An MLC 2006 audit is won or lost on evidence: signed agreements, rest hour records that match the logbook, and crew who can explain how to complain. This checklist gives DPAs and masters every item flag and PSC inspectors sample, tagged by how it is proved, so the next audit holds no surprises. Work through it on board and keep each answer with its evidence in Marine Inspection.
MLC 2006 audit checklist: prove crew welfare compliance with documents, observation and interviews
Inspectors check MLC compliance three ways: they read the records, walk the ship and talk to the crew. A finding in any one of the three can stand on its own, so an internal audit has to test all three.
MLC certification applies to ships of 500 GT and above on international voyages; smaller ships are still inspected against the same standards.
MLC 2006 compliance in 2026: what has changed and what is coming
The checklist must reflect the Convention as amended, not as first ratified. The 2022 amendments have been in force since 23 December 2024, and a further set adopted in April 2025 is expected to enter into force in December 2027. For the Convention’s five Titles and certificate structure, see our MLC 2006 crew welfare overview, and ask how the checklist tracks each amendment.
2022 amendments to audit now
- Seafarers told of their right to compensation if recruitment obligations fail (A1.4)
- Drinking water and meals provided free; master inspects food and water
- PPE issued in sizes that fit each seafarer, including women
- Shipowner name on MLC certificate, DMLC and financial security certificates must match
- Prompt repatriation, including for abandoned seafarers
- Ship-to-shore phone and internet at reasonable cost encouraged; some flags make it mandatory
2025 amendments to prepare for
- Bullying, harassment and discrimination built into OSH programmes, investigation and complaints (A4.3, A5.1.5)
- Right to shore leave without discrimination, with no visa or special permit (A2.4.2)
- Repatriation costs clarified: passage, accommodation, up to 30 kg luggage, medical care
- Seafarers recognised as key workers (guideline)
Flags will implement these through national law, and DMLC Part II procedures will need revising.
Where MLC inspections find problems
Overall MLC compliance is high, but the findings cluster in a few places: employment agreements, wages and rest hour records. The 2024 Paris and Tokyo MOU campaign on crew wages and employment agreements shows how quickly findings grew once inspectors looked closely. Start auditing these areas first, for free.
CIC deficiencies by topic, 2023 vs 2024
2023 2024 · Source: Paris MoU / Tokyo MOU CIC report, 2024
Hours of rest figure from the 2014 Paris/Tokyo MOU STCW hours of rest campaign, the last dedicated campaign on the topic.
How a DPA plans an MLC internal audit
Most companies run the MLC audit alongside the ISM internal audit, with the DPA or a nominated auditor leading. Combining them saves a visit but needs discipline, because MLC evidence lives in payroll, crewing and the galley as much as the bridge. Our ISM audit checklist covers the safety management side. Here is a practical sequence; you can see it run as a guided audit.
Read DMLC Part II first
It is the company’s own promise of how each requirement is met. Audit against it, not a generic list.
Pull records before boarding
Payroll and allotments, crew list, SEAs, recruitment agency licence, financial security certificates.
Sample, do not skim
Take a full month of rest hours for several ranks, including a port stay, and compare with deck and engine logs.
Interview across ranks
Talk privately to ratings, cadets and the cook as well as officers. Ask open questions.
Walk the spaces
Cabins, mess rooms, galley, provision rooms, sanitary spaces, hospital and recreation areas.
Close with evidence
Each finding linked to a record, photo or interview note, with an owner and a due date.
Turn this checklist into a live audit for every ship
Tick items on board, attach the record or photo, and see open MLC findings across the fleet in one view.
MLC audit checklist: certificates and documents
Documents are where the inspection starts, and gaps here invite a more detailed inspection of everything else. Make sure the certificates on the bulkhead match the ones in the file, and store their expiry dates for automatic reminders.
MLC audit checklist: employment, recruitment and medical fitness
Employment agreements produced the largest single block of findings in the 2024 campaign, usually because a required element was missing rather than the whole document. Check the content line by line, and see how SEA checks are logged per seafarer.
MLC audit checklist: hours of work and rest
Rest hours are the most sampled MLC item and the easiest to get wrong on paper. Inspectors compare the records with logbooks, alarm logs and drill times, so records that are too tidy draw attention. Check the limits below against at least one full month, and let the app flag breaches as entries are made.
MLC audit checklist: wages, leave and repatriation
Payment at monthly intervals scored the highest compliance in the 2024 campaign, but deductions and the match between payslips and agreements caused findings. Audit the money trail, not just the payslip. For how a finding becomes a PSC code, see our PSC deficiency codes guide.
MLC audit checklist: accommodation, food and drinking water
This is the walk-round part of the audit. Inspectors look at the spaces and then check that the master’s own inspections were recorded. Free drinking water and food inspections gained new weight with the 2022 amendments. See photo-based accommodation rounds.
MLC audit checklist: health, safety and medical care
Title 4 carried more than one in ten Paris MoU deficiencies in 2024. Medical stores, PPE and the safety committee are the usual weak spots. Bullying and harassment controls belong here now, ahead of the 2027 standards. Track medical chest expiry dates free.
MLC audit checklist: on-board complaint procedure
An inspector may ask any rating how they would raise a complaint. If the answer is a shrug, the procedure exists only on paper. The complaint route is also how many MLC inspections begin, so it deserves its own section. Read how PSC boardings unfold in our PSC inspection guide, and see complaint logs kept confidential by role.
MLC inspection interview questions crew are asked
Interviews test whether the paperwork describes real life. Brief the crew on their rights, never on answers. These are the kinds of questions inspectors put to ratings and junior officers, and good internal auditors ask them too.
MLC nonconformities: from audit finding to close-out
Not every gap is equal. Under the Convention, a serious breach, or repeated breaches, of seafarers’ rights can lead to detention, while most findings are corrected within a set period. Grade internal findings the same way, so the most urgent ones are fixed first.
How Marine Inspection keeps MLC compliance audit-ready all year
An MLC audit once a year leaves eleven months for things to drift. Marine Inspection scores each ship against the five Titles continuously: rest hours, certificates, inspections and complaints feed one view, and every open item carries its evidence and owner. The board below is an illustrative example for one vessel.
Open items
MLC 2006 audit checklist FAQs
Who carries out an MLC internal audit?
Usually the DPA or a trained internal auditor, often combined with the ISM internal audit. Flag inspections and recognised organisation surveys are separate, and PSC inspects independently in port.
How often is the MLC certificate inspected?
The certificate lasts up to five years, with an intermediate inspection between the second and third anniversary. An interim certificate can be issued for up to six months.
What are the MLC 2006 hours of rest limits?
At least 10 hours of rest in any 24 hours and 77 hours in any 7 days. Rest can be split into no more than two periods, one at least 6 hours long, with no more than 14 hours between them.
What changed in MLC 2006 in December 2024?
The 2022 amendments came into force: free food and drinking water, properly sized PPE, seafarers informed of compensation rights over recruitment, matching shipowner names on certificates, and stronger repatriation duties.
Can MLC deficiencies lead to detention?
Yes. Conditions that are clearly hazardous to seafarers’ safety, health or security, or serious or repeated breaches of their rights, can result in detention. In the 2024 wages and SEA campaign, 30 ships were detained on campaign items.
What is in DMLC Part II?
The shipowner’s description of how the ship meets each national requirement listed in Part I, plus how compliance is maintained. It is the best starting point for an internal audit. Marine Inspection can turn your DMLC Part II into a checklist.
Every requirement ticked, every tick backed by evidence
Give your DPA one place to plan MLC audits, collect proof from each ship and close findings before the inspector arrives.
