Preparing Passenger Ships for MLC Compliance in 2027 Amid Heightened Security Risks

The Maritime Labour Convention (MLC) is an important international maritime regulation, often referred to as the "Seafarer Bill of Rights." On June 6, 2025, the International Labour Organization (ILO) amended the MLC, which applies broadly to any person "employed, engaged, or working in any capacity on board a covered ship." The MLC amendments are expected to go into effect on December 23, 2027, and will have far-reaching implications for the maritime industry, especially the tourism, hospitality and leisure industries.

This Holland & Knight alert summarizes the key changes on the horizon and outlines practical compliance steps shipping interests, ship managers and operators should consider now.

Key 2025 Amendments

• Violence and Harassment: The amendments to Regulation 4.3 (Health and Safety Protection and Accident Prevention) explicitly prohibit shipboard violence, harassment, sexual harassment, bullying and sexual assault. Member States are required to define these terms in accordance with Article 1.1(a) of the ILO Violence and Harassment Convention, 2019 (No. 190). Shipping interests should seek advice concerning the adoption and implementation of relevant policies and measures to prevent and address these behaviors and to establish safe, fair and effective reporting mechanisms. For passenger ships with large crews and extensive guest-facing operations, the scope of these new obligations is significant and creates a legal liability rubric for operators that do not maintain robust prevention and response programs.
• Recruitment and Placement: New provisions under Regulation 1.4 require recruitment and placement services to implement measures to prevent and address violence, harassment and sexual assault, ensuring ethical and safe employment practices from the outset. Shipping interests that rely on third-party crewing agencies and staffing companies should ensure that their recruitment partners are prepared to comply with these enhanced standards.
• Shore Leave: Regulation 2.4 has been amended to formalize seafarers' entitlement to non-discriminatory shore leave. Visa or special permit requirements for shore leave are eliminated, and port authorities are to provide written reasons for any denial. Shipping interests are to facilitate shore leave in line with operational needs and seafarers' well-being. Given the tight turnaround schedules that characterize many passenger ship itineraries, operators will need to review their scheduling practices to ensure meaningful shore leave opportunities for crew. Shipping interests should also ensure that seafarers are well informed of their rights to shore leave.
• Repatriation and Key Worker Status: Under the amendments to Regulation 2.5, seafarers are formally recognized as "key workers," and Member States are obligated to facilitate their movement for repatriation, shore leave and medical care. Shipping interests' financial responsibilities for repatriation have been clarified to include travel, accommodation, food, medical treatment and personal luggage. The "key worker" designation is intended to prevent a recurrence of the crew change crises experienced during the COVID-19 pandemic, during which thousands of crew members on passenger ships were stranded at sea.
• Gender-Specific Health Needs: Ships will now be required to provide appropriate menstrual hygiene products and disposal facilities onboard, addressing gender-specific health needs and promoting inclusivity. Though many modern passenger vessels may already provide such amenities, operators should confirm that their onboard supplies and waste management procedures meet these new requirements.
• Medical Care: Amendments to Regulation 4.1 added the International Medical Guide for Seafarers and Fishers (First Edition, 2023) as a new international standard governing onboard medical training. Shipboard medicine chests and equipment must align with these updated standards. Passenger ship operators, which often maintain onboard medical facilities, should audit their medical supplies, training protocols and staffing to ensure compliance.
• Complaint Procedures: Revisions to Regulation 5.1 strengthen confidentiality and anti-victimization safeguards in onboard complaint procedures. Seafarers must be able to report grievances without fear of retaliation, and protections are also introduced against "vexatious" or malicious complaints. These enhanced protections will require careful review of existing grievance and disciplinary procedures.

The Amendments in Context: Conflict Zones and Warlike Operations Areas

The 2025 MLC amendments arrive against a backdrop of escalating maritime security threats. The International Bargaining Forum (IBF) has designated multiple regions as Warlike Operations Areas (WOAs) or High-Risk Areas, including the Persian Gulf, Strait of Hormuz and Gulf of Oman. Under the IBF framework, seafarers on covered vessels operating in WOAs may trigger enhanced protections in connection with wages and related benefits. Ongoing hostilities and security restrictions have resulted in seafarers experiencing extended service periods or delayed repatriation in the region, prompting unions – including the International Transport Workers' Federation (ITF) and Nautilus International – to urge Flag States in ensuring that MLC rights are upheld despite the mounting pressures of armed conflict.

Although the amendments do not override Port State security measures or armed‑conflict restrictions, they nonetheless strengthen the legal foundation underlying seafarer protections in conflict‑affected regions. For example, the amendments to Regulation 2.4 on shore leave eliminate visa requirements for shore leave and require port authorities to communicate the reasons for any denial, introducing greater transparency that may be relevant in conflict‑affected ports even where disembarkation remains restricted. Additionally, the enhanced repatriation framework under Regulation 2.5, together with new guidance recognizing seafarers as "key workers," reinforces expectations that Member States, to the extent practicable, facilitate crew changes, repatriation and access to medical care even amid geopolitical disruption. The strengthened repatriation provisions clarify the scope of shipping interests' financial obligations (including travel, accommodation, food, medical treatment and personal luggage), adding specificity that may reduce disputes when crews are stranded in hostile waters. Although the amendments will not enter into force until December 23, 2027, shipping interests with vessels operating in or near designated WOAs should consider aligning their employment agreements, safety management systems and repatriation procedures with these forthcoming requirements now, particularly given the heightened disputes and enforcement risk that conflict zone operations present.

International Convention on Standards of Training, Certification and Watchkeeping Harassment Prevention Training

Under MLC Regulation 1.2, seafarers are to obtain medical certification confirming their fitness for duty prior to beginning work aboard a ship. The MLC accepts medical certificates issued in compliance with Standards of Training, Certification and Watchkeeping (STCW) standards as valid certificates.

As of January 1, 2026, amendments to the STCW Code (Table A-VI/1-4) introduce a new mandatory minimum standard of competence relating to the prevention of and response to violence and harassment, including sexual harassment, bullying and sexual assault. This competence must be incorporated into basic safety training courses, and all seafarers completing entry-level certification or recertification from January 2026 onward are to demonstrate competency in recognizing, preventing and responding to harassment situations. The one-year gap between the implementation of the updated STCW and MLC amendments offers shipowners essential time to ensure their crews receive this foundational training before the expanded legal duties under the MLC take effect. Existing crew members' certifications generally remain valid until the expiration of their existing certification.

Practical Compliance Steps

• Conduct a gap analysis of Safety Management Systems (SMS), employment agreements and onboard policies against the 2025 MLC amendments and related STCW requirements.
• Adopt or enhance policies addressing violence and harassment – including prohibited conduct, reporting channels, investigation procedures and anti‑retaliation protections – and integrate these measures into the SMS and onboard training frameworks.
• Confirm that placement services and other third-party agencies and concessionaires comply with enhanced Regulation 1.4 requirements in connection with seafarer recruitment.
• Review port call schedules and operational planning to assess the practical availability of shore leave, taking into account procedural protections under Regulation 2.4 and prevailing security restrictions in high‑risk ports.
• Audit onboard medical facilities, medical evacuation planning, crew medical training and shipboard certifications against updated international standards.
• Review and update onboard grievance and complaints mechanisms to ensure compliance with strengthened confidentiality, reporting and anti‑victimization requirements.
• Maintain current and valid MLC medical certifications and conduct internal audits ahead of December 2027.
• Review seafarer employment agreements and collective bargaining agreements to confirm compliance with IBF WOA and High-Risk Area designations, including war-risk bonuses, enhanced death and disability compensation, rights of refusal to sail and repatriation obligations.

Conclusion

The 2025 MLC amendments are the most significant expansion of seafarer protections in recent years. Although the 2025 amendments will not go into effect until December 23, 2027, the compliance window is narrowing. Early implementation is recommended to mitigate litigation exposure and demonstrate good faith compliance.

For questions about how these developments may affect your operations, please contact the authors.

Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.