Complaint to the flag state

When an SMS complaint to the master and a written complaint to the company under MLC 2006 Standard A5.1.5 have not produced a remedy, you have the right to escalate directly to the flag state. Every flag state operating under MLC 2006 is required to maintain a complaint procedure for seafarers and to investigate seriously. The flag state can compel the shipowner to act, suspend or withdraw the Maritime Labour Certificate, and detain the vessel. Filing a flag-state complaint does not waive your other rights — you can still contact the ITF, the port-state administration, and the next port-of-call's PSC office.

Step-by-step

1. Identify the flag of the vessel from the Continuous Synopsis Record (SOLAS XI-1 Reg.5) posted on board. The flag state's contact address is in the DMLC Part I.
2. Document the complaint in writing, dated, with copies of any prior on-board complaint and the company's written response (or lack of it).
3. Submit the complaint to the flag state's seafarer complaint contact — most administrations have an email or web form (e.g. RMI, Liberia, Panama, Bahamas all publish dedicated channels).
4. Provide: vessel name and IMO, your full name and rank, dates of relevant events, the specific MLC standard breached, evidence (photos, payslips, OLB extracts, witnesses), and your current contact details.
5. Do not sign off in exchange for promised remedies — get the remedy first or ensure the flag-state file is open and active before signing off.
6. If you are still on board when you file: notify the ITF inspector at the next port so a port-state-control inspection can be requested in parallel.

Evidence to save

• Photo of DMLC Part I onboard (the flag-state contact)
• Written on-board complaint + master's reply (or lack thereof)
• Identifying vessel info: name + IMO + Continuous Synopsis Record extract
• Witness statements where applicable

What NOT to sign

• Any document withdrawing the flag complaint in exchange for promised remedy
• Quittance at sign-off while the flag complaint is open

Legal basis

MLC 2006 Standard A5.1.5 (on-board complaint procedures) and Standard A5.2.2 (flag-state inspection and complaint handling). Flag-state administration contact details are listed on the IMO GISIS website. The flag state must investigate complaints and report back; major flag states publish annual MLC complaint summaries.

Organisations that can help

Disclaimer. General information only — not legal advice. Rules vary by flag state, port state, vessel type, applicable CBA, and contract. For specific cases, contact ITF, ISWAN, your union, or a maritime lawyer.