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MLC 2006 · Reg. 1.4 · Reg. 2.1 · Reg. 2.2 · Standards A2.5.2 & A4.2.1 · 2022 Amendments

MLC 2006 Seafarer Employment Agreements (SEA), Wages & Welfare Checklist

Maritime Labour Convention, 2006 (MLC, 2006) deficiencies account for more than 10% of all Port State Control findings across the Paris MoU, Tokyo MOU, and Indian Ocean MOU — and are a mandatory human-element focus area in SIRE 2.0 and RightShip RISQ 3.2 Section 15.

Complementing our STCW & MLC Rest Hours Calculator Guide, this guide covers the six non-negotiable MLC inspection pillars: zero recruitment fees (`Reg. 1.4`), Seafarers’ Employment Agreements (`Reg. 2.1`), monthly wage accounts (`Reg. 2.2`), repatriation & A2.5.2 / A4.2.1 financial security, weekly Master accommodation & food inspections (`Regs. 3.1–3.2`), and the 2022 MLC Amendments (in force 23 December 2024).

Updated · Written by SeaReady in our own words. Not affiliated with OCIMF, RightShip, CDI, any MoU or any administration — always check the current official documents.

1. The Six MLC 2006 Inspection Pillars (Titles 1 to 5)

During a Port State Control inspection (IMO Res. A.1206(34) / ILO Guidelines for Port State Control Officers), the PSCO begins by reviewing the Maritime Labour Certificate and Declaration of Maritime Labour Compliance (DMLC Parts I & II), followed by document and living-quarter checks across six core pillars:

Core MLC 2006 shipboard inspection requirements across Titles 1–5.
MLC 2006 Pillar & RegulationStatutory StandardWhat PSC & Vetting Inspectors Verify On Board
Zero Recruitment & Placement Fees (MLC Reg. 1.4 & Standard A1.4.5(b))No fees or charges borne directly or indirectly by the seafarerOnly the cost of a national statutory medical certificate, national seafarer’s book, and passport/personal travel document may be borne by the seafarer; the cost of all visas, travel to the vessel, and manning agency fees must be paid by the shipowner. Manning agencies in non-MLC states require an audit or SRPS certificate under Standard A1.4.9.
Seafarers’ Employment Agreements — SEA (MLC Reg. 2.1 & Standard A2.1)Original signed by both seafarer & shipowner/representative on boardEvery seafarer must hold an original signed SEA containing all 11 mandatory particulars under Standard A2.1.4 (shipowner full name/address, wage formula, paid annual leave calculation, repatriation entitlement, CBA incorporation, and ≥ 7 days notice period). Seafarers must be given time to examine and seek advice before signing.
Monthly Payment of Wages & Allotments (MLC Reg. 2.2 & Standard A2.2)Paid at ≤ 1-month intervals with a signed monthly accountSeafarers must receive a monthly account of payments due and amounts paid (basic wages, overtime hours/rate or guaranteed overtime, allotments, and exchange rate not unfavourable to the seafarer). Unpaid wages over 2 months routinely trigger immediate PSC Action Code 30 detention.
Repatriation & Maximum Tour of Duty (MLC Reg. 2.5 & Standard A2.5.1)Maximum < 12 months continuous service on boardNo seafarer may serve on board for 12 months or more without their informed, voluntary consent and a repatriation plan; shipowners are prohibited from requiring advance deposits toward repatriation costs or recovering repatriation costs from wages except after proven serious default under national law.
Financial Security Certificates — Abandonment & Shipowner Liability (Standards A2.5.2 & A4.2.1)Two current P&I / insurer certificates posted conspicuously in crew accommodationBoth the Standard A2.5.2 Certificate (abandonment: up to 4 months unpaid wages/entitlements, repatriation & essential needs) and the Standard A4.2.1 Certificate (contractual claims for death or long-term disability) must be valid, match the DMLC Part I/II shipowner details, and be posted in English on the crew noticeboard.
Accommodation, Victualling & On-Board Complaints (MLC Regs. 3.1, 3.2 & 5.1.5)Weekly Master accommodation & food/water inspections logged in Official Log BookWeekly Master inspections of crew accommodation (Standard A3.1.18) and food/drinking water/galley spaces (Standard A3.2.7), ship’s cook ≥ 18 years with Flag-recognised qualification on ships with ≥ 10 crew, and an On-Board Complaint Procedure copy handed to every seafarer with their SEA.

2. Seafarers’ Employment Agreements (SEA) & Wage Account Audit

PSCOs and RightShip inspectors routinely sample 3 to 5 crew members across ranks (including ratings and catering staff) to cross-check their original Seafarers’ Employment Agreement (`Standard A2.1`) against the DMLC Part II and monthly payroll records:

  • Original Signed SEA Kept by the Seafarer: Every seafarer must have in their possession a signed original (or verified copy) of their SEA, signed by both the seafarer and the shipowner or an authorised representative of the shipowner before embarkation, alongside an English copy of any applicable Collective Bargaining Agreement (CBA) on board.
  • No Prohibited Clauses or Indefinite Extensions: The SEA must clearly state the termination conditions (if for a definite period, the exact expiry date; if for an indefinite period, the notice period which must be at least 7 days and never shorter for the shipowner than for the seafarer). Any contract extension must be voluntary, signed prior to expiry, and keep total continuous service under 12 months.
  • Monthly Wage Slips & Allotment Remittances (`Standard A2.2`): Verify that every crew member receives an individual monthly account showing basic pay, overtime hours worked (matching the signed rest/work hour sheets), leave pay, home allotment amount, exchange rate, and authorised deductions only — with zero deductions for obtaining employment or visa fees.

3. Top 5 MLC 2006 Detainable Deficiencies (Action Code 30)

Under MLC Regulation 5.2.1 and the Paris / Tokyo MOU procedures, a vessel must be detained where working and living conditions constitute a clear hazard to the safety, health, or security of seafarers, or represent a serious or repeated breach of MLC requirements:

Most frequent MLC 2006 grounds for Port State Control detention (Action Code 30).
Serious Breach / Detention TriggerMLC CitationPreventive Shipboard Action
Repeated non-payment or late payment of wages (> 1–2 months)MLC Standard A2.2 & A2.5.2Verify signed monthly wage slips, bank remittance confirmations for allotments, and immediate P&I financial security notification if arrears occur.
Invalid, expired, or unposted A2.5.2 / A4.2.1 Financial Security CertificatesMLC Standards A2.5.2.6 & A4.2.1.14Confirm both P&I certificates are current, name the exact registered owner / MLC shipowner on the MLC Certificate and DMLC Part II, and are posted in the crew messroom.
Seafarers serving > 11–12 months on board without reliefMLC Standard A2.1.4(g) & A2.5.1.2(b)Monitor SEA expiry dates 60 days ahead; ensure contract extensions never push total continuous service to 12 months or beyond.
Illegal recruitment fees or visa costs deducted from wagesMLC Standard A1.4.5(b) & A2.2Audit pre-joining declarations and wage deduction rows; reimburse any manning-agent fee or visa cost charged to the seafarer (A1.4.5(b) allows only the national medical certificate, seafarer’s book and passport). Who pays the joining flight is set by the employment agreement or CBA.
Insufficient food, unpotable drinking water, or missing qualified Ship’s CookMLC Reg. 3.2 & Standard A3.2Maintain diversified religious/cultural provisions, current fresh-water microbiological test reports, and a valid Flag-recognised Ship’s Cook Certificate.

4. Weekly Master Inspections, Galley Hygiene & the 2022 MLC Amendments

Before arrival in port, the Master, Chief Officer, Chief Engineer, and Ship’s Cook should complete a physical walkthrough covering the accommodation, galley, hospital, and the 2022 MLC Amendments (mandatory from 23 December 2024):

  • Weekly Master Inspections (`Standards A3.1.18 & A3.2.7`): Confirm that weekly inspections of all crew accommodation spaces, sanitary facilities, potable water tanks/filters, dry provision stores, and cold rooms (−18 °C meat/fish freezer, +4 °C vegetable/dairy room, working internal release latches and person-trapped alarms) are logged without gaps in the Official Log Book.
  • Galley & Messroom Standards: Check grease-trap cleanliness above the galley range, working galley range hood fire dampers and deep-fat fryer fixed extinguishing systems (SOLAS II-2/10.6.4), colour-coded chopping boards, defrosting in refrigerated spaces (never in warm standing water), and zero expired food stock.
  • 2022 MLC Amendments Checklist: Verify onboard availability of appropriately-sized PPE (including smaller sizes for women seafarers under Standard A4.3), functional crew recreational facilities and shipboard Wi-Fi / internet connectivity (Standard A3.1), and a well-stocked ship’s hospital and medical chest (Standard A4.1 — never used as a cabin or storeroom).

Questions seafarers ask

What recruitment or pre-joining costs can legally be paid by a seafarer under MLC 2006 Regulation 1.4?

Under MLC 2006 Standard A1.4 paragraph 5(b), no fees or other charges for seafarer recruitment or placement may be borne directly or indirectly, in whole or in part, by the seafarer, other than the cost of the seafarer obtaining a national statutory medical certificate, the national seafarer’s book, and a passport or other similar personal travel documents — not including, however, the cost of visas, which must be borne by the shipowner.

What two Financial Security Certificates must be posted on the crew noticeboard under the 2014 MLC Amendments?

Every vessel subject to MLC 2006 must post two separate, valid certificates from an approved financial security provider (such as an International Group P&I Club) in a conspicuous place in the crew accommodation: (1) the Certificate of Financial Security under Standard A2.5.2 covering repatriation, essential needs, and up to four months of outstanding wages and entitlements in the event of abandonment; and (2) the Certificate of Financial Security under Standard A4.2.1 covering shipowner liability for contractual claims in respect of seafarer death or long-term disability.

What is the maximum continuous period a seafarer can serve on board before entitled to repatriation under MLC 2006?

Under MLC 2006 Standard A2.5.1 paragraph 2(b), the maximum duration of service periods on board following which a seafarer is entitled to repatriation must be less than 12 months. In addition, under Standard A2.4 paragraph 3, any agreement to forgo the minimum annual leave with pay (calculated on the basis of a minimum of 2.5 calendar days per month of employment) is prohibited except in cases provided by the competent authority.

What are the 2022 MLC Amendments that entered into force on 23 December 2024?

The 2022 Amendments to the Code of the MLC 2006 (in force 23 December 2024) strengthen seafarer welfare across five areas: (1) appropriately-sized personal protective equipment (PPE), including for women seafarers (Standard A4.3); (2) free, balanced, and nutritious food and drinking water checked regularly for quality and quantity (Standard A3.2); (3) social connectivity and reasonable ship-to-shore internet access (Standard A3.1 / Guideline B3.1.11); (4) prompt disembarkation for immediate medical care in port and facilitation of repatriation of the body of deceased seafarers (Standards A4.1 & A2.5.1); and (5) recording and reporting of all seafarer deaths to the ILO (Standard A4.3.5).

Open the PSC & MLC 2006 Inspection Checklists in SeaReady

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