The Maritime Labour Convention 2006 is the seafarer's bill of rights — a single comprehensive instrument that sets minimum standards for every aspect of life and work at sea, from employment agreements and wages to accommodation, food, medical care, and complaint procedures. Ratified by 111 countries representing over 97% of world gross shipping tonnage as of 2026, MLC applies to virtually every commercial vessel regardless of flag — and the "no more favourable treatment" clause means even ships from non-ratifying states face inspection and potential detention when calling at ratifying state ports. For HR managers and fleet managers, MLC compliance is verified through the Maritime Labour Certificate (MLC Certificate) and the Declaration of Maritime Labour Compliance (DMLC) Parts I and II, with inspections at intervals not exceeding 36 months. PSC officers routinely check hours of rest records, seafarer employment agreements, accommodation conditions, and complaint procedures — and they have the power to detain vessels for serious or repeated breaches. The Convention's Code was most recently amended in 2025, continuing to strengthen protections including anti-harassment provisions and financial security requirements. This guide covers all five MLC Titles in practical terms, with the specific standards your vessel must meet and the documentation PSC officers verify. Start a free trial of Marine Inspection to digitize hours of rest tracking, crew certification management, and MLC compliance documentation.
The Five Titles: What MLC Covers
MLC is structured around five Titles, each covering a distinct area of seafarer welfare. Every Title contains Regulations (general principles), Standards (Part A — mandatory), and Guidelines (Part B — recommended). Understanding this structure is essential for building your DMLC Part II.
Hours of Work and Rest: The Most Inspected Requirement
Hours of rest violations are the single most common MLC deficiency found during PSC inspections. The rules are absolute — there is no flexibility for operational pressure. Book a Marine Inspection demo to see how automated hours of rest tracking prevents violations before they occur.
Certification: MLC Certificate & DMLC Structure
MLC compliance is documented through a two-part certification system. PSC officers check both the certificate validity and the DMLC content during inspections. Sign up for Marine Inspection to manage MLC certificate tracking and DMLC documentation.
| Document | Issued By | Contains | Validity | PSC Focus |
|---|---|---|---|---|
| MLC Certificate | Flag state or RO | Confirmation that vessel meets MLC requirements following onboard inspection | 5 years with intermediate verification (between 2nd and 3rd anniversary) | Valid, endorsed, posted conspicuously onboard |
| DMLC Part I | Flag state administration | National requirements implementing MLC for each of the 16 inspection areas — what the flag state requires | Attached to MLC Certificate | Matches flag state's current national legislation |
| DMLC Part II | Shipowner — verified by RO | Ship-specific measures showing how the company implements each DMLC Part I requirement on this vessel | Re-approved at renewal or significant changes | Specific to the vessel, practical procedures documented, matches actual conditions |
| Seafarer Employment Agreements (SEA) | Shipowner + seafarer | Individual employment terms: wages, hours, leave, repatriation, notice periods, benefits | Per contract duration | Every crew member has a signed SEA, copy retained by seafarer |
| Hours of Rest Records | Maintained onboard | Daily records for every crew member showing rest and work periods | Retained onboard for inspection | No violations of 10hr/24hr and 77hr/7-day minimums, signed by seafarer and Master |
| Financial Security Certificates | P&I Club or insurer | Evidence of financial security for abandonment (2014 amendments) and shipowner liability (2014 amendments) | Per policy period | Valid certificates onboard, covering all crew |
| Complaint Procedures | Shipowner | Documented onboard and onshore complaint procedures — posted and accessible to all crew | Ongoing | Procedures posted, crew aware of rights, no victimisation provisions |
What PSC Officers Actually Check
MLC PSC inspections follow a structured approach — officers check documents first, then conditions onboard. Knowing what triggers detailed inspection helps you prepare.
| Inspection Area | What Officers Verify | Common Deficiencies | Detention Risk |
|---|---|---|---|
| Hours of rest records | Daily records for every crew member, signed by seafarer and Master | Records not maintained, violations of 10hr/77hr limits, rest periods split into 3+ segments | High |
| Employment agreements | Every crew member has a signed SEA with required terms | Missing SEAs, unsigned agreements, terms not matching flag state requirements | High |
| Wages and payment | Monthly payment records, allotment arrangements, no unauthorised deductions | Late payments, deductions not agreed in SEA, no allotment facility | Medium |
| Accommodation conditions | Cabin size, headroom, sanitary facilities, heating/ventilation, lighting, noise | Overcrowding, broken sanitary fittings, poor ventilation, excessive noise levels | High |
| Food and catering | Quality, quantity, variety, hygiene, qualified cook (ships with 10+ crew) | Insufficient food, poor galley hygiene, cook not holding valid certificate | High |
| Medical care | Medical chest contents, medical guide onboard, access to shore-based care | Expired medications, incomplete medical chest, no designated medical officer | Medium |
| Complaint procedures | Onboard procedures posted, crew aware of rights, no victimisation | Procedures not posted, crew unaware of complaint process, no onshore contact | Medium |
| Financial security | Valid abandonment and liability certificates onboard | Missing or expired certificates, coverage not matching crew onboard | High |
Onboard Complaint Procedures
MLC requires every ship to have a documented, accessible complaint procedure — and crew must know it exists. PSC officers specifically ask crew members whether they know how to file a complaint. Schedule a demo to see how Marine Inspection manages complaint documentation and crew communication records.
MLC Compliance Checklist
Use this before PSC inspections, flag state surveys, and MLC certificate renewals. These items cover the 16 DMLC inspection areas and the most common deficiency findings. Sign up for Marine Inspection to run these checklists digitally.