MLC Certification (Maritime Labour Certificate and DMLC)
Two distinct documents meant to be read together: the certificate declares compliance, the Declaration explains how the Company intends to maintain it day to day.
Operational Explanation
Compliance with the Maritime Labour Convention (MLC 2006) is attested by two complementary documents: the Maritime Labour Certificate, which certifies the ship's compliance with the working and living conditions required by the Convention, and the Declaration of Maritime Labour Compliance (DMLC), structured in two parts — Part I, drawn up by the Flag Administration, listing the applicable national requirements, and Part II, drawn up and maintained by the shipowner, describing the measures adopted to ensure ongoing compliance between one inspection and the next.
The certificate has a maximum validity of 5 years, subject to an intermediate inspection to be conducted between the second and third anniversary of issue, and a renewal inspection before expiry. The Code of the Convention was most recently amended in 2025, strengthening protections against harassment and introducing new financial security requirements.
Regulatory Reference
MLC 2006 (Maritime Labour Convention), Regulation 5.1.3: requires a Maritime Labour Certificate and DMLC (Parts I and II) for ships of 500 GT and upwards engaged on international voyages; intermediate inspection between the 2nd and 3rd anniversary; maximum validity 5 years.
Scope of Application
Every ship of 500 gross tonnage and upwards engaged on international voyages, subject to MLC 2006.
Procedure / How to Complete It
- Verify that the Maritime Labour Certificate is valid and consistent with the DMLC Part I issued by the Flag Administration.
- Keep the DMLC Part II up to date, reflecting the measures actually adopted on board to ensure ongoing compliance (hours of work/rest, accommodation, food, medical care, complaint procedure).
- Schedule the intermediate inspection within the window between the second and third anniversary of the certificate's issue.
- Start the renewal inspection process in good time before the certificate's five-year expiry.
- Verify alignment of onboard procedures with the most recent amendments to the Code of the Convention (2025), including strengthened protections against harassment.
Practical Example
Management example: ahead of the MLC intermediate inspection, the Company verifies that the DMLC Part II accurately reflects the onboard procedures actually in use for managing rest hours, updating it where necessary before the inspector arrives.
Real Cases
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| DMLC Part II not updated following changes to onboard procedures | Discrepancy found at inspection between the declared document and actual practice | Update the DMLC Part II whenever onboard procedures change significantly |
| Intermediate inspection scheduled outside the window between the 2nd and 3rd anniversary | Procedural non-conformity with MLC requirements | Always schedule the intermediate inspection with margin within the expected window |
| Onboard procedures not aligned with the most recent amendments to the Code of the Convention | Non-conformity against updated requirements not yet operationally implemented | Periodically check MLC Code amendments and update procedures accordingly |
PSC Observations
Operational Tips
- Always update the DMLC Part II when onboard procedures change; do not leave it as a static document.
- Schedule the intermediate inspection with margin within the window between the 2nd and 3rd anniversary.
- Periodically check the most recent MLC Code amendments and align onboard procedures accordingly.
Checklist
- Maritime Labour Certificate valid and consistent with the DMLC Part I
- DMLC Part II updated to reflect actual onboard procedures
- Intermediate inspection scheduled within the window between the 2nd and 3rd anniversary
- Renewal process started in good time before the five-year expiry
- Onboard procedures aligned with the most recent amendments to the MLC Code