotation that make the rest hours genuinely achievable. Where a bunker vessel physically cannot deliver its schedule inside the rest limits with the crew it carries, the honest answer is more crew or fewer deliveries, not a rest sheet that says otherwise.
Frequently asked questions
What is MLC 2006 in simple terms? It is an international treaty from the ILO that sets minimum standards for how seafarers are recruited, employed, housed, fed, paid, and cared for, and how those standards are enforced. It entered into force on 20 August 2013 and applies to almost all commercial ships, including tankers and bunker vessels.
Which ships need a Maritime Labour Certificate? Ships of 500 gross tonnage or more engaged on international voyages, or operating from a port or between ports in another country, must carry a Maritime Labour Certificate and a Declaration of Maritime Labour Compliance. Smaller vessels and those on domestic voyages may not need the certificate, but the underlying labour standards still apply.
What is the difference between DMLC Part I and Part II? Part I is written by the flag state and lists the national laws that implement MLC’s requirements. Part II is written by the shipowner and describes the specific measures the ship uses to meet each of those requirements. Part I says what the rule is; Part II says how this ship follows it.
What are the MLC hours of rest? Under the minimum-rest option most flags apply, a seafarer must have at least 10 hours of rest in any 24-hour period and 77 hours in any seven-day period. Rest may be split into no more than two periods, one of at least six hours, with no more than 14 hours between them.
How long is the Maritime Labour Certificate valid? Up to five years, with at least one intermediate inspection between the second and third anniversary of issue to confirm the ship still complies.
What happens if a ship fails an MLC inspection? Minor issues are recorded as deficiencies to be rectified within a set period. Serious or repeated breaches, or conditions that clearly endanger seafarers’ safety or health, can lead to the ship being detained until the problem is fixed, with the delay and cost falling on the owner.
What were the 2022 MLC amendments? The 2022 amendments, in force from 23 December 2024, require appropriately sized personal protective equipment for all seafarers, strengthen drinking water and repatriation provisions, and require seafarer deaths to be recorded and reported annually.
Short Q&A
We already have the certificate. Are we compliant? Not necessarily. The certificate proves the ship met the standard on inspection day. Compliance is a standing obligation, and the areas that drift, hours of rest and wage records especially, are exactly the ones an inspector re-tests. Treat the certificate as the start of the obligation, not the end.
Can a manager take on our MLC exposure? A competent crew manager runs the SEAs, rest-hour monitoring, wage administration, financial security, and DMLC Part II as a live system rather than a filing exercise, and stands behind the outcome at inspection. That is the difference between buying a document and buying a managed result.
If you are running tanker or bunker tonnage and want your MLC compliance handled as an operational discipline rather than a certificate on the wall, Emaris Shipping manages the labour side end to end, from employment agreements and rest-hour monitoring to inspection readiness. Talk to us before your next port state control check, not after it.