The Maritime Labour Convention 2006 is one of the four pillars of international maritime regulation — alongside SOLAS, MARPOL, and STCW. Yet it remains the least understood of the four among yacht owners and captains who come from a leisure rather than commercial maritime background.
That gap has real consequences. The 2025 Paris MOU Annual Report recorded MLC Title IV deficiencies in 10.0% of all inspections — the third most common deficiency category, behind only SOLAS fire safety and structural systems. The Paris MOU ran a dedicated Concentrated Inspection Campaign on Crew Wages and Seafarer Employment Agreements from September to November 2024. And as of 23 December 2024, new MLC amendments are in force with PSC authorities specifically instructed to check for compliance.
This guide covers what MLC actually requires on a yacht, what has recently changed, and what captains and owners need to have in place.
Source: Paris MOU 2025 Annual Report (parismou.org, published 1 July 2026); ILO MLC 2006 Standard A2.3; Maritime Mutual Risk Bulletin, December 2024.
What Is MLC 2006 and Who Does It Apply To?
The Maritime Labour Convention 2006 was adopted by the International Labour Organization (ILO) in February 2006 and entered into force on 20 August 2013. It consolidates and replaces more than 37 previous international maritime labour instruments. It is commonly referred to as "the Seafarers' Bill of Rights."
MLC establishes minimum standards across five areas:
- Title 1: Minimum requirements to work on a ship (age, medical fitness, training)
- Title 2: Conditions of employment (wages, working hours, leave, repatriation)
- Title 3: Accommodation, recreational facilities, food and catering
- Title 4: Health protection, medical care, welfare and social security
- Title 5: Compliance and enforcement
Does MLC Apply to Your Yacht?
MLC applies to ships engaged in commercial operations — including charter yachts — operating under the flag of a ratifying state, or calling at the ports of a ratifying state. As of February 2026, 111 countries have ratified MLC, representing the overwhelming majority of global shipping tonnage and virtually all Mediterranean port states.
Purely private pleasure yachts are generally outside MLC's formal scope. However, the moment a yacht operates commercially — receiving charter fees, operating under a management agreement, or carrying passengers for reward — MLC requirements apply. Any yacht with professional paid crew that operates commercially should be treated as subject to MLC.
The distinction between "private" and "commercial" is not always obvious. A yacht that occasionally charters, or whose owner occasionally receives guests under arrangements that could be characterised as commercial, may be subject to MLC. When in doubt, apply MLC standards — the cost of compliance is far lower than the cost of detention.
Working Hours and Rest Hours: The Core Requirements
MLC Regulation 2.3 and Standard A2.3 establish the mandatory framework for working time. These numbers are not guidelines — they are enforceable minimums, and falsifying rest hour records is treated as a major breach of the Convention.
Minimum Rest Requirements (Standard A2.3)
- Minimum 10 hours of rest in any 24-hour period
- Minimum 77 hours of rest in any 7-day period
Rest periods may be divided into no more than two periods, one of which must be at least 6 consecutive hours. The interval between consecutive rest periods must not exceed 14 hours.
Maximum Working Hours (Alternative Compliance Method)
Flag states may regulate either minimum rest or maximum work. The maximum working hour limits are:
- Maximum 14 hours of work in any 24-hour period
- Maximum 72 hours of work in any 7-day period
These align with STCW Convention requirements for watchkeeping personnel, meaning compliance with one generally supports compliance with the other.
Exceptions and Compensatory Rest
Temporary deviations from these limits are permitted only for genuine emergencies: fire, collision, man overboard, or other safety-critical situations. Once the emergency has been resolved, compensatory rest must be provided at the earliest opportunity.
Systematic or repeated overwork without justification is a serious MLC violation that can result in PSC detention, fines, and — critically — potential voiding of P&I insurance coverage in crew-related claims.
Record-Keeping Requirements
The captain must maintain daily records of each crew member's hours of work or rest in a standardised format approved by the flag state. Each crew member must receive a copy of their records. Records must be maintained for a minimum of three years.
PSC inspectors will cross-check rest hour records against logbooks, AIS tracking, and engine room records. A rest hour log that shows perfect compliance during a period when the vessel was navigating in challenging conditions will attract scrutiny. Accurate records are always preferable to falsified ones — the consequences of falsification are significantly worse than those of a genuine violation with a transparent corrective action plan.
Seafarer Employment Agreements (SEA)
Every professional crew member on a commercial yacht must have a signed Seafarer Employment Agreement before joining the vessel. The SEA is among the most frequently cited MLC deficiency categories during PSC inspections — in the Paris MOU 2024 Concentrated Inspection Campaign, Seafarers' Employment Agreements accounted for 1.5% of all recorded deficiencies.
What a SEA Must Contain
Per MLC Regulation 2.1 and Standard A2.1, a compliant SEA must include:
- Full name, date of birth, and birthplace of the seafarer
- Name and address of the shipowner
- Place and date of engagement
- Capacity (role) in which the seafarer is employed
- Amount of wages or the formula used to calculate them
- Amount of paid annual leave or the formula used to calculate it
- Conditions for termination, including any required notice period
- Health and social security protection benefits provided
- Repatriation entitlements
- Reference to the applicable collective bargaining agreement (if any)
- Vessel's onboard complaints procedure
The seafarer must receive a signed copy. The original must be kept on board and available for PSC inspection.
The 2022 Amendments: In Force Since 23 December 2024
The amendments adopted by the ILO in 2022 entered into force on 23 December 2024. PSC authorities were specifically advised to check for compliance with the upgraded requirements during inspections from this date forward.
Key Changes
Gender-appropriate PPE: Shipowners are now expressly required to provide personal protective equipment that is gender-appropriate and ergonomically suitable — including helmets, coveralls, gloves, and safety footwear. Failure to provide suitable PPE for female crew members can be cited as a PSC deficiency.
Drinking water: Drinking water must be free of charge, of adequate quality, and available in sufficient quantities at all times. Enhanced monitoring of catering arrangements and food quality also applies.
Financial security for repatriation and abandonment: Enhanced requirements for financial security certificates covering repatriation and abandonment scenarios. The MLC 'Blue Card' naming requirements have been clarified to resolve previous disputes between DMLC and P&I certificate names.
Repatriation without discrimination: Repatriation must be facilitated without discrimination on any grounds, irrespective of flag state.
April 2025 ILO Amendments
The 5th meeting of the ILO Special Tripartite Committee, held in Geneva from 7 to 11 April 2025, adopted further amendments to MLC 2006 covering violence and harassment, repatriation, shore leave, and leave entitlements. These amendments will follow the standard ratification and entry-into-force process — captains and owners should monitor ILO and flag state communications for implementation timelines. These amendments were approved on 6 June 2025 at the ILO's 113th International Labour Conference. The objection period runs until 23 June 2027, with expected entry into force on 23 December 2027.
Welfare and Accommodation Standards
Beyond working hours and employment agreements, MLC establishes minimum standards for crew welfare that are relevant to yacht operations.
Food and catering: Food must be of adequate nutritional value and quality, taking into account crew size, religious requirements, and cultural practices. Fresh water must be freely available.
Accommodation: Crew accommodation must meet minimum size and facility standards. These apply differently to yachts of different sizes and ages — flag state guidance specifies the applicable requirements. The 2022 amendments allow substantial equivalents for large yachts.
Medical care: A medicine chest and medical guide must be maintained on board. The captain must be able to provide basic medical treatment. Vessels on international voyages must carry a medical practitioner or, for smaller vessels, have a certified first aid provider.
Internet access: The 2022 amendments added a guideline that shipowners should, "so far as reasonably practicable," provide seafarers with free or affordable internet access on board. This is a guideline (non-mandatory), but reflects the direction of travel in crew welfare standards.
Shore leave: Crew members are entitled to shore leave when the vessel is in port. Denying shore leave without justification can be cited as a welfare deficiency.
MLC and Yacht Charter Operations
Charter yachts face specific MLC exposure that private owners do not.
Crew turnover. Frequent crew changes increase the risk of missing, outdated, or improperly executed SEAs. Each new crew member requires a compliant agreement before joining.
Rest hour pressure. Charter schedules create pressure on working hours that private programmes do not. A vessel running continuous charters with tight turnaround windows may be creating rest hour violations that appear in the log as compliant — until a PSC inspector cross-checks the records against other evidence.
Multi-jurisdiction exposure. A charter yacht operating between Turkey, Greece, and Croatia may face MLC inspection from different port authorities within a single season. MLC compliance must be consistent regardless of jurisdiction.
What Captains Need to Have Ready
A captain who has the following in order will handle MLC-focused PSC scrutiny without difficulty:
Documentation checklist:
- Current SEA for every crew member on board, signed and with crew copies
- Daily rest hour records for all crew, in flag state-approved format
- Wage payment records — wages must be paid monthly
- MLC Certificate of Compliance (for vessels 500 GT+) and DMLC
- Medicine chest inventory and medical guide
- Onboard complaints procedure, posted and accessible to crew
Operational checklist:
- Rest hours in compliance with Standard A2.3 — no systematic overwork
- PPE available and gender-appropriate
- Food and fresh water of adequate quality
- Shore leave granted when in port unless operationally prohibited
- Crew informed of their rights under MLC
Frequently Asked Questions
Conclusion: MLC Compliance as Operational Standard
MLC 2006 is not a bureaucratic framework imposed on maritime operations from outside. It is a codification of what it means to employ professional crew in a responsible way — fair hours, reliable pay, appropriate welfare, and a clear procedure for raising concerns.
For yacht captains and owners, the practical approach is straightforward: treat every professional crew member as a seafarer with defined legal rights, maintain accurate records, execute compliant employment agreements, and stay current with amendment timelines.
The December 2024 amendments are in force. The April 2025 updates are in the pipeline. PSC inspectors are specifically checking for MLC compliance. The 10.0% deficiency rate in the 2025 Paris MOU report demonstrates that the industry has not fully caught up.
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Sources: ILO, Maritime Labour Convention 2006 (ilo.org); Paris MOU 2025 Annual Report (parismou.org, published 1 July 2026); Maritime Mutual Risk Bulletin No. 96, December 2024; DNV, New Amendments to the MLC 2006 (April 2025); Chambers and Partners, MLC 2006 Amendments analysis. Regulatory requirements are subject to change — consult your flag state administration or a qualified maritime lawyer for current requirements applicable to your vessel.
