Martin Lex is the pen name of the 7S1L safety desk: SOLAS, lifesaving and firefighting gear, muster drills, emergency signals and safe work on board. Portrait is illustrative.
Walk the crew alleyway of one of the world's big cruise ships and the flag certificate in the ship's office quite often says Nassau. The Bahamas Maritime Authority (BMA) registers a major share of the global cruise fleet, which makes it the flag state behind tens of thousands of hotel department contracts: stewards, waiters, cooks, bar teams, spa staff. When something breaks and the company does not fix it, the BMA is where the flag route leads. This guide walks the whole route of an MLC complaint under the Bahamas flag: evidence, the on-board procedure, the flag state desk, and the doors that stay open in every port.
What a Bahamas cruise SEA must contain in the first place, from the guaranteed monthly total to the repatriation clause, lives in our companion guide to cruise ship crew contracts and MLC rights. This page is about enforcement.
One rule carries everything here. Paper beats memory. A complaint is exactly as strong as the dated copies behind it.
Secure the evidence before you complain
Say a restaurant steward has been rostered past the working hour limits for six weeks and the overtime never shows on the wage statement. The case starts long before any email to Nassau. Photograph the SEA, every monthly wage account (the shipowner owes you one under MLC Standard A2.2), the posted duty roster, and your rest hour records. The ship must keep those records. Ask for yours. For an hours case they matter more than anything else you own.
Use your own phone and back everything up off the ship, on the first crew Wi-Fi package if you have to. Access to the crew office printer and the ship's systems can end the moment a dispute starts. Then keep a timeline in plain dates: the day the roster first broke the limits, the port where the food and beverage manager said the sheet would be "fixed later", the names of crewmates on the same station. A steward with a dated timeline and twelve photos is a case. A steward with a memory is a story. Hand over copies only. Originals stay with you.
Clauses that try to sign away the right to complain are void, and they are exactly the kind of tell our guide to seafarer employment agreement red flags teaches you to spot before you fly out.
Start on board: the MN033 ladder
On Bahamas-flagged ships the on-board procedure follows BMA Marine Notice MN033, and it runs up a ladder the hotel department already knows. The written complaint goes first to your head of department or supervising officer: for a cabin steward the housekeeping manager, for a cook the executive chef. If that level cannot resolve it, you refer it to the master, who under MN033 handles the matter personally. Keep a dated copy of every step and note who received it. That copy becomes the spine of the case.
MLC Regulation 5.1.5 puts the procedure on the ship and forbids any victimization for using it, and MN033 defines victimization widely: any adverse action taken or even threatened over a genuine grievance. You have the right to be accompanied and represented by a shipmate of your choice at any stage. A first-contract galley utility does not have to face the master alone. Every seafarer also gets a copy of the procedure, and it must name the Bahamas Director of Labour, the competent authority in your own country where that differs, and a person on board who gives confidential, impartial advice.
The procedure produces paper of its own. MN033 requires a written report of the complaint, the actions taken and the decisions agreed, with a copy to you and an entry in the ship's official logbook. If that report never appears, that absence is itself worth a line in your timeline.
The clocks in the procedure
A complaint the ship cannot resolve goes ashore to the shipowner. From there MN033 sets the only fixed clock in the process: if no conciliated settlement is reached after twenty days, either party has a further twenty days to refer the complaint to the Director of Labour for a decision. Forty days sounds long mid-contract. On a nine-month cruise SEA it is short enough to finish while you are still on board, which is exactly where a complaint has the most weight.
You do not have to climb the whole ladder in every case. MN033 confirms the right to file directly with the master, the shipowner, or an external competent authority at any time. And if you fear victimization for filing at all, the notice gives you the right to go straight to the Director of Labour, either for guidance or with the complaint itself.
Filing an MLC complaint with the Bahamas flag state
The BMA sits in Nassau with offices in London, New York and Hong Kong. Per Marine Notice MN033 the complaints contact is stcw@bahamasmaritime.com, and the authority publishes its procedures at bahamasmaritime.com. The named competent authority is the Director of Labour, care of the BMA in Nassau (Shirlaw Street, P.O. Box N-4679). The Bahamas has ratified MLC 2006, and your SEA runs under the Bahamas Merchant Shipping Act and BMA regulations.
Send the same tight package that works on every flag.
- Ship name and IMO number, in the subject line too.
- Your rank and department, and the dates of your contract.
- What happened, in dates and numbers: overtime hours unpaid, rest hour limits broken, repatriation refused.
- The date you filed on board and what came back, with the MN033 report if you received one.
- Copies attached: SEA, wage statements, rest hour records, roster photos.
Plain English works. Send from a personal address you will still control after sign-off, not the crew account that dies with your card, and keep every reply. These are the same contacts our checker shows when you select the Bahamas on the Bahamas flag page, verified against the official sources, not copied from a forum post.
Port state and the ITF stay open
A flag state complaint does not close the other doors, and cruise schedules make some of them unusually close. MLC Regulation 5.2.2 gives you an onshore complaint route in any port the ship calls: report to the port state control officer, directly or through the agent, a chaplain or a shipmate ashore. The officer can inspect the ship under Regulation 5.2.1 and, for serious or repeated breaches, hold her at the berth. A cruise ship that misses a turnaround day has the company's full attention by lunchtime. Expect one thing though: under MN033, an external authority will pass the complaint to the BMA and will look at whether the on-board procedure was used. One more reason the dated copy from step one matters.
The ITF has inspectors in the big cruise homeports, and an inspector walking the gangway with your wage accounts in hand changes the conversation. A Mission to Seafarers or Stella Maris center at the cruise terminal can print, scan and forward documents when your data package is gone. Why open registries make this many doors necessary is the subject of our guide to flags of convenience and your contract.
Free crew appSeafarer Contract CheckCheck your contract clause by clause against MLC 2006 and flag state regulations. The check is free. On iPhone, Android or in the browser.
Hotel department, full rights
Everything the MLC grants applies to the hotel department in full, because the Convention covers anyone employed or engaged in any capacity on board. The spa therapist on a concession contract, the photographer, the casino dealer: on a Bahamas-flagged ship the working hour limits, the monthly wage account and the complaint procedure reach them the same as the bosun on deck. If a manager tells you the MLC is "a deck and engine thing", that sentence belongs in your timeline, with a date.
Wages two or more months behind are their own category. Under the MLC as amended in 2014 that meets the definition of abandonment once support is also cut, and the financial security certificate posted on board (a Bahamas requirement under BMA Marine Notice MN043) names the insurer who must then step in. Photograph that certificate on your first week, not in your last.
What realistically happens, and how long it takes
The BMA publishes no complaint turnaround statistics, and no honest guide should invent one. The MN033 clock, twenty days plus twenty, is the only fixed timeline in the process; everything around it runs in weeks, sometimes months. The usual sequence: acknowledgment, a request to the company, sometimes an inspection at a port call, then a direction to put things right. File before you sign off if you safely can. A complaint from a steward still on board gets attention faster than one sent from home two oceans away, and flag state, port state and ITF are three separate levers that move independently.
The route has the same shape under the other big registries, with different desks at the end. Our guides for the Panama flag, the Liberia flag, the Marshall Islands flag and the Malta flag hold those verified contacts.
Check the contract before it becomes a complaint
Most of what lands in a flag state inbox was visible in the SEA before it was signed. Run your cruise contract through the free MLC Contract Check with the Bahamas flag selected: it reads the contract clause by clause against MLC 2006 in about a minute, in your browser, no account. The report cites the standard behind every red clause and shows the verified BMA contact under the verdict. How to get the most out of a check is in our walkthrough of the tool.
Crews who treat paper as part of the job join with everything ready: contract checked, certificate photographed, copies backed up before the first drill. It is the same discipline 7SHORT1LONG® prints for, from the housekeeping department t-shirt in the crew mess to the sign on set packed the night before the flight to the homeport.
How the Bahamas flag rates in port state control
Port state control keeps score on every flag. The regional inspection regimes publish each year which registers get detained most, and the ITF keeps its own list of flags of convenience. This is where Bahamas stands on the current lists:
- Paris MoU (Europe and Canada): white list, rank 15 of 69, performance list valid July 1, 2026 to July 6, 2027.
- Tokyo MoU (Asia Pacific): high performance, inspections and detentions 2022 to 2024.
- ITF: listed as a flag of convenience, 2025 list.
- MLC 2006: party to the Convention.
These lists count detentions, not contracts. A white list flag can still sit under a bad SEA, and a black list flag tells you how much backing to expect from the administration when something goes wrong on board. The current rating of every flag we cover stands on the Bahamas flag page, and the app report names MLC 2006 plus the flag at the top of every check, with the same rating next to it.
Source note
Bahamas Maritime Authority (bahamasmaritime.com), BMA Marine Notice MN033, MLC Onboard Complaint Procedures (second issue, 2024) and Marine Notice MN043 on MLC financial security, the MLC 2006 text at the ILO, and ITF: your rights under the MLC. BMA office locations per the authority's contact pages.
This article is editorial context from a crew brand, not legal advice. For a live dispute, put your documents in front of the ITF, a maritime lawyer, or the BMA itself.
FAQ
How do I file an MLC complaint under the Bahamas flag?
File a written complaint on board first, with your head of department or the master, and keep a dated copy. Then email stcw@bahamasmaritime.com with the ship name and IMO number, your SEA, wage statements, rest hour records and a dated timeline of what happened.
Do I have to finish the on-board procedure before contacting the BMA?
No. MN033 confirms the right to file directly with the master, the shipowner or an external competent authority at any time, and to go straight to the Director of Labour if you fear victimization. Practically: file on board first if you safely can, because the BMA will ask whether the procedure was used.
How long does a Bahamas MLC complaint take?
The BMA publishes no turnaround statistics. The only fixed clock is in MN033: twenty days for a conciliated settlement ashore, then a further twenty days to refer the complaint to the Director of Labour. Expect weeks rather than days and keep port state control and the ITF working in parallel.
Does the MLC cover hotel, spa and casino staff on cruise ships?
Yes. The Convention covers anyone employed or engaged in any capacity on board, so stewards, cooks, spa therapists and casino dealers on a Bahamas-flagged ship hold the same rest hour, wage and complaint rights as the deck crew.
The company office told me to "raise it at the end of the season". Do I wait?
No. File on board now, in writing, and keep the copy. Waiting costs you evidence, witnesses and wage months. There is no season clause in the MLC.
Can guests or family file for me?
The complaint carries most weight coming from you, with your documents attached. What family ashore can do is keep copies of everything you send them: statements, photos of the roster, dates. If contact breaks off, that folder becomes the case.
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