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Operational guide · Certification & surveys

MLC Certification (Maritime Labour Certificate and DMLC)

The Maritime Labour Certificate and DMLC connect certification with actual measures for working and living conditions on board.

MLC 2006DMLCMaritime Labour Certificatecertification

Operational Explanation

Read the certificate and DMLC as a path from requirements to practice. Part I identifies national requirements applicable to the ship; Part II describes the shipowner’s measures to maintain them between inspections. Records and observed conditions establish whether those measures work, including after organisational or operational change.

DMLC Part I is drawn up by the competent authority; Part II by the shipowner and certified by the authority or authorized RO. The certificate lasts at most five years. With one intermediate inspection and five-year validity, inspection falls between the second and third anniversaries, based on the expiry day and month, followed by endorsement.

Document / evidenceHow to use it
DMLC Part INational requirement, references, specific conditions and any equivalences/exemptions stated by the authority.
DMLC Part IIShipowner measures for ongoing compliance and continuous improvement.
Practice and recordsWho checks, when and with which evidence; discrepancies and corrective action under the applicable system.
CertificationDMLC version, certificate, dates, inspections/endorsements and revisions managed with the issuer.

Regulatory Reference

MLC 2006, Regulation 5.1.3; Standard A5.1.3. 2022 amendments entered into force on 23 December 2024; 2025 amendments are expected to enter into force on 23 December 2027. ILO — amendments.

A5.1.3.10–12 connects Parts I/II, inspection results and document availability; B5.1.3.2–4 provides guidance on measures, responsible persons, records and DMLC clarity. Distinguish Part A requirements from Part B guidance.

Scope of Application

MLC ships of at least 500 GT on international voyages, or of at least 500 GT flying a Member’s flag and operating from or between ports in another country. Other Member-flag ships may be certified at the shipowner’s request.

Procedure / How to Complete It

  1. Compare certificate, DMLC and actual procedures.
  2. Manage Part II changes with the flag/RO before replacing the certified version.
  3. Plan intermediate and renewal inspections using certificate dates and issuer instructions.
  4. Check existing obligations and keep the plan for future amendments separate.

An internal schedule can connect each Part I item with its Part II measure, responsible person and available evidence. For work/rest hours, for example, compare the stated measure, actual organisation and relevant records. A discrepancy requires assessment and process action: editing DMLC wording alone does not establish that practice has changed.

Practical Example

If rest-hour procedures change, compare records and DMLC; submit any revision through the applicable flag/RO process rather than replacing it unilaterally.

Internal review traces the Part I requirement, Part II measure and practice shown by rosters and records. If revision is needed, retain the previous version, proposed change and agreed follow-up, as well as action to maintain required conditions.

What Typically Goes Wrong

Updating the DMLC without handling certification; calculating anniversaries from issue; postponing existing duties until 2027.

Common Mistakes Mistake Library

MistakeConsequenceHow to avoid it
Replace Part II with a revision not managed with the issuerCertified documentation and actual measures may diverge without the required assessment.Compare change and practice, follow the flag/RO process and retain the certified version and revision outcome.
Calculate anniversaries from issue dateThe intermediate inspection may be planned outside its applicable window.Use the expiry day and month and check dates and endorsements with the issuer.
Postpone existing obligations until the 2025 amendmentsAlready required conditions may remain unimplemented until an irrelevant future date.Distinguish existing obligations from the plan for 23 December 2027 and check applicable national implementation.

What the PSCO Checks

Check valid certificate and DMLC against observed conditions. Documents do not cure discrepancies between stated procedures and onboard practice; assess grounds for a more detailed inspection under Regulation 5.2.1.

Operational Tips

Preparation checklist

Educational checklist. This summary supports learning and preparation only. It does not replace the vessel’s approved procedures, manuals, statutory documents, company SMS, or applicable official requirements. Completing it demonstrates neither compliance nor readiness for an inspection: it shows that a list has been read, not that the ship is in order. Always verify the current documents carried on board.

FAQ

Who certifies Part II?
The competent authority or duly authorized RO; the shipowner draws it up.
Which date determines the anniversary?
The day and month of certificate expiry.
Are the 2025 amendments already in force?
No. As of 13 October 2026, the expected date is 23 December 2027. Existing obligations remain applicable.

Related Topics

Certified substantive revision: 13 October 2026 · page fingerprint c81fcad6c9a0