Flag-state complaints

Every flag state that has ratified MLC 2006 is required, under Standards A5.1.5 and A5.2.2, to maintain a complaint procedure specifically for seafarers and to investigate those complaints seriously. The DMLC Part I — the flag state's own document, displayed on board — lists the national measures implementing each MLC area and must include the flag state's contact point for seafarer complaints. The IMO Global Integrated Shipping Information System (GISIS) provides contact information for every maritime administration in the world. Filing a flag-state complaint does not waive or limit any other right you have: you can simultaneously contact the ITF, file a PSC complaint at the next port, and continue through the onboard procedure. The flag state can compel the shipowner to act, suspend or withdraw the Maritime Labour Certificate, and in severe cases detain the vessel. Major flag states — Liberia, Marshall Islands, Panama, Bahamas, Cyprus — all publish dedicated seafarer complaint contact channels and are expected to acknowledge and investigate within defined timeframes under MLC. For the full technical treatment, see /reference/mlc.

What this usually means

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

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.
Document the complaint in writing, dated, with copies of any prior on-board complaint and the company's written response (or lack of it).
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).
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.
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.
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

The vessel's flag from the Continuous Synopsis Record (CSR) posted on board under SOLAS XI-1 Reg. 5 — this tells you which flag administration to contact.
Photograph of the DMLC Part I posted in the messroom — it contains the flag state's contact address for seafarer complaints.
Copies of your prior onboard complaint submissions and any responses — evidence that you have exhausted internal procedure.
All documentary evidence of the breach: wage accounts, photographs, medical records, witness names.
The vessel's IMO number, current port or position, and your full name and rank.
Written record of any retaliation following a complaint already raised.
The flag state complaint acknowledgement number or reference once received — keep this to track the case.

What NOT to sign

Do not sign off in exchange for a promise that the flag state will resolve the matter — file the complaint first and keep the case open while you are still on board.
Any document waiving your right to complain to the flag state or PSC as part of resolving an onboard dispute.
A release of claims before the flag state has confirmed in writing that the specific breach has been remedied.
Any agreement to withdraw your flag-state complaint in exchange for verbal assurances from the company.

Escalation path

Identify the flag from the Continuous Synopsis Record on board. Look up the flag state's maritime administration contact on GISIS (gisis.imo.org) or from the DMLC Part I.
Send a written complaint — email where available — with: vessel name and IMO, your name and rank, specific MLC standard breached, timeline of events, copies of supporting evidence.
Keep a copy of everything sent. If the flag state does not acknowledge within 14 days, resend and notify the ITF.
In parallel: notify the ITF inspector at the next port to request a PSC inspection — you do NOT waive PSC rights by filing with the flag state.
If the flag state fails to act within a reasonable time: escalate to the ILO's MLC monitoring body via the national workers' organisation (your union) or directly through an ITF affiliate.
For publicly listed vessels, the flag state complaint record is discoverable under Paris MoU / Tokyo MoU databases — PSC inspectors share non-confidential flag-state complaint data.

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.