What is MLC 2006? A Seafarer’s Guide to Rights and Protections

Ask ten seafarers what MLC is and most will get the general idea right: it’s the convention that says you must be paid, rested, fed and sent home. Ask when it was last changed and the answers scatter.

That gap matters more than it sounds. The rulebook that applies to you today is not the one adopted in 2006. Eight amendments came into force in December 2024. Seven more were adopted in April 2025 and are expected to take effect in December 2027. Almost every online guide to MLC – including several published by Indian manning agencies this year – still describes the 2006 position as if nothing has moved.

This guide covers what MLC 2006 is, what it entitles you to in concrete terms, what actually changed recently, how it works in Indian law specifically, and what to do when it is breached.

What Is MLC 2006?

MLC stands for the Maritime Labour Convention, 2006. It is an international labour convention adopted by the International Labour Organization (ILO) that sets minimum standards for the working and living conditions of seafarers. It consolidated more than sixty earlier ILO maritime instruments into one document.

It is routinely called the “Seafarers’ Bill of Rights”, and alongside SOLAS, STCW and MARPOL it is described as the fourth pillar of international maritime regulation. SOLAS protects the ship. STCW governs your competence. MARPOL protects the sea. MLC protects you.

It entered into force internationally on 20 August 2013, twelve months after the thirtieth ratification threshold was met.

Why you will never see an “MLC 2026”

This is the part that causes the most confusion, so it is worth being exact.

The convention is called MLC 2006 because that is the year it was adopted. It keeps that name permanently. What changes is the Code – the Standards (Part A, mandatory) and Guidelines (Part B, advisory) that sit under each Regulation. The Code is amended through a tripartite body called the Special Tripartite Committee (STC), on which governments, shipowners and seafarers’ representatives all sit.

The Code has been amended five times: in 2014, 2016, 2018, 2022 and 2025. That is why every properly drafted reference reads “MLC, 2006, as amended”. Those three words are doing real work – they mean the current consolidated text, not the 2006 original.

So when you see a course, a circular or an agency website referring to “MLC 2026”, “MLC 2022” or “MLC 2016” as though it were a separate convention, the person writing it has misunderstood how the instrument works. There is one convention. It has been amended five times. Ask which amendments, not which year.

Does MLC apply to your ship?

Broadly, yes – if you are on a commercial vessel.

MLC applies to all ships, publicly or privately owned, ordinarily engaged in commercial activities. It does not apply to fishing vessels, traditionally built craft such as dhows and junks, warships or naval auxiliaries.

Two points seafarers commonly get wrong:

• Ships under 500 GT are not exempt from your rights. What changes below 500 GT on international voyages is only the certification requirement – those ships need not carry a Maritime Labour Certificate and a Declaration of Maritime Labour Compliance (DMLC). The substantive entitlements still apply.
• The flag of the ship is not a loophole. Under the “no more favourable treatment” principle, a ship flagged in a country that has not ratified MLC can still be inspected against MLC standards when it enters the port of a country that has. A non-ratifying flag does not buy the owner an easier inspection.

The five Titles, in one pass

MLC is organised into five Titles. You do not need to memorise them, but knowing which Title your problem sits under makes any complaint far more effective.

Title 1 – Minimum requirements to work on a ship. Minimum age, medical certification, training and qualifications, and recruitment and placement (Regulation 1.4).

Title 2 – Conditions of employment. Your employment agreement, wages, hours of work and rest, leave, repatriation, compensation for ship loss, manning levels, career development.

Title 3 – Accommodation, recreational facilities, food and catering. Cabins, sanitation, ventilation, mess rooms, recreation, food and drinking water, the qualified ship’s cook.

Title 4 – Health protection, medical care, welfare and social security. Onboard medical care, shipowner liability, occupational safety, shore-based welfare, social security.

Title 5 – Compliance and enforcement. Flag state inspection, port state control, the Maritime Labour Certificate and DMLC, and the complaint procedures.

Your Rights, in Specifics

Generalities do not help you in an argument with a superintendent. These are the actual figures.

1. Minimum age

16 is the absolute floor for working on a ship – no exceptions. 18 is the minimum for night work and for work classified as hazardous.

2. A written employment agreement

You are entitled to a Seafarers’ Employment Agreement (SEA) in writing, signed by both you and the shipowner, with the terms clear and a copy in your possession. You must be given the opportunity to examine it and seek advice before signing.

You are also entitled to a record of employment on discharge. Standard A2.1(3) specifies what that record must not contain: any statement about the quality of your work, or about your wages. A discharge record used to grade your performance is not compliant.

3. Wages

Payable at intervals no longer than one month, in full and in accordance with the SEA. You are entitled to a monthly account showing payments and exchange rates, and to a means of transmitting allotments to your family.

4. Hours of work and rest

Standard A2.3(5) gives flag States a choice of two limits, and your flag applies one of them:

Maximum hours of work: 14 hours in any 24-hour period, and 72 hours in any seven-day period; or
Minimum hours of rest: 10 hours 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 must not exceed 14 hours.

Musters, drills and firefighting exercises must be arranged to minimise disturbance to rest. If your rest is broken by a call-out, you are entitled to compensatory rest. Records of your hours must be kept, in a standard format, endorsed by the master and by you, with a copy given to you.

Two practical notes. First, rank makes no difference to the limit – a chief officer on a port-intensive trade has the same entitlement as an OS. Second, if exceptions are happening routinely rather than exceptionally, that is not a hard trade, that is a manning problem.

5. Paid annual leave

Calculated on the basis of a minimum of 2.5 days per month of employment. An agreement to forgo paid leave is prohibited, except in cases specifically permitted by the competent authority.

6. Repatriation

You are entitled to be sent home, at no cost to you, in defined circumstances: when your agreement expires; when it is terminated by either side for justified reasons; when you are unable to carry out your duties through illness or injury; on shipwreck; on the shipowner’s insolvency or sale of the ship; and where the ship is bound for a war zone you do not consent to enter.

The maximum period of service on board before repatriation entitlement arises is set so that it is less than twelve months – which is where the familiar eleven-month contract limit comes from.

Repatriation costs are the shipowner’s: travel, accommodation, meals en route, your baggage allowance, and medical treatment where needed to make you fit to travel.

7. Abandonment and financial security

Added by the 2014 amendments and among the most useful provisions in the convention.

Under Standard A2.5.2 you are deemed abandoned where the shipowner:

• fails to cover the cost of your repatriation; or
  leaves you without the necessary maintenance and support; or
• has otherwise unilaterally severed ties with you, including failure to pay contractual wages for a period of at least two months.

Every ship in scope must carry a financial security certificate – an insurance policy or equivalent – and it must be displayed somewhere on board where you can see it. Photograph it when you join. When the security is triggered it must cover outstanding wages and entitlements (limited to four months of each), reasonably incurred expenses, and the cost of repatriation.

A separate financial security is required under Standard A4.2.1 for contractual claims arising from death or long-term disability caused by occupational injury, illness or hazard. Payment must be made in full and without delay, with interim payments where the extent of disability is difficult to assess.

8. Medical Care and Shipowner Liability

Onboard medical care is at no cost to you, and you are entitled to access to medical care ashore in port. The ship must carry a medicine chest and medical equipment appropriate to its voyage, and a crew member with the required medical training.

The shipowner bears liability for sickness and injury occurring between the date you join and the date you are repatriated, including your wages while you remain sick or injured on board and, subject to national limits, a defined period after you are landed.

9. Accommodation, food and connectivity

Standards cover cabin size and headroom, sanitation, ventilation, lighting, noise and vibration, mess rooms and recreational facilities.

Food and drinking water must be provided free of charge, of appropriate quantity, nutritional value and quality, with regard to the religious and cultural practices of the crew on board and prepared in hygienic conditions by a properly trained cook.

10. The right to complain without retaliation

Every ship must have an onboard complaint procedure, and you must be given a copy of it. You are entitled to be accompanied or represented, and victimisation for making a complaint in good faith is prohibited.

What Actually Changed: The 2022 Amendments, In Force Since 23 December 2024

These are in force now. If your ship is operating to the 2019 standard, it is out of compliance.

1. Social connectivity. Recreational facilities on board must include social connectivity adapted to seafarers’ needs, including reasonable access to ship-to-shore telephone communication and internet access, with any charges at a reasonable amount. The convention does not define “reasonable” – but the direction of travel is clear, and as satellite crew-connectivity packages have got cheaper the excuse has got thinner.

2. Food and drinking water. Reinforced as free of charge, nutritious, balanced, sufficient in quantity and quality, prepared hygienically and with regard to religious and cultural practice.

3. Recruitment and placement (Regulation 1.4). Seafarers must be informed, prior to or during engagement, of their rights under the system of financial protection that private recruitment and placement agencies are required to maintain to compensate seafarers for monetary loss where the agency or the shipowner fails to meet obligations under the SEA. In plain terms: your manning agency has a duty to tell you what protection exists behind it.

4. Repatriation. Member States must actively facilitate prompt repatriation, including for abandoned seafarers. Where a port State requires a minimum number of crew to remain on board, replacement seafarers engaged for that purpose have the same MLC entitlements. Where a seafarer dies on board, the State concerned must facilitate repatriation of the remains.

5. Medical disembarkation. Seafarers must not be prevented from disembarking for public health reasons where they need urgent medical attention, and ships must be permitted to replenish stores, fuel, water and provisions.

6. Health and safety. Personal protective equipment must be provided in appropriate sizes- a provision that exists because ill-fitting PPE, particularly for smaller-framed and female seafarers, was causing injuries.

7. Fatalities. Member States must ensure seafarer deaths are properly investigated, recorded and reported annually to the ILO.

What is Coming: The 2025 Amendments

On 11 April 2025, the fifth meeting of the Special Tripartite Committee adopted amendments to the Code covering Regulations 1.4, 2.1, 2.4, 2.5, 4.3, 4.4 and 5.1. They were approved by the International Labour Conference on 6 June 2025, notified to member States on 23 June 2025, and are expected to enter into force on 23 December 2027.

Six themes:

• Violence and harassment on board. For the first time the Code addresses prevention of shipboard violence, harassment and bullying, including sexual harassment.
• Seafarers as key workers. The first reference in any ILO instrument designating seafarers as key workers – directly a response to the crew change crisis of 2020-21, and aimed at visas, border crossings, crew changes and access to medical care.
• Shore leave. Seafarers’ rights to shore leave are strengthened on health and wellbeing grounds, with a parallel resolution seeking consistency with the IMO’s FAL Convention.
• Repatriation. Movement for the purpose of repatriation is to be facilitated without discrimination, including on grounds of nationality or flag.
• Fair treatment. States must cooperate and have due regard to the IMO/ILO guidelines on the fair treatment of seafarers following a maritime accident, and those on seafarers detained in connection with alleged crimes.
• Medical guidance. Ships should carry current medical information and guidance for whoever is responsible for medical care on board.

Note the status honestly. These are adopted and approved, but not yet in force. The period for member States to register formal disagreement runs until 23 June 2027. Until December 2027, they are not yet your enforceable entitlements. Anyone telling you today that you have an enforceable MLC right to shore leave on the new terms is ahead of the instrument.

How MLC Works in India

India ratified MLC 2006 on 9 October 2015. Ratification alone does not give you a remedy – what does is the domestic law that implements it, and in India that is a stack of four things.

1. The Merchant Shipping (Maritime Labour) Rules, 2016. The principal implementing rules for MLC in Indian law, later amended. These carry the flag-State obligations – inspection, certification, DMLC, and the financial security requirements for repatriation.

2. The Merchant Shipping (Recruitment and Placement of Seafarers) Rules, 2016 – the RPS Rules. This is the layer most relevant to you before you ever board. No person may carry on the business of recruiting or placing seafarers in India, for an Indian or foreign shipowner and regardless of the vessel’s flag, without an RPSL licence. Rule 5 sets the obligations of a licensed agency, including:

• maintaining a bank guarantee as a system of protection to compensate seafarers for monetary loss arising from the failure of the agency or the shipowner to meet obligations under the SEA;
• not using lists or mechanisms to prevent a qualified seafarer from obtaining employment;
• ensuring that no fee or charge is borne by the seafarer, directly or indirectly, for placement;
• reporting incidents, injuries and deaths to the administration.

Crucially, where an agency does not disclose the employer’s identity to the seafarer at the time of contracting, the agency assumes the entire responsibility of the shipowner. That single provision is why the name of the principal must appear on your contract.

3. The Merchant Shipping Act, 2025. The governing primary legislation, under which the Directorate General of Maritime Administration (DGMA) exercises its enforcement powers – including the abandonment directives issued in 2026 under Section 301 read with MLC 2006 and the RPS Rules, which extend to blacklisting vessels repeatedly involved in abandonment of seafarers.

4. DGMA Orders on insurance cover. Under DGMA Order 22 of 2026, RPSL companies must satisfy additional P&I and insurance requirements before engaging, recruiting or deploying an Indian seafarer on a foreign-flag vessel. A further order issued in August 2026 tightened the verification obligation: the RPSL company must confirm that the vessel holds valid, verifiable cover through an International Group P&I club or a DGMA-approved non-IG insurer, must verify the certificate’s authenticity before deployment, and must keep documentary evidence of that verification. Where a vessel is not covered by those arrangements, the RPSL company must ensure insurance of not less than ₹1,00,00,000 (one crore) per Indian seafarer from an IRDA-approved Indian insurer or a DGMA-approved P&I service provider. No Indian seafarer may be deployed unless those requirements are met.

The practical upshot: an Indian seafarer is protected by more than MLC alone. You have the convention, a bank guarantee held against your agency’s licence and a mandatory insurance floor on the vessel. That is a stronger position than most seafarers realise they are in and a considerably stronger one than an unlicensed “agent” on WhatsApp can offer.

What You Can and Cannot Lawfully Be Charged

Regulation 1.4 is the provision most often paraphrased into uselessness. Here is the precise position.

1. You cannot be charged a fee for finding you employment. Not as a “registration fee”, “documentation fee”, “line-up charge”, “interview fee” or “seat booking”. Under both MLC Standard A1.4 and the Indian RPS Rules, no fee for placement may be borne by the seafarer directly or indirectly.

2. Certain personal costs are legitimately yours. The cost of obtaining your medical certificate, your CDC / seafarer’s book, and your passport or equivalent personal travel documents.

3. Certain costs are the shipowner’s, not yours. Under the Indian rules, visa costs and pre-sign-on and post-sign-off medical examination charges are to be borne by the shipowner.

So the test is not “did money change hands” – it is what the money was for. A receipt for your own passport application is normal. A payment to secure a joining date is not, and it is the most common mechanic in Indian seafarer recruitment fraud.

Before You Sign: A Verification Checklist

• Check the RPSL number on the official register, not on a screenshot or a letterhead the agency sends you. Licences expire and get suspended.
• Confirm the name of the principal / shipowner appears in your SEA. If the agency will not name the employer, it is assuming full employer liability under Rule 5 – make sure it knows that, in writing.
• Read the SEA before signing and keep a signed copy. You are entitled to examine it and seek advice first.
• Confirm the contract length and what happens on extension.
• Confirm wage terms, currency, payment interval and allotment arrangements.
• Ask whether the vessel is covered by an IG P&I club or a DGMA-approved insurer.
• Ask what financial protection stands behind the agency – the 2022 amendment gives you the right to be told this before or during engagement.
• Photograph the financial security certificates when you board.
• Do not pay anything for the placement itself. Refuse, and report it.

If Your Rights are Breached

Escalate in order. Each step creates a record that the next one relies on.

1. The onboard complaint procedure (Regulation 5.1.5). Every ship must have one and you must have a copy. Use it in writing, and keep your copy.
2. The shipowner or manager ashore, through the company’s designated contact in the complaint procedure.
3. Your manning agency, if you were engaged through one. An RPSL holder has obligations to you and a licence at risk.
4. The flag State administration of the vessel.
5. Port State Control in any port of call (Regulation 5.2.2). A PSCO can take up an onshore complaint, and MLC deficiencies can lead to detention.
6. In India, the DGMA / Seamen’s Employment Office with jurisdiction over the agency. Indian authorities have acted on abandonment, blacklisted vessels and taken action against RPSL companies.
7. The ITF, whose inspectors deal with unpaid wages and abandonment cases worldwide, and the ILO.

Victimisation for a complaint made in good faith is prohibited under the convention. Keep documentation, dated, from the beginning – hours-of-rest records, the SEA, wage accounts, photographs of the security certificates, and copies of everything you send.