ILO Convention 181 (Private Employment Agencies), Article 7, states plainly: private employment agencies shall not charge directly or indirectly, in whole or in part, any fees or costs to workers. MLC 2006 Standard A1.4(5)(b) repeats this requirement specifically for maritime manning agencies. Any fee charged to you as a seafarer — whether called a 'processing fee', 'documentation fee', 'training levy', 'joining fee', or 'visa cost' — is unlawful, and the agency that charged it can have its licence suspended or cancelled by the national licensing authority. In the Philippines this is the DMW (Department of Migrant Workers, successor to POEA); in India it is the Director General of Shipping under the MS (Recruitment and Placement of Seafarers) Rules 2016; in Ukraine it is Maradmin. Common scams go further: fake joining letters with upfront-payment pressure, fraudulent STCW certificates that will be detected on the STCW white list, and bogus agencies with no licence at all. Always verify the agency's licence on the official register before paying anything or travelling. For the full legal framework, see /reference/mlc.
What this usually means
Manning agencies and operators sometimes require you to pay for STCW courses, type-specific endorsements (chemical tanker, gas tanker, ECDIS familiarisation), or 'sponsored' cadetship costs. Many of these charges violate ILO Convention 181 Article 7 (no fees to workers) and MLC 2006 Standard A1.4(5)(b). This topic covers identifying recoverable fees, the bond / training-recovery clauses that operators try to enforce, and recovery routes.
Step-by-step
List every fee you have paid: course tuition, examination fee, medical, certification fee, agency fee, visa fee, joining-fee, 'document handling' fee. Keep receipts and bank statements.
Identify the lawful fees. Most jurisdictions permit: your STCW basic certificate (BST) costs (you are responsible for entry-level qualifications); your CoC examination fee paid to the flag state directly; your medical certificate (some CBAs require employer reimbursement). Most other fees charged TO the seafarer are unlawful under ILO C181 Art. 7.
Identify training-recovery / bond clauses in your SEA. These typically state: 'Should the seafarer leave employment within X years, training costs of Y are recoverable.' Where these are ILO C181-non-compliant, they are unenforceable. Where the operator has actually paid the cost (e.g. genuine sponsored cadetship), the clause may be partially enforceable.
Demand a refund in writing from the manning agency. CC the manning agency's licensing authority (DMW PH, DG Shipping IN, Maradmin UA).
If the agency refuses: file complaint with the licensing authority. Philippines DMW has a Migrant Workers and Overseas Filipinos Act 8042 process that can refund and cancel agency licences.
If a bond is being enforced against you: dispute on the ILO C181 ground. Most national labour courts will find a bond unenforceable where the seafarer paid the fees in the first place — the operator cannot 'recover' what it never spent.
Evidence to save
Receipts and bank transfer records for every fee paid to the agency — date, amount, stated purpose.
Written quote or invoice from the agency itemising all fees charged.
The agency's licence number as stated in the contract or on their letterhead.
Screenshot of the licensing authority's online register confirming (or failing to confirm) the licence.
Any joining letter or job offer received — fake ones often use generic vessel names, missing IMO numbers, or misspelled shipping company names.
WhatsApp or email chains showing pressure to pay quickly 'to secure the berth'.
Your STCW certificates with the issuing flag state's reference — needed if you suspect a certificate is fraudulent.
What NOT to sign
Any agreement to pay fees to the manning agency before, during, or after employment — unlawful under ILO C181 Art. 7.
A training-bond or training-recovery clause where the 'costs' being recovered were actually paid by you, not the operator.
A document that calls an unlawful agency fee a 'voluntary contribution' or 'advance on wages'.
An employment contract from an agency that cannot show you a valid, current licence from the relevant national authority.
Any NDA or confidentiality clause covering the fees you were charged — these are used to prevent you reporting to the licensing authority.
A 'no-fault cancellation' clause that lets the agency keep fees if the contract is cancelled for any reason.
Escalation path
Before paying anything: verify the agency licence on the official register (dmw.gov.ph for PH, dgshipping.gov.in for IN, marad.gov.ua for UA).
If you have already paid unlawful fees: demand a refund in writing, CC the licensing authority in the demand.
File a complaint with the licensing authority — DMW Philippines (formerly POEA), DG Shipping India, Maradmin Ukraine — with receipts as evidence.
Contact the ITF Inspectorate — ITF runs campaigns against FoC-vessel crewing agencies that charge placement fees.
Report fake STCW certificates to the issuing flag state's maritime administration and to IMO (who maintain the STCW white list of recognised flag states).
For criminal fraud (fake joining letters, identity theft): report to national police with all digital evidence preserved, including message metadata.
Legal basis
ILO Convention 181 (Private Employment Agencies), Article 7: 'Private employment agencies shall not charge directly or indirectly, in whole or in part, any fees or costs to workers.' MLC 2006 Standard A1.4(5)(b) (recruitment placement services free to seafarers). National manning-agency licensing: PH RA 11641 (DMW), IN MS Rules 2016, UA Maradmin licensing regime. Cadetship-sponsorship recovery clauses are enforceable only where genuine costs were incurred AND C181 is not implicated.
Disclaimer. General information only — not legal advice. Rules vary by flag state, port state, vessel type, applicable CBA, and contract. Where a fact below is critical to your case, verify against the cited source and consider professional advice.