The structure: five titles, one certificate
The convention is built from Articles, Regulations and a Code, and the Code has two parts: Part A sets mandatory Standards, Part B sets non-mandatory Guidelines. Everything is organized under five Titles. Title 1 covers the minimum requirements to work on a ship: minimum age, medical fitness, training and qualification, and recruitment and placement. Title 2 covers conditions of employment: seafarers' employment agreements, wages, hours of work and hours of rest, leave, repatriation and manning levels. Title 3 covers accommodation, recreational facilities, food and catering. Title 4 covers health protection, medical care, welfare and social security protection. Title 5 covers compliance and enforcement. Ships of 500 GT and above engaged on international voyages, or operating from a port or between ports in another country, carry a Maritime Labour Certificate, issued for a period not exceeding five years with an intermediate inspection between the second and third anniversary date. It is supported by a two-part Declaration of Maritime Labour Compliance. In Part I the flag states how it implements the convention. In Part II the shipowner states how the ship achieves ongoing compliance. Inspectors read Part II against reality, which is why a boilerplate Part II is a liability rather than a shortcut.
Where ships actually get caught
The recurring findings are concrete. Accommodation and catering deficiencies. Food and drinking water. Medical care arrangements and expired medical certificates. Seafarers' employment agreements missing, unsigned, or inconsistent with what the crew describes. Wage accounts in arrears or undocumented. Rest hour records that conflict with port logs, cargo operations and drill times. Frequency and severity are two different questions, and it is worth keeping them apart. In the Paris MoU Annual Report 2025, Title 4 (health protection, medical care and welfare) accounts for 10.1 per cent of all recorded deficiencies and Title 3 (accommodation, food and catering) for 7.2 per cent. Title 2, which carries wages, seafarers' employment agreements and hours of rest, accounts for 2.4 per cent. The Title 2 items are far less frequent and far more serious. Unpaid wages and missing or expired employment agreements are treated as serious, and significant wage arrears are established grounds for detention. The convention also requires financial security, certificated and visibly posted on board, covering repatriation and shipowners' liability for contractual claims. Those requirements came from the 2014 amendments, which entered into force on 18 January 2017. Inspectors check the certificates. Crews increasingly know their rights under them.
A convention that keeps amending
The MLC evolves through regular amendment rounds, and compliance drifts if the management system stands still. The 2016 amendments, in force since 8 January 2019, cover protection against shipboard harassment and bullying and the extension of Maritime Labour Certificate validity. The 2018 amendments, in force since 26 December 2020, continue a seafarer's employment agreement and wages during captivity following piracy or armed robbery. The 2022 amendments entered into force on 23 December 2024 and added requirements including free drinking water, appropriately sized personal protective equipment for all seafarers, strengthened connectivity provisions, and provisions on medical care ashore and repatriation of deceased seafarers. A further and far-reaching set was adopted by the Special Tripartite Committee in April 2025 and approved by the International Labour Conference in June 2025, with entry into force expected on 23 December 2027. The headline changes recognize seafarers' right to shore leave without a visa or special permit, strengthen protections against violence, harassment and bullying, clarify what repatriation costs the shipowner must bear, and reflect the recognition of seafarers as key workers. Operators who map each amendment cycle to their DMLC Part II, their crew contracts and their procedures keep the documented system aligned with the convention as it actually stands, rather than as it stood at certification.
Why the human element pays back
Beyond enforcement, MLC compliance is operationally self-interested. Fatigue management is collision avoidance. Decent food and connectivity are retention tools in a tight labour market. A functioning on-board complaints procedure surfaces problems before they reach an inspector or a union. Ships with clean MLC records tend to be the ships people want to return to, and crew who are treated well keep the rest of the compliance picture healthy.