Certificates, MLC, SMS: The Real Timeline for Crew Wellbeing
Since 1 January 2026, every basic safety training certificate issued under the STCW Code has been expected to cover a competence that did not exist two years ago: contributing to the prevention of, and response to, violence and harassment at sea, including sexual harassment, bullying and sexual assault. The amendment is short. Its practical consequences are not, because the International Maritime Organization attached no transitional provisions to it, leaving each flag state to work out what happens to the certificates already in circulation.
France and the United Kingdom have answered that question differently, and the gap between their two answers is instructive. More instructive still is what neither answer settles: the onboard reporting arrangements that the Maritime Labour Convention will require from December 2027, on a date no national administration can move. Two timelines now run in parallel, one attached to the seafarer, the other attached to the ship, and it is the distance between them that will occupy technical and human-resources departments over the next two years.
The key dates
23 May 2024: the IMO adopts resolution MSC.506(108), adding to STCW Table A-VI/1-4 a new competence on preventing and responding to violence and harassment, including sexual harassment, bullying and sexual assault.
1 January 2026: the amendments enter into force, with no transitional provisions.
24 November 2025: the French administration confirms that certificates issued before transposition remain valid until their five-year expiry, with the top-up delivered at refresher training.
31 March 2027: the UK Maritime and Coastguard Agency's deadline for a free online top-up module of roughly one hour.
23 December 2027: the MLC amendments adopted on 6 June 2025 enter into force, requiring prevention policies and safe reporting mechanisms on board.
Two flag states, two readings of the same amendment
The regulatory mechanics are worth following closely, because they explain both decisions. Resolution MSC.506(108) creates the competence; resolution MSC.560(108) sets out the amendment procedure under Article XII of the STCW Convention, with an acceptance date of 1 July 2025 and entry into force on 1 January 2026. Because no transitional arrangement was built in, every administration had to decide what to do with certificates already held.
France chose operational continuity. A bilingual attestation signed on 24 November 2025 by the Director of Seafarers states that certificates issued before transposition into French law remain valid until their five-year expiry, with the additional training on violence and harassment delivered during the mandatory refresher. The document is designed to be handed straight to a Port State Control inspector. The United Kingdom took the opposite view: rather than wait for revalidation, the MCA requires a free online module of about an hour, to be completed before 31 March 2027.
For a mixed-nationality fleet, that means two sets of deadlines for one and the same competence, sometimes among officers serving on the same vessel. The difficulty is not regulatory. It is organisational, and it lands on whoever keeps the crew records.
December 2027: wellbeing enters the safety management system
The second timeline belongs to the Maritime Labour Convention. The amendments adopted on 6 June 2025 at the 113th session of the International Labour Conference enter into force on 23 December 2027. Regulation 4.3 explicitly prohibits violence, harassment, sexual harassment and bullying, and requires shipowners to put prevention policies in place alongside safe reporting mechanisms. Regulation 5.1 widens whistleblower protection and broadens the definition of retaliation.
The difference in kind from the STCW strand is considerable. Training qualifies an individual; a reporting procedure has to exist on board, be documented, be known to the crew and be verifiable. It therefore belongs in the safety management system and in Part II of the Declaration of Maritime Labour Compliance, next to the ISM procedures operators already run. Crew wellbeing stops being a management intention and becomes an auditable compliance line.
The real friction: knowing who owes what, ship by ship
Holding both timelines together calls for information many operators do not have in usable form: the expiry date of every certificate, seafarer by seafarer, matched against each seafarer's assignment, ship by ship. As long as certificate tracking lives in a shared spreadsheet, the exercise remains possible but fragile. One tab per vessel, a column of dates, and a reminder nobody receives because the file sends nothing: the arrangement holds for exactly as long as the person who built it stays with the company.
The cost of approximation is not theoretical. Port State Control detentions are rising, and an expired certificate remains one of the easiest non-conformities for an inspector to record. From late 2027, a different risk is added to it: a reporting procedure whose existence is documented but which nobody on board knows how to use.
A subject that changes owner inside the organisation
This may be the most interesting effect of the two deadlines. Until now, harassment prevention sat with human resources, when it sat with anyone at all. Crew wellbeing was treated as a matter of morale, measured by retention figures and by what masters mentioned informally.
Writing it into the safety management system moves the cursor. The superintendent now sees a documentary requirement that will be checked during an inspection; the HR manager sees a procedure to keep alive and to make known; the sustainability lead sees a reportable indicator. Three readings, one object, and a clear need to say who owns it. Operators who settle that governance question before 2027 will approach the deadline far more calmly than those who discover it while revising their Declaration of Maritime Labour Compliance.
A certificate proves training, not a working procedure
The thread running through both timelines comes down to one sentence: a certificate proves that a seafarer has been trained, it does not prove that a procedure works. The national decisions of late 2025 settle the first point for the next few years; the second remains open, and its date is already fixed. Between the two, what most operators lack is a consolidated view of who needs which training, by when, on which ship.
That is precisely what the BoatOn Book crew management module brings together: every seafarer's certificates and their expiry dates, their assignment to vessels and the alerts that go with them, in the same tool as maintenance plans and onboard documents. Enough to know, without opening a spreadsheet, who is covered and who is not. See the BoatOn Book modules.
Sources: attestation issued by the French Director of Seafarers on 24 November 2025, circulated by the French International Register single window; IMO resolutions MSC.506(108) and MSC.560(108); 2025 amendments to the Maritime Labour Convention, 2006 (International Labour Organization); UK Maritime and Coastguard Agency. Stock photograph — Pexels.
