Marine Advisory: 10/2026 - Concentrated Inspection Campaign (CIC) on MLC – Seafarer Employment Agreements and Wage Compliance
21 May 2026
Marine Advisory 10/2026
SUBJECT: Concentrated Inspection Campaign (CIC) on MLC – Seafarer Employment Agreements and Wage Compliance
Dear Shipowners, Ship Operators, Ship Managers, and Masters,
Background
The Administration has identified recurring deficiencies related to Seafarer Employment Agreements (SEAs), wage payments, and financial transparency, which are core requirements under the Maritime Labour Convention (MLC, 2006, as amended).
Recent Port State Control (PSC) inspections have resulted in increased deficiencies and detentions associated with:
- Invalid or improperly executed SEAs
- Wage discrepancies and delayed payments
- Non-transparent payroll practices
This CIC aims to verify compliance with MLC Title 2 (Conditions of Employment) and ensure that seafarers’ contractual and financial rights are fully protected.
Key Risks
Non-compliance with MLC requirements may result in:
- PSC deficiencies and vessel detention
- Financial penalties and reputational damage
- Crew complaints and potential legal claims
- Increased scrutiny from flag State and PSC regimes
PSC Focus Areas
During the CIC period, inspections will focus on:
- Validity and execution of Seafarer Employment Agreements (SEAs)
- Accuracy and timeliness of wage payments
- Transparency of pay slips and deductions
- Alignment with Collective Bargaining Agreements (CBA), where applicable • Recordkeeping and seafarer acknowledgment
Preventive Measures for Ship Operators
Shipowners and operators are advised to:
- Ensure all SEAs are valid, complete, and properly signed
- Implement payroll verification controls
- Maintain transparent wage accounting systems
- Conduct internal audits of wage compliance
- Address discrepancies proactively and document corrective actions
Immediate Actions Recommended
All stakeholders should:
- Conduct an internal review using the CIC questionnaire below
- Rectify any inconsistencies prior to PSC inspections
- Ensure full documentation is available onboard
- Engage shore management in payroll oversight
Guidance to Inspectors
Any “No” response should be supported with detailed remarks and evidence Serious deficiencies may warrant:
- Expanded inspection
- Notification to Flag Administration
- Requirement for immediate corrective action
References
- Maritime Labour Convention (MLC), 2006 (as amended) – Title 2
- PSC Guidelines on MLC Inspections
- Applicable Collective Bargaining Agreements (CBA)
Please contact the Fleet Prevention Department at prevention@liscr.com or telephone +1 703 790 3434 for more information and/or additional guidance or if any of the responses is “No”.
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Concentrated Inspection Campaign
Questionnaire for the 2026 CIC on MLC Compliance – SEAs and Wages
Vessel Name: | ||||||
IMO Number: | ||||||
Port: | ||||||
Date: | ||||||
No. | Inspection Item | Verification / Evidence Required | Yes | No | ||
1 | Are all Seafarer Employment Agreements (SEAs) currently valid and cover the full period of service onboard? |
| ||||
2 | Are SEAs signed by both parties and dated prior to, or at the time of joining? |
| ||||
3 | Do wages paid fully match amounts stipulated in the SEA and applicable CBA? |
overtime rate & hours, leave pay
| ||||
4 | Are all wage payments made at intervals not exceeding one month with no delays? |
| ||||
5 | Are monthly wage accounts (payslips) provided and clearly itemized? |
(signature/electronic | ||||
6 | Are deductions compliant with SEA/CBA and properly authorized? |
– Repatriation costs (if applicable) | ||||
• Ensure no excessive/unjustified deductions | ||||
7 | Are MLC financial security certificates for seafarer repatriation costs and liabilities valid? | • Verify MLC blue card and certificate validity | ||
8 | Are sufficient drinking water and provisions available on board for the crew. | • Verify crew is not charged for drinking water • Check for:
|
