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 dates of the certificate, and a renewal inspection before expiry. Standard A5.1.3 §2 anchors the anniversary to expiry, not to issue: “Anniversary date means the day and month of each year which will correspond to the date of expiry of the maritime labour certificate”. The most recent amendments to the Code of the Convention, strengthening protections against harassment and introducing new financial security requirements, were adopted on 11 April 2025 and approved by the 113th session of the International Labour Conference on 6 June 2025, with entry into force expected on 23 December 2027: until then they are not yet applicable as amendments to the Convention.
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 and for ships of 500 GT and upwards flying the flag of a Member and operating from a port, or between ports, in another country (§1); certification at the shipowner's request for other ships flying the flag of a Member (§2); intermediate inspection between the 2nd and 3rd anniversary; maximum validity 5 years.
Scope of Application
Ships of 500 gross tonnage and upwards engaged on international voyages and ships of 500 gross tonnage and upwards flying the flag of a Member and operating from a port, or between ports, in another country (Regulation 5.1.3 §1), subject to MLC 2006. Other ships flying the flag of a Member may be certified at the shipowner's request to the flag State (Regulation 5.1.3 §2).
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 dates of the certificate, calculating the anniversary from the day and month of the expiry date and not of the issue date.
- Start the renewal inspection process in good time before the certificate's five-year expiry.
- Prepare the alignment of onboard procedures with the amendments to the Code of the Convention approved on 6 June 2025, including strengthened protections against harassment, whose entry into force is expected on 23 December 2027.
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.
What Typically Goes Wrong
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 |
| No preparation of onboard procedures for the amendments to the Code of the Convention approved on 6 June 2025 | Late adjustment to their entry into force, expected on 23 December 2027 (until that date they are not yet applicable as amendments to the Convention) | Periodically check MLC Code amendments and plan the update of procedures by their entry into force |
What the PSCO Checks
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 plan the alignment of onboard procedures: those approved on 6 June 2025 have their entry into force expected on 23 December 2027.
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.
- 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
- Plan for alignment with the amendments to the MLC Code approved on 6 June 2025, with entry into force expected on 23 December 2027
FAQ
Related Topics
Last substantive revision of this page: 19 August 2026 · page fingerprint 0349b717482f