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TECHNICAL NOTE No. TECH-008-2026 MMC-336, amendments Regulations 2.5 (repatriation) and 4.2 (ship-owner´s liability).
The purpose of this technical note is to provide clear and updated information to Recognized
Organizations, inspectors, shipowners, operators, and other stakeholders regarding the amendments to
the Maritime Labour Convention, 2006 (MLC, 2006). Specifically, it outlines the financial security
requirements established under Regulations 2.5 (Repatriation and Abandonment) and 4.2 (Shipowners’
Liability), as well as the obligations that must be verified during inspections on board Panamanian‑flagged
vessels. This guidance aims to ensure uniform implementation and compliance with the amended
Convention, in accordance with the procedures and standards of the General Directorate of Merchant
Marine and the Segumar Offices.
1. Regulation 2.5 – Repatriation / Abandonment
The amendments strengthen the financial security system to ensure prompt assistance to seafarers in
cases of abandonment.
A seafarer is considered abandoned when the shipowner:
• Fails to cover repatriation costs.
• Leaves the seafarer without necessary maintenance and support.
• Unilaterally cuts ties, including non-payment of wages for at least two months.
Shipowner obligations:
• Maintain valid financial security (P&I Club or insurer).
• Coverage must include food, accommodation, drinking water, essential fuel, and medical care.
• Seafarers must be able to file claims directly with the insurer.
• All ships must comply from the date the amendments enter into force.
2. Scope of Financial Assistance
Financial security must cover:
• Up to four months of outstanding wages and entitlements.
• All reasonable expenses incurred by the seafarer, including repatriation.
• Essential needs: food, clothing (if needed), accommodation, water, fuel, medical care, and other
reasonable costs until arrival home.
3. Repatriation Costs Covered by the Shipowner
Minimum coverage includes:
• Transportation to: place of engagement, CBA-stipulated location, country of residence, or any
agreed place.
• Fast and appropriate transport; air travel when required.
• Food and accommodation from disembarkation until arrival.
• Wages and allowances during repatriation.
• Transport of 30 kg of personal luggage.
• Medical treatment until the seafarer is fit to travel.
4. Regulation 4.2 – Shipowners’ Liability
Shipowners must maintain financial security to ensure compensation in cases of:
• Death or
• Long-term disability resulting from occupational injury, illness, or hazard.
This requirement aligns with Executive Decree No. 86 (2013), Article 172.
5. Mandatory Onboard Documentation
Panamanian-flagged ships must carry:
• Certificates or documentary evidence of both financial securities (A2.5.2 and A4.2.1).
• Copies posted in a location accessible to seafarers.
• If multiple providers exist, documents from each must be onboard.
6. Declaration of Maritime Labour Compliance (DMLC)
DMLCs issued from 18 January 2017 must include:
• Financial Security for Repatriation (Reg. 2.5).
• Financial Security for Shipowner’s Liability (Reg. 4.2).
7. Transitional Measures (ILO Resolution, April 2014)
Member States must:
• Recognize a transitional period for issuing/renewing MLC Certificates and DMLCs.
• Ensure compliance with amended requirements no later than the first renewal inspection
after the amendments enter into force.
8. RO Verification
During initial, intermediate, and renewal inspections, ROs must:
• Verify the presence and validity of both financial securities.
• Include this verification in the MLC checklist.
9. Change of P&I Club or Insurer
Shipowners must notify the General Directorate of Merchant Marine and submit updated policies to:
• mlc@segumar.com
• mlcassist@segumar.com
10. Definition of Shipowner (MLC, 2006 – Article II, 1(j))
Includes:
• Registered owner,
• Manager,
• Agent,
• Bareboat charterer who assumes operational responsibility and MLC duties.
SEA signing: If another entity employs the seafarer, it may sign the SEA only as representative of
the shipowner, with proper authorization.
11. Identification on Financial Security Documents
Financial securities under Standards A2.5.2 and A4.2.1 must clearly state:
• The name of the shipowner, or
• The registered owner (if different).
If you want, I can also prepare:
• A bilingual (EN/ES) version,• A checklist for inspectors, or
• A formal circular format