When port State control ran a targeted campaign on crew wages and employment agreements, deficiency rates jumped roughly fourfold against the preceding three years. The ships had not changed. What changed was that someone read the contracts.
What the Campaign Actually Found
Between September and November 2024, the member authorities of the Tokyo MOU ran a concentrated inspection campaign on crew wages and seafarer employment agreements under the Maritime Labour Convention, jointly with the Paris MoU. Officers worked from a pre-defined questionnaire covering wages, employment agreements and the financial security arrangements the convention requires.
The results, published in November 2025, make uncomfortable reading. Comparing the campaign against port State control data for the previous three years, there was a significant difference in deficiency rate for almost every question, particularly those relating to seafarer employment agreements. The rate of deficiencies raised on the campaign topic during a three-month window was similar to, or exceeded, the totals for the previous three years, an effective fourfold increase.
That is not a story about a sudden decline in standards. It is a story about what happens when inspectors look closely at documentation that is usually accepted at face value. The report’s own recommendation was that owners and operators pay greater attention to compliance with MLC requirements when establishing and monitoring seafarers’ employment contracts.
The fleet did not get worse during those three months. Inspectors simply read the contracts properly, and the findings were there all along.
Why Documentation Rather Than Conditions
The MLC is popularly understood as the convention about living conditions, accommodation, food, and hours of work. It is those things, and it consolidated dozens of earlier ILO instruments into a single framework covering employment conditions, hours of work and rest, accommodation, recreational facilities, food and catering, health protection, medical care, welfare and social security.
But conditions aboard are visible and expensive to fake, so they tend to be either compliant or obviously not. Contracts, wage records and hours of rest records are documentary, generated ashore, and easy to get subtly wrong in ways nobody notices until an officer sits down with them and a questionnaire. That is the gap the campaign exposed.
The compliance framework is built around two documents on ships of 500 gross tonnage and above: the Maritime Labour Certificate and the Declaration of Maritime Labour Compliance, in Parts I and II. Part I is what the flag State requires; Part II is what the shipowner does about it. Inspections run at intervals not exceeding 36 months, and a port State officer can inspect any ship arriving in port regardless of whether its flag State has ratified, because of the convention’s no more favourable treatment provision.
Where the Findings Concentrate
Seafarer employment agreement: Must be in writing, signed by both seafarer and shipowner, and contain the particulars the convention specifies including the parties’ details, place and date of signing, termination conditions, and health and social security protection. Missing particulars are the most common single failure.
Wages: Payment at no greater than monthly intervals, with an account provided to the seafarer showing what was paid and any deductions, and a means of transmitting earnings to family.
Hours of rest: Records maintained and matching the minimum requirements, and, critically, matching what the ship’s other records show about who was working when.
Repatriation: The entitlement, the circumstances triggering it, and the financial security in place to fund it.
Financial security: Evidence of the cover required for abandonment and for contractual claims arising from death or long-term disability.
Complaint procedures: A documented on-board complaint procedure that crew can actually describe, with a copy provided to each seafarer.
Hours of rest deserves particular attention because it is where documentary compliance meets operational reality. A record showing compliant rest hours that cannot be reconciled with port arrival times, cargo operations and watch schedules is worse than an honest record showing an exceedance, in exactly the same way that back-filled drill records are worse than an admitted gap. An inspector who finds one improbable record starts checking the others.
Where the Exposure Starts for Crewing
Here is the point that matters for anyone providing manpower supply. The convention places obligations on the shipowner, but a very large share of the documentation an inspector examines is generated at the point of engagement, before anyone joins a vessel. The employment agreement is drafted and signed then. Wage terms are set then. The seafarer’s understanding of their entitlements is formed then.
An operator whose crewing partner issues agreements missing required particulars, or whose wage terms do not reflect what the convention requires, has inherited a deficiency they did not create and cannot see. It surfaces months later, in a foreign port, as a finding against their ship.
The contract is signed ashore, months before anyone boards. That is where an MLC deficiency is created, and it is the one place nobody inspects.
Read that way, MLC compliance is not purely a shipboard discipline. It runs back through the crewing chain to the point of placement, which means the standard of the agreements a supplier issues is a direct component of the operator’s regulatory exposure. Where a supplier also handles wage payment and repatriation arrangements, the dependency is deeper still.
What Happens When Something Is Found
The response scales with severity. A port State may record a deficiency and instruct the master to rectify it within a defined period. It may detain the ship until serious deficiencies are rectified, or until it has accepted a proposed plan of action. Where detention occurs, the ship appears in the monthly detention lists published on the Tokyo and Paris MoU websites, which is a reputational exposure that outlasts the port call.
Seafarers also have a direct route. They may complain to a port State inspector during an inspection, and some authorities accept complaints from crew who have already left the vessel. That makes the MLC unusual: it is one of the few conventions where the people it protects can initiate the enforcement themselves.
Preparing Properly
The last item is the one that separates a paper system from a working one. Inspectors interview crew, and an MLC inspection frequently turns on whether what the documents claim matches what the people aboard describe. A seafarer who cannot say how they would raise a complaint, or who does not recognise the wage terms in their own agreement, has answered a question about the operator’s systems rather than about themselves.
None of this is difficult, and almost all of it is settled ashore before a vessel is involved. That is precisely why it goes unexamined until a campaign like the 2024 one puts it under a questionnaire, and the findings arrive four times faster than anyone expected.
Frequently Asked Questions
What did the Tokyo MOU campaign on wages and employment agreements find?
The campaign ran from 1 September to 30 November 2024, jointly with the Paris MoU, using a pre-defined questionnaire on crew wages, seafarer employment agreements and financial security. Comparing results against the previous three years of port State control data showed a significant difference in deficiency rate for almost every question, particularly those on employment agreements, amounting to roughly a fourfold increase during the campaign period.
Which MLC documents must a ship carry?
Ships of 500 gross tonnage and above must carry a Maritime Labour Certificate and a Declaration of Maritime Labour Compliance in Parts I and II, with Part I setting out the flag State’s requirements and Part II describing the measures the shipowner has adopted. Inspections take place at intervals not exceeding 36 months. Seafarer employment agreements, wage accounts, hours of rest records and financial security certificates are examined alongside them.
Can a ship be detained under the MLC?
Yes. Responses range from recording a deficiency with a period allowed for rectification, through to detaining the ship until serious deficiencies are rectified or a plan of action has been accepted. Detentions appear in the monthly lists published by the Tokyo and Paris MoUs. Under the no more favourable treatment provision, a port State may inspect a ship even where its flag State has not ratified the convention.
Why does MLC exposure start at crew placement?
Because much of what an inspector examines is created before anyone joins the vessel. The seafarer employment agreement is drafted and signed at engagement, wage terms are set then, and the seafarer’s understanding of their entitlements is formed then. An operator whose crewing partner issues agreements missing required particulars inherits a deficiency that only surfaces later, as a finding against their ship in a foreign port.
Sources: Tokyo MOU, Report of the 2024 Concentrated Inspection Campaign on Crew Wages and Seafarer Employment Agreement (MLC, 2006), published November 2025, including the comparison of campaign deficiency rates against the previous three years of port State control data · Tokyo MOU and Paris MoU joint announcement of the concentrated inspection campaign, conducted 1 September to 30 November 2024 · International Labour Organization, Maritime Labour Convention, 2006, as amended (Title 2 conditions of employment, Title 4 health protection and social security, and Title 5 compliance and enforcement, including the Maritime Labour Certificate and Declaration of Maritime Labour Compliance)
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