Operational Guide · Registers & Logbooks

# Handling Seafarer Complaints (MLC 2006)

Every ship subject to MLC must have an internal complaint procedure with precise response times: ignoring it, or treating it as a formality, exposes the Company to a real risk during inspection.

MLC 2006 complaints complaints handling Regulation 5.1.5

## Operational Explanation

The Maritime Labour Convention 2006 (Regulation 5.1.5) requires every ship subject to the Convention to have an on-board procedure for the fair and effective handling of seafarers' complaints alleging breaches of MLC requirements, including seafarers' rights.

The typical procedure provides for a response within 7 days from the head of department or immediate superior; if the complaint is not resolved satisfactorily, the seafarer may approach the Master within 2 days, who has a further 7 days to propose a solution. The seafarer has the right to be accompanied or represented during the procedure, the right to confidentiality, the right not to suffer retaliation for filing a complaint, and the right to approach external competent authorities if necessary.

The MLC amendments approved by the 113th session of the International Labour Conference (6 June 2025), with entry into force expected on 23 December 2027, include the addition of "appropriate shore-based personnel" as a further level to which a seafarer can address a complaint, and a broadened definition of victimisation, now covering adverse action against complainants, victims, witnesses and whistleblowers, including protections in cases where a complaint is deemed vexatious or made in bad faith.

## Regulatory Reference

MLC 2006, Regulation 5.1.5 (On-board complaint procedures); amendments approved by the 113th ILC session (6 June 2025), in force from 23 December 2027, adding shore-based personnel as a complaint level and broadening protection against victimisation.

## Scope of Application

Every ship subject to MLC 2006, for all seafarer complaints alleging breaches of the Convention's requirements.

## Procedure / How to Complete It

1. Provide every seafarer, on joining, with a copy of the on-board complaint procedure, including contact details for the subsequent escalation levels.
2. The seafarer files the complaint with their head of department or immediate superior, who must respond within 7 days.
3. If the complaint is not resolved satisfactorily, the seafarer may approach the Master within 2 days, who has a further 7 days to propose a solution.
4. Guarantee at every stage the seafarer's right to be accompanied or represented, and the confidentiality of the process.
5. If the complaint is not resolved on board, inform the seafarer of the possibility of approaching external competent authorities (the Company, the Flag Administration, or the new shore-based personnel roles introduced by the 2025 amendments).

## Practical Example

Example of application: a seafarer files a complaint about an alleged breach of rest hours with their immediate superior; not receiving a satisfactory response within 7 days, they approach the Master, who involves the Company and documents the proposed solution within the required timeframe, with a complete record of the process under the MLC procedure.

## Real Cases

The absence of a functioning complaint procedure, or its purely formal application without a real possibility of escalation, is an area of growing attention in MLC-related PSC inspections, especially in light of the broadened protection against victimisation introduced by the 2025 amendments.

## Common Mistakes Mistake Library

Mistake | Consequence | How to avoid it
--- | --- | ---
Complaint procedure not provided or not clearly explained to the seafarer on joining | Seafarer unaware of their rights and the complaint procedure, MLC deficiency at inspection | Always provide and explain the complaint procedure to every seafarer on joining
Complaint response times not met (7+2+7 days) | Direct breach of Regulation 5.1.5, possible escalation to external authorities | Actively monitor response times for every complaint filed
Even implicit perception of retaliation against a complainant | Under-reporting of real problems, breach of protection against victimisation | Actively guarantee and communicate that there are no negative consequences for a good-faith complainant

## PSC Observations

As part of MLC inspections, PSCOs verify the existence and functioning of the on-board complaint procedure, the crew's actual awareness of it, and the documentation of any complaints filed together with their response times.

## Operational Tips

- Always provide and explain the complaint procedure to every seafarer on joining, don't just make it available on request.
- Actively monitor response times for every complaint filed, without waiting for the seafarer to have to chase it up.
- Actively communicate that there are no negative consequences for a good-faith complainant.

## Checklist

- Complaint procedure provided and explained to every seafarer on joining
- Contact details for all escalation levels clearly indicated
- Response times (7+2+7 days) actively monitored for every complaint
- Confidentiality and the right of representation guaranteed at every stage
- Complete documentation of the complaint process kept on board

## FAQ

What response times does the MLC complaint procedure require?
The head of department or immediate superior has 7 days to respond; if the complaint is not resolved, the seafarer can approach the Master within 2 days, who has a further 7 days to propose a solution.
What changes with the MLC amendments approved in June 2025?
They add 'appropriate shore-based personnel' as a further level to which a complaint can be addressed, and broaden the definition of victimisation to cover adverse action against complainants, victims, witnesses and whistleblowers; entry into force is expected on 23 December 2027.
Can a seafarer approach external authorities directly without going through the on-board procedure?
The on-board procedure aims to resolve complaints at the lowest possible level, but the seafarer always retains the right to approach the Master, the shipowner and, if necessary, the competent external authorities.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

Designated Person Ashore (DPA)Certificates (IT)Crew Familiarisation and Training

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