Illegal recruitment fees push seafarers into debt, erode vessel safety, and expose shipping companies to growing legal and reputational risk. This resource combines the latest research evidence with a practical compliance toolkit for employers.
According to the ILO Maritime Labour Convention 2006 (as amended), "no fees or other charges for seafarer recruitment or placement … are borne directly or indirectly, in whole or in part, by the seafarer, other than the cost of obtaining a national statutory medical certificate, the seafarer's book and a passport — not including the cost of visas, which shall be borne by the shipowner."
In addition to recruitment fees are a host of additional costs whose legitimacy and responsibility are not clear in law. There are also costs and charges that violate not only MLC but anti-corruption norms and national law. The below graphic aims to encapsulate these. Costs can accumulate all along the seafarer's journey from home (1.) through transit (2.) to vessel (3.). It should be noted that the distinction between the various categories is not always easy to define. It is also not always clear who the employer is or where accountability lies. The 'beneficial employer' is whoever is operating the ship, and is arguably who should be responsible for costs relating to recruitment.
Recruitment fees are not always charged openly. In practice, they may be disguised as inflated training charges, medical facilitation fees, document processing costs, advance cash payments before onboarding, or loans linked to job placement. Even where they are described differently, such payments may still amount to recruitment fees if the seafarer is required to pay in order to secure or keep a job.
There are many actors involved in the costs outlined below, and beneath the graphic we have included a table.
Actions that violate MLC or anti-corruption norms
Retaining passports, certificates of competency, or any other identity documents as 'security' at any stage of recruitment or employment. While some ships legitimately hold documents for safe-keeping during voyages, crewing agencies and managers should not unlawfully withhold passports.
While this is not a recruitment fee, such practices could be attributed to coercion tactics, such as the retention of documents to ensure payment of a recruitment fee. Document confiscation is a recognised indicator of forced labour and trafficking under ILO Convention No.29 and the Palermo Protocol.
| Stage | Event | Main actors |
|---|---|---|
| At home | Agency placement / service charges, including sub-agent charges | Local broker, sub-agent, licensed crewing agency |
| Selection tests and assessments required by the employer | Ship operator, crewing agency, testing centre/educational institution | |
| Background verification and security clearance required by the employer | Crewing agency, Government office | |
| Pre-departure orientation and instructions | Crewing agency, ship operator, unions | |
| Visa and travel permits for joining the vessel | Crewing agency, visa agent, embassy or consulate | |
| During transit | Airfare and local travel to the port of embarkation | Travel agent, airline, crewing agency |
| Accommodation and subsistence during transit and employer-caused delays | Hotel provider, crewing agency, ship operator | |
| Immigration and port formalities / fees required for joining | Port agent, immigration authority | |
| Assignment-specific endorsement / familiarisation | Ship operator, flag state, training provider | |
| Vessel type-specific certification | Ship operator, training institute | |
| When on board | Branded uniforms | Ship operator, onboard management |
| Personal protective equipment | Ship operator, onboard management | |
| Recruitment fee recovered through salary deduction | Ship operator, onboard finance team, crewing agency |