The seven 2025 amendments to the MLC and what to prepare before they take effect

The International Labour Conference approved seven amendments to the Code of the Maritime Labour Convention (MLC) on 6 June 2025. The ILO expects them to enter into force on 23 December 2027.

That is more than two years away. But some of the amendments can be prepared for now, and some have to wait for the flag State to legislate. This article sorts the seven by that line.

A provision starting with A is binding; one starting with B is guidance

What changes is not the body of the Convention but its Code. The Code has two parts, and Article VI of the Convention sets the difference.

1. The Regulations and the provisions of Part A of the Code are mandatory. The provisions of Part B of the Code are not mandatory.

Part A holds the Standards. Their numbers start with A, and they must be complied with. Part B holds the Guidelines. Their numbers start with B, and they are guidance: a flag State gives them due consideration when writing national law.

So read the seven amendments by provision number before reading their headings.

Amendment	Provisions changed	Nature
1. Repatriation without discrimination	New paragraph 10 in A2.5.1	Mandatory
2. Shore leave	A2.4 renamed A2.4.1, new A2.4.2, new B2.4.5	Mandatory + guidance
3. Seafarers as key workers	New B2.5.2	Guidance
4. Fair treatment and marine casualties	New paragraphs 1 and 2 in A5.1.6, amended paragraph 2 of B4.4.6	Mandatory + guidance
5. Costs of repatriation	New paragraph 3 in A2.5.1, replaced paragraph 3 of B2.5.1	Mandatory + guidance
6. Medical training	Amended paragraphs 2 and 4 of B4.1.1	Guidance
7. Violence and harassment	A4.3 and A5.1.5 amended, B1.4.1, B3.1.10, B4.3.1, B4.3.6, B4.3.11 amended	Mandatory + guidance

Binding sentences arrive with amendments 1, 2, 4, 5 and 7. Amendments 3 (key workers) and 6 (medical training material) land only in the Guidelines.

Three sentences state directly what the company must do

Most sentences in the amendments give orders to States (Each Member). The State changes its law, and the law reaches the ship. But three sentences point at the shipowner directly.

The first is shore leave, in new paragraph 6 of A2.4.2.

6. Shipowners shall allow shore leave to seafarers when off duty, upon the ship’s arrival in port, except when leaving the ship is prohibited or restricted by relevant authorities of the port State, or due to safety or operational reasons.

When the ship arrives in port, seafarers who are off duty must be allowed ashore. The only grounds for holding them on board are restrictions by the port State’s authorities and safety or operational reasons. The first four paragraphs of the same Standard bind the port State side: no visa or special permit may be required for shore leave (paragraph 3), and where permission is refused, the reasons go to the seafarer and the master, in writing on request (paragraph 4). Shore leave granted under the Convention on Facilitation of International Maritime Traffic (FAL) counts as meeting paragraphs 1 to 4 (paragraph 7).

The second is the cost of repatriation. New paragraph 3 of A2.5.1 sets the minimum list of costs the shipowner bears. It gets its own section below.

The third is the policy on violence and harassment, in new paragraph 2(f) of A4.3.

(f) require shipowners to adopt and implement relevant policies and measures to prevent and address shipboard violence and harassment, including sexual harassment, bullying and sexual assault;

The sentence is addressed to the flag State. But what it orders is “make shipowners adopt and implement a policy”. The one who ends up writing the policy is the company.

Repatriation costs move from “should be paid” to “must be paid”

The list of costs already exists. But it sits in a Guideline (B2.5.1, paragraph 3) with should. The amendment moves four of its items into Standard A2.5.1 and turns them into shall. A recommendation becomes an obligation.

3. The costs to be borne by the shipowner for repatriation under subparagraph 2(c) shall include at least the following: (a) passage to the destination selected for repatriation; (b) accommodation and food from the moment the seafarers leave the ship until they reach the repatriation destination; (c) transportation of up to 30 kg of the seafarer’s personal luggage to the repatriation destination; and (d) medical treatment when necessary until the seafarers are medically fit to travel to the repatriation destination.

Item	Today	After the amendment
Passage to the destination	Guideline B2.5.1 paragraph 3	Standard A2.5.1 new paragraph 3
Accommodation and food until arrival	Guideline B2.5.1 paragraph 3	Standard A2.5.1 new paragraph 3
Transport of personal luggage	Guideline B2.5.1 paragraph 3	Standard A2.5.1 new paragraph 3
Medical treatment until fit to travel	Guideline B2.5.1 paragraph 3	Standard A2.5.1 new paragraph 3
Pay and allowances	Guideline B2.5.1 paragraph 3	Stays in B2.5.1 paragraph 3

Only pay and allowances stay in the Guideline, and only where national law or a collective agreement provides for them. The luggage wording changes too: today it reads transportation of 30 kg, after the amendment up to 30 kg.

Until now, what had to be paid was for the flag State to decide. After the amendment the floor is in the Convention itself. Whatever the flag, the company cannot go below these four items.

Violence and harassment grows from two lines of guidance into five binding paragraphs

The word harassment does not appear in Standard A4.3 today. It lives only in the Guidelines: one line each in B4.3.1 paragraph 4(d) and B4.3.6 paragraph 2(g), reading harassment and bullying.

After the amendment, five paragraphs enter Standard A4.3. National law must address shipboard violence and harassment, including prohibiting it in law (paragraph 1(e)), and the amendment says what that law has to contain (paragraph 2(e) to (h)). The definition follows Article 1 of the Violence and Harassment Convention (No. 190). Shipowners adopt and implement policies; seafarers comply with them. And there must be a way to report.

(h) establish, after consultation with shipowners’ and seafarers’ organizations, safe, fair and effective reporting mechanisms and procedures for cases of shipboard violence and harassment, including sexual harassment, bullying and sexual assault.

The Guidelines change alongside. Preventive measures in recruitment go into B1.4.1, and the old harassment and bullying wording is replaced by one that covers sexual harassment, bullying and sexual assault. A new paragraph in B3.1.10 requires menstrual hygiene products and means of disposal on board.

Three sentences change in the on-board complaint procedures

Every seafarer already holds a copy of the ship’s complaint procedures (A5.1.5, paragraph 4). Three sentences in that document change. When the sentences change, the copies handed out have to be reissued.

First, there is one more place to file a complaint. The provision today names the master and external authorities. The amendment inserts to appropriate shoreside personnel or between them. A seafarer will be able to go straight to shore-based staff.

Second, more people are protected against victimization. The sentence today covers only the seafarer who filed. The amendment replaces that with complainants, victims, witnesses and whistle-blowers. Witnesses and whistle-blowers are new.

Third, confidentiality becomes an obligation.

5. Appropriate steps shall be taken, at all stages, to safeguard the confidentiality of complaints made by seafarers.

No new inspection item is added; two items you are already inspected on change

To hold a Maritime Labour Certificate, the ship has to pass the flag State’s inspection. The inspection items are listed in Appendix A5-I, and that list already includes Health and safety and accident prevention and On-board complaint procedures. A4.3 and A5.1.5, the two provisions amendment 7 changes, are exactly those two items.

A Declaration of Maritime Labour Compliance (DMLC) is attached to the certificate. Part I is written by the flag State: it states what the national requirements are. Part II is written by the shipowner: it states how the company keeps meeting them between inspections (A5.1.3, paragraph 10). When national law changes, the flag State revises Part I. When Part I changes, the company revises Part II.

Documents that cite provisions by number need their numbers rechecked

The amendments do not only change sentences. They also shift numbers.

• A2.4 becomes A2.4.1 (annual leave), and A2.4.2 (shore leave) appears next to it. A document that says only Standard A2.4 no longer says which one it means.
• Today’s B2.5.2 (implementation by Members) moves down, and the key workers Guideline takes its number.
• A2.5.1 gains a paragraph 3 and a paragraph 10, pushing the following paragraphs down. The final numbering has to be read off the ILO consolidated text.

Where a procedure, a seafarers’ employment agreement or a DMLC Part II cites a provision by number, that number will point somewhere else.

The date of entry into force can differ from ship to ship

Code amendments are adopted by the Special Tripartite Committee and approved by the Conference (Article XV, paragraphs 4 and 5). After that, they do not wait for each country to ratify. If objections are few, they simply enter into force.

7. An amendment approved by the Conference shall be deemed to have been accepted unless, by the end of the prescribed period, formal expressions of disagreement have been received by the Director-General from more than 40 per cent of the Members which have ratified the Convention and which represent not less than 40 per cent of the gross tonnage of the ships of the Members which have ratified the Convention.

To block an amendment, more than 40 per cent of ratifying countries have to object within the set period, and those countries have to hold at least 40 per cent of the tonnage. If the threshold is not reached, the amendment counts as accepted and takes effect six months after the period ends. That is why the date carries the word “expected”.

A country can still delay. By giving notice before the entry-into-force date, it can hold off applying the amendment for up to one year (Article XV, paragraphs 8 and 10). So the same amendment can start applying at different times under different flags.

What you can align now splits from what must wait for the flag State

The amended sentences come in two kinds: those where the Convention writes the content out in full, and those where it leaves the content to national law.

Where the sentences are all there, you can align now. For the repatriation cost list (new paragraph 3 of A2.5.1), match the cost lists in contracts and manuals to the provision. The same goes for the three sentences in the complaint procedures (A5.1.5): the shoreside route, the widened protection, and confidentiality are given as sentences in the text itself.

Violence and harassment has to wait. The definition (A4.3, paragraph 2(e)) and the reporting mechanism (paragraph 2(h)) are for national law to set. A policy written before the flag State defines the terms can end up at odds with that definition. The safer order is to watch the flag State’s legislation and the revision of DMLC Part I, then align Part II.

What to check

• Whether the flag State has given notice of disagreement or of a deferral
• Whether the complaint procedures carry the shoreside route and protection for witnesses and whistle-blowers
• Whether a violence and harassment policy and a reporting route exist as documents
• Whether the repatriation cost list is written into the contract and the manual
• Which on-board documents cite provisions by number
• Whether the revision of DMLC Part II is timed to the flag State’s revision of Part I

The quotations are taken from the amendments approved on 6 June 2025 (ILC.113/Instruments) and from the consolidated text of the MLC, 2006 (including the 2022 amendments). The expected date of entry into force is the one printed in the fifth edition of the ILO Compendium of Maritime Labour Instruments. Where the flag State sets a stricter requirement, that requirement comes first.