The 2025 amendments address topics such as recognition of seafarers as key workers and fair treatment. The experiences of the COVID-19 pandemic accelerated the discussion: hundreds of thousands of seafarers were trapped on board for months, without relief, without shore leave, without adequate medical care ashore. The amendments are the regulatory response to this.
Specifically, the most important changes include: first, the formal recognition of seafarers as key workers who must have access to shore leave, relief and medical care even during crises. Second, tightened requirements for documentation of work and rest hours, particularly actual compliance rather than merely formal recording. Third, provisions for fair treatment of seafarers during maritime incidents and port state proceedings.
For operators, this means that the MLC 2006 in its current version carries considerably more operational substance than the original convention. It is no longer sufficient to present an MLC certificate. The amendments require that working conditions on board actually correspond to the documented standards.
MLC requirements take effect in daily operations wherever documentation and practice diverge. The classic example is work-hour documentation: in many cases, MLC-compliant work and rest hours are formally entered correctly in the tables, yet actual workloads deviate. Particularly during port-intensive operations, cargo work or inspections, exceedances regularly occur.
PSC inspectors know this and have adapted their inspection methodology. They compare recorded rest hours with the deck logbook, engine logbook entries and cargo documents. When an officer has documented a cargo operation at 03:00 but their rest-hour table shows an uninterrupted rest period from 22:00 to 06:00, the discrepancy is obvious.
The operational impact extends beyond work-hour documentation, however. The MLC amendments also address accommodation quality, access to communication facilities (internet, telephone) and catering standards. For technical managers, this means MLC compliance is not a pure HR topic but directly intervenes in onboard organisation.
An MLC gap check on three levels is advisable: documents, processes and onboard reality. At the document level, this concerns whether the DMLC (Declaration of Maritime Labour Compliance) Parts I and II reflect the current amendments, whether SEAs (Seafarer Employment Agreements) meet the new requirements and whether insurance certificates for repatriation and liability are current.
At the process level, the following must be verified: is there a functioning complaints procedure on board that is actually used and does not merely exist on paper? Are crew reliefs planned so that maximum service periods are not exceeded, even with unforeseen delays? Is there a system for recording and reporting work-hour exceedances?
At the onboard practice level -- and this is the level PSC is most interested in -- it must be checked whether accommodation meets standards (room size, ventilation, lighting, condition of sanitary facilities), whether catering is adequate and whether the crew actually has access to the designated communication facilities.
Early adaptation reduces PSC risks and strengthens crewing quality. MLC deficiencies during PSC inspections carry direct financial consequences: detention costs idle time and reputation, repeated deficiencies lead to a higher risk profile in the port state information system, which triggers more frequent inspections. In the Paris MoU area, vessels with repeated MLC deficiencies are classified as Standard Risk or High Risk, increasing inspection frequency.
Furthermore, MLC compliance directly influences recruitment. In an increasingly competitive market for qualified seafarers, experienced officers and engineers preferentially choose companies with demonstrably good working conditions. An operator known for poor MLC compliance will struggle to retain and recruit qualified personnel.
The MLC 2006 is structured into five titles: minimum requirements for seafarers to work on ships (Title 1), conditions of employment (Title 2), accommodation, recreational facilities, food and catering (Title 3), health protection and social security (Title 4) and compliance and enforcement (Title 5). The 2025 amendments intervene in several titles.
In the area of employment conditions (Title 2), requirements for wage continuation during sickness and injury are specified. Seafarers are entitled to wage continuation for at least 16 weeks from the date of illness or injury. The amendments clarify that this also applies when the crew member has been repatriated and treatment continues ashore.
In the area of accommodation (Title 3), standards for sleeping rooms, mess rooms and sanitary facilities are made more concrete. Stricter dimensional requirements have applied to newbuilds since the original MLC; the amendments now emphasise that an acceptable standard must also be maintained on existing vessels. Deteriorated accommodation, defective sanitary facilities or inadequate ventilation are not tolerable conditions.
In the area of health protection (Title 4), access to medical care ashore is established as a right of seafarers, not a discretionary decision by the operator. This has practical consequences: when a crew member requires medical treatment ashore, the operator must organise this -- even when it is operationally inconvenient.
MLC-related deficiencies are among the global top five most common PSC deficiency categories. Paris MoU statistics show that work and rest hour violations, inadequate accommodation and missing complaints procedures are regularly cited. The situation is similar in Tokyo MoU ports.
A typical PSC scenario: the inspector enters a crew member's accommodation and finds a defective ventilation fan, peeling paint and a non-functioning shower. The master explains that the repair is planned for the next drydocking. The inspector classifies this as an MLC deficiency because the accommodation does not meet minimum standards. If work-hour documentation additionally shows discrepancies, the inspector can order a detailed (expanded) inspection, which requires considerably more time and effort.
For operators, the lesson is clear: MLC compliance must be continuously lived, not merely prepared for audits. The onboard management -- master and Chief Engineer -- must be aware that MLC-relevant conditions can be inspected without prior notice and that the responsibility for providing adequate resources lies with the management.
A structured MLC gap analysis should be conducted annually, ideally before the next flag state or class audit. The analysis covers: document review (DMLC, SEAs, insurance), process review (relief planning, complaints procedure, work-hour recording) and onboard inspection (accommodation, catering, communication).
The result should be a prioritised action plan: close critical gaps immediately, address medium gaps within 90 days, plan long-term improvements for the next drydock or budget cycle. The plan must be presented to shore management so that the necessary resources are allocated.
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