MLC 2006: visa-free shore leave and seafarers as "key workers" from December 2027

The 2025 amendments to the Maritime Labour Convention enter into force on 23 December 2027: shore leave without a visa or special permit, written reasons for any refusal, itemised repatriation costs, seafarers recognised as key workers. What a yacht should prepare.

MLC 2006: visa-free shore leave and seafarers as "key workers" from December 2027
14 October 2026 · 6 min read

This article is part of our complete reference guide.

On 23 December 2027 the Maritime Labour Convention 2006 changes for the fifth time since 2014. The amendments adopted by the International Labour Conference on 6 June 2025 are known; what they mean in practice for a yacht crew is less so. Two publications have just clarified it: the sixth edition of the ILO’s frequently asked questions on the Convention, released on 4 June 2026, and a SAFETY4SEA briefing of 12 October 2026 that separates what already applies from what enters into force in fourteen months.

For a yacht, the essential part is not the new provisions on harassment, already covered here. It lies in three everyday matters: going ashore, getting home, and being recognised as a seafarer by the administrations one passes through.

The timeline, and why it is settled

Amendments to the Code of the Convention follow the Article XV procedure. Approved by the Conference on 6 June 2025, they were notified to ratifying States on 23 June 2025. Those States have until 23 June 2027 to express formal disagreement; unless more than 40 per cent of them, representing at least 40 per cent of world tonnage, object, the amendments enter into force six months later, on 23 December 2027. None of the four previous sets came anywhere near that threshold. The date should be planned for as a certainty.

The Convention today binds 113 States, Cuba having ratified it in June 2026. For yachting, that covers the reference flags as well as the port States where the season is played out: France, Spain, Italy, Malta, Croatia and Greece. Oman, in 2022, was the first Gulf State to ratify it.

Shore leave: what Standard A2.4.2 requires of port States

This is the most concrete provision in the package. A new Standard A2.4.2 obliges the port State to allow seafarers ashore while the ship is in port, once arrival formalities are completed, unless there are grounds of public health, public safety and security, or public order. Three points define the rule.

No visa or special permit may be required of a seafarer for shore leave. The wording targets that precise purpose: shore leave, not transit, not joining a ship, not residence.

A refusal must be reasoned in writing. When the authority refuses shore leave, it must give the seafarer its reasons, in writing. That is the end of the verbal decision at the foot of the gangway, with no record and no recourse.

Without discrimination, including on the ground of the ship’s flag. The shipowner, for its part, facilitates shore leave taking account of operational requirements and the crew’s well-being.

For a non-EU crew in the Mediterranean, this text has to be read alongside two others. The Schengen Borders Code already provides a shore-leave regime for seafarers listed on a crew list lodged in advance. And the EES has recorded every crossing since 10 April 2026, with a strict count of 90 days in 180. Standard A2.4.2 touches neither: it opens no right of stay and does not pause the counter. What it changes is the crew’s position when a local port practice treats a yacht seafarer as a tourist, or demands a permit the Convention rules out. From December 2027, the refusal will have to be written, and the port State will have to be able to justify it before the ILO.

Repatriation: the list of costs a shipowner can no longer argue about

The right to repatriation already existed. Standard A2.5.1 receives a new paragraph 3 setting the minimum borne by the shipowner:

  • passage to the chosen destination;
  • accommodation and food from leaving the ship until arrival;
  • carriage of 30 kg of personal luggage;
  • medical treatment, when needed, until the seafarer is fit to travel.

A new paragraph 10 further requires each State to facilitate the repatriation of seafarers without discrimination, irrespective of the ship’s flag.

In yachting, the repatriation clause of an employment agreement often refers to “an economy-class ticket” and the airline’s baggage allowance. Twenty-three kilos, an unplanned hotel night, a seafarer signed off injured abroad: each of these situations becomes, in December 2027, a gap between the contract and the Convention. Contracts get re-read before, not after.

Key workers: a guideline, not an obligation

Guideline B2.5.2 asks each State to designate and recognise seafarers as key workers, and to take measures to facilitate their safe movement: shore leave, repatriation, crew changes, medical care ashore. It is the first time an international labour instrument has recognised a category of workers in this way.

A guideline belongs to Part B of the Code: States must give it due consideration without being bound by it. Its concrete reach will therefore depend on administrations, at borders as in consulates. The text is no less useful to a manager: it names what crews have been asking for years, a crew change in Palma or Antibes treated as a maritime operation rather than a leisure trip.

The rest of the package

Three further sets of amendments complete the whole, and all four rest on the same date.

Violence and harassment. Standard A4.3 receives a new subparagraph on the prevention and elimination of violence and harassment, including sexual harassment, bullying and sexual assault, by reference to ILO Convention No. 190. The shipowner adopts policies and measures; the on-board complaint procedure gains in confidentiality and in protection against victimisation. The corresponding STCW training has been mandatory since 1 January 2026.

Recruitment and placement. Recruitment services are invited, by guideline, to provide measures against violence, harassment and sexual assault. A manager who recruits through an agency should know what that agency has put in place.

Fair treatment of detained seafarers. Guideline B4.4.6 now refers to the joint ILO/IMO guidelines on the fair treatment of seafarers detained on suspicion of a maritime crime, adopted at the end of 2024, and to the IMO casualty investigation code. After the Bayesian inquiry, yachting knows what that reference is worth.

What a yacht prepares before December 2027

Nothing new is required today. But most of the documents concerned are renewed on a five-year cycle, with an intermediate inspection, and the flag will issue its implementing circular in the course of 2027. The work fits in a short list.

  • Re-read the employment agreements: repatriation clause aligned with the new paragraph 3 (passage, accommodation, food, 30 kg, medical care until fit to travel), an explicit repatriation destination, and an up-to-date complaint procedure.
  • Check the financial security for abandonment and repatriation: that the certificate posted on board does cover medical costs until fit to travel.
  • Update Part II of the DMLC: shipowner’s measures to facilitate shore leave, anti-harassment policy, reporting channel with a shore-side outlet. Part I will follow the flag.
  • Write shore leave into the SMS: planning compatible with hours of rest and the ship’s requirements, crew lists lodged before arrival so that formalities are deemed completed, and retention of any written refusal.
  • Keep the Schengen count for every non-EU seafarer, independently of shore leave: Standard A2.4.2 does not replace it.
  • Qualify recruitment agencies on their prevention measures, and record it.

For a private yacht, the prior question remains applicability, which depends on flag and tonnage; our reading of the Convention from the seafarer’s side recalls the thresholds. For a commercial yacht, the question does not arise.

The Convention asks nothing that well-run programmes do not already practise: an organised crew change, a seafarer repatriated without counting bags, a run ashore that does not depend on the mood at a counter. The difference, from December 2027, is that these practices become verifiable by the port State. What we do in MLC crew management is write them down before an inspector reads them. The complete MLC 2006 guide remains the reference for the rest of the Convention.

Sources

Frequently asked questions

Does visa-free shore leave exempt the crew from the Schengen day count?
No. Standard A2.4.2 prohibits requiring a visa or special permit for the purpose of shore leave, once arrival formalities are completed. It creates no right of stay and changes neither the 90-days-in-180 rule nor EES registration. A non-EU seafarer who goes ashore uses up days exactly as before.
Do these amendments apply to a private yacht?
It depends on the flag. The MLC applies to commercial yachts; for private yachts, the Cayman Islands, Marshall Islands and Isle of Man registers apply it from 500 GT on international voyages. Below that, the flag generally applies a lighter regime modelled on the same text.
What should be done before 23 December 2027?
Re-read the repatriation clause of the seafarer employment agreements (minimum costs, 30 kg of luggage, medical care until fit to travel), check that the financial security covers those items, update Part II of the DMLC and the complaint procedure, and write shore leave into the safety management system. The flag will issue its circular in the course of 2027.
Portrait of Jean Pousthomis

By

Jean Pousthomis

Master Mariner · STCW II/2 unlimited · Founder & DPA, Cursorio

Master Mariner and founder of Cursorio. Externalised DPA for private superyachts held directly or via family office.

LinkedIn

Tags

MLC 2006 shore leave repatriation key workers crew ILO regulation

A question about this topic?

A one-hour discussion clarifies your situation and identifies the next steps. Confidential, no commitment.

Get in touch