Vanuatu flag above a weathered bulk carrier during a port state inspection at anchorage

crew-rights

Vanuatu Flag Labor Law: The Flag That Applies MLC 2006 Without Ever Ratifying It

Vanuatu is the one flag in this series that applies MLC 2006 without having signed it. The ILO register lists no ratification. What the flag has instead is a registry bulletin: Maritime Bulletin 112, in force since August 20, 2013, under the Maritime Act CAP 131, which tells shipowners under the Vanuatu flag to meet the Convention's standards and lets the registry issue a Declaration of Maritime Labour Compliance on that basis. The registry itself changed hands on November 1, 2024 and is now operated from 39 Broadway in New York. It stands on the Paris MoU black list and on the ITF list of flags of convenience. A contract under this flag gets the Convention by bulletin, not by treaty, and the difference shows the day something goes wrong.

Before you sign a contract under the Vanuatu flag, know which laws apply. You can check your seafarer contract free in the MLC Checker Tool. Pick Vanuatu, and the report reads your SEA against MLC 2006, says plainly that the flag has not ratified, and points you to the routes that work anyway.

Bulletin, not treaty

When a state ratifies MLC 2006 it takes on an obligation to other states: to certify its ships, to inspect them, to take complaints, and to answer to the ILO for how it does all three. When a registry issues a bulletin, it takes on a rule for its own customers. Bulletin 112 does the second thing. It is real, it is in force, and a Vanuatu-flagged ship with a DMLC issued under it will be treated by port state control much like a certified ship. What is missing is the layer above: no international commitment, no ILO reporting, no other state entitled to ask Vanuatu why a complaint went unanswered.

For you the practical consequence is where to place your expectations. The Convention still protects you in every foreign port, because Article V, the no more favourable treatment rule, tells port state control to hold ships of non-ratifying flags to the same standard. The flag state itself has promised nothing to anyone but its own shipowners.

New management in New York

The Office of the Maritime Administrator, the Vanuatu International Shipping Registry, has been operated since November 1, 2024 by Vanuatu Logistics and Administrative Services Limited, at 39 Broadway in Lower Manhattan, on behalf of the government in Port Vila. The registry publishes a general address as its MLC contact point and a New York telephone number. There is no complaint-only inbox. A complaint that the master and the shipowner do not resolve goes to that address, in writing, dated, with a copy kept by you, and with the ITF copied in. The verified contacts stand on the Vanuatu flag page of the checker.

What the bulletin gives you on a Vanuatu ship

Bulletin 112 imports the Convention minimums, and the DMLC Part I on board restates them. The lines in the SEA that have to match:

  • A written SEA signed by you and the shipowner or the owner's representative, with an original you keep.
  • Wages at least monthly, with a monthly statement of pay and deductions.
  • At least 10 hours of rest in any 24 and 77 in any seven days, recorded and countersigned.
  • Paid annual leave of at least 2.5 calendar days per month of service.
  • Repatriation at the shipowner's cost after a stated maximum time on board.
  • Medical care and sick pay after illness or injury, within the limit the bulletin allows.
  • A written on-board complaint procedure handed over with the SEA.

On an open register with no national collective agreement behind it, those minimums are usually the whole offer. If your SEA names an ITF approved agreement, your paper is stronger, and on this flag that matters more than on most, because the ITF is the party with reach. The clauses that usually go wrong are in our guide to seafarer contract red flags, and the basic wage line is covered in the seafarer minimum wage guide.

Black list in Europe, medium in Asia

On the Paris MoU performance list valid July 1, 2026 to July 6, 2027, Vanuatu stands on the black list at rank 65 of 69. The Tokyo MoU rates the flag medium performance for 2022 to 2024. The ITF lists Vanuatu as a flag of convenience on its 2025 list.

A black list flag that has not ratified is a ship port state control reads closely. Officers in Europe board it as a priority and read the crew documents as part of the inspection: the SEA, the rest hour sheets, the payslips, the DMLC. That is the owner's exposure and your protection. Keep the paper in order, and know the repatriation clause before a detention turns into unpaid weeks alongside. Under the Convention the shipowner pays the flight home and the flag state steps in if the owner fails; on a flag that made no commitment, plan for the ITF to be the one that steps in. How abandonment plays out on flag of convenience ships is in our guide to flags of convenience and your contract.

Seafarer Contract Check app icon 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.
Or use the web version

Vanuatu flag in the contract: what I check before sign-on

  • The DMLC issued under Bulletin 112 is on board, and the SEA refers to the Convention standards, not to a treaty the flag never signed.
  • Basic wage, overtime and leave pay in separate lines.
  • The sickness clause: weeks of wages after being landed sick, and when the owner's liability ends.
  • The repatriation clause names the shipowner as the payer and sets a maximum time on board, and the financial security for repatriation is named.
  • A collective agreement is named and attached, or you know in writing that none applies.
  • The on-board complaint procedure came with the SEA, and the ITF contact for your next port is written down.

The step by step use of the checker is in How to Use the MLC Contract Check. For two black list registers that did ratify and still publish little, read our guides to Belize flag labor law and Guinea-Bissau flag labor law.

How the Vanuatu 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 Vanuatu stands on the current lists:

  • Paris MoU (Europe and Canada): black list, rank 65 of 69, performance list valid July 1, 2026 to July 6, 2027.
  • Tokyo MoU (Asia Pacific): medium performance, inspections and detentions 2022 to 2024.
  • ITF: listed as a flag of convenience, 2025 list.
  • MLC 2006: not ratified.

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 Vanuatu 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

ILO NORMLEX ratification register for MLC 2006 (no ratification by Vanuatu); Vanuatu Maritime Bulletin 112, in force August 20, 2013, under the Maritime Act CAP 131; the registry's notice of the change of management effective November 1, 2024 and its contact page (register-vu.com); Maritime Labour Convention, 2006, Article V; Paris MoU performance lists valid July 1, 2026 to July 6, 2027; Tokyo MoU Annual Report 2024, Table 8; ITF list of FOC registries 2025. Flag facts checked against these sources on September 1, 2026. This article is editorial context for working seafarers, not legal advice.

FAQ

Has Vanuatu ratified MLC 2006?

No. The ILO register lists no ratification by Vanuatu. The registry applies the Convention's standards to Vanuatu-flagged ships by its own Maritime Bulletin 112, in force since August 20, 2013, under the Maritime Act CAP 131, and issues a DMLC Part I on that basis.

Does the MLC apply to me on a Vanuatu-flagged ship?

In a foreign port, yes: port state control applies the Convention to the ship under Article V, the no more favourable treatment rule, whatever the flag has signed. On board, the flag applies the standards by bulletin, which is a registry rule, not a treaty obligation.

Who runs the Vanuatu ship register?

The Office of the Maritime Administrator, Vanuatu International Shipping Registry, operated since November 1, 2024 by Vanuatu Logistics and Administrative Services Limited at 39 Broadway in New York, on behalf of the Government of Vanuatu.

Is Vanuatu a flag of convenience?

Yes. The ITF lists Vanuatu as a flag of convenience on its 2025 list. The flag stands on the Paris MoU black list, rank 65 of 69, on the performance list valid July 2026 to July 2027, and at medium performance in the Tokyo MoU region for 2022 to 2024.

Where do I complain about conditions on a Vanuatu-flagged ship?

After the on-board procedure, to the registry's MLC contact point in New York, with a copy to the ITF. Because the flag has made no international commitment, plan on port state control and the ITF inspector in your next port as the counterparts who can actually act.

7SHORT1LONG® is a Seafarer Identity Brand. A bulletin is a promise to the owner; the crew makes its own. The sign on set is for the day you board, and the seafarer hoodies for the night watches that follow.

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