Crew changes, medical care and repatriation depend on state-level recognition. The debate around key worker status for seafarers began during the COVID-19 pandemic, when border closures and travel restrictions brought crew changes worldwide to a halt. In June 2020, the IMO called on its member states through Resolution MSC.473(ES.2) to recognise seafarers as key workers and enable their cross-border travel for crew changes.
Six years on, implementation remains patchy. Whilst over 70 states have formally recognised key worker status, the practical implementation varies considerably. Some countries have transposed the recognition into national law, others limit it to crisis periods. The question of whether a seafarer can actually cross a border during a renewed pandemic or geopolitical crisis remains unresolved in many jurisdictions.
It improves the basis for entry, crew changes and repatriation. When seafarers are recognised as key workers, they can receive visa facilitations, transit facilitations and access to medical care during crisis situations. This sounds abstract but has immediate operational consequences.
A container ship that cannot change its crew because the port does not admit seafarers has an operational problem. Crew members who must remain on board beyond their contract period are more fatigued, less alert and at higher risk of mental health issues. This directly affects safety performance – the ability to carry out maintenance correctly, bridge watchkeeping and emergency response capability.
IMO Resolution MSC.473(ES.2) recommends that member states designate seafarers as key workers and grant them travel facilitations. The problem: IMO resolutions are recommendations, not binding regulations. Implementation rests with individual states, and here the differences are considerable.
The ILO, through Standard A2.5 of the MLC 2006, already established a binding framework for repatriation. Yet the MLC governs the shipowner's obligation, not the state's obligation to open borders. When a state closes its borders, the shipowner cannot carry out repatriation even if legally required to do so.
The International Chamber of Shipping (ICS) developed a protocol for safe crew changes during the pandemic in 2020, jointly with the ITF. This protocol defined hygiene standards, testing procedures and logistical requirements. It was adopted by many operators and functioned as a de facto standard, even though it had no legal binding force.
At EU level, the European Commission published guidelines for crew changes in EU ports in May 2020. These were more helpful than the IMO resolution because they were more concrete and called on member states to implement specific measures. But again, implementation was uneven.
The central question for 2026 is: have states learnt from the pandemic? The answer is mixed. Some countries, including Singapore, the Netherlands and the United Kingdom, have permanently anchored key worker status. Others allowed emergency provisions to lapse without creating permanent structures.
For operators, key worker status has direct implications for voyage planning and crew change logistics. If the status is recognised in an important hub port, crew changes can be reliably planned there. If not, the operator must maintain alternative routes and backup change ports.
The economic dimension is significant. A delayed crew change can in the worst case block a vessel for days if the designated port does not admit seafarers and the vessel must be diverted to an alternative port. The daily layup cost for a mid-sized container ship ranges between USD 15,000 and 30,000.
Operators who build their crew change strategy around key worker status should conduct a risk analysis for their most important ports: in which jurisdictions is the status permanently anchored, in which only temporarily, and in which is there no regulation? This analysis determines the choice of crew change ports and contingency planning.
Singapore positioned itself as a leading crew change hub during the pandemic. The Maritime and Port Authority of Singapore (MPA) developed a comprehensive protocol for crew changes that integrated COVID testing, quarantine rules and transfer logistics. Between March 2020 and December 2021, over 400,000 crew changes were carried out in Singapore.
Singapore's success was based on three factors: first, the early political decision to recognise seafarers as key workers; second, close cooperation between MPA, health authorities and the shipping industry; third, existing infrastructure – airport, port facilities and a manning agent network.
This model demonstrates what is possible when political will exists. It also shows that the prerequisites are not present everywhere. Countries with less developed infrastructure or lower maritime interest will not achieve this level.
The recommended course of action can be summarised in three steps. First: assess in which jurisdictions key worker status is relevant for the fleet. Second: document the recognition status for each relevant port and integrate it into crew change planning. Third: create contingency plans for the eventuality that important crew change ports become unavailable at short notice.
Beyond this, operators should actively monitor developments. The ICS and ITF regularly publish updates on the state of implementation. The IMO continues the discussion in the Maritime Safety Committee. Those who are informed early can adjust their planning before problems arise.
Political crises can generate similar tensions. The pandemic was not the last event that will complicate border crossings for seafarers. Geopolitical conflicts, regional health crises or natural disasters can trigger similar restrictions at any time. Operators who design their crew change planning only for normal times will be caught cold by the next crisis.
Free initial consultation – we analyze your situation and find the best path forward.
Request Consulting