• August 15, 2015


The Minister for Economic Development has responded to our query about the Isle of Man Ship Register and supervision thereof.

His reply in full is set out below:

“12th August 2015

Vnr Moffatt Veen

Thank you for your letter of 12th July regarding concerns over the Isle of Man Ship Registry being considered a centre of excellence. The Director of the Ship Registry has supplied answers to your questions which I trust will go some way to reassuring you that use of the phrase is not unwarranted

Since 2007 the Isle of Man Ship Registry has submitted annual reports to the International Labour Organisation (ILO), initially under the requirement of ILO Convention 178 (the Labour Inspections (Seafarers) Convention), and, since August 2013, under the requirements of the Maritime Labour Convention 2006 (MLC). The latter Convention was intended to create a level playing field for the international shipping industry by providing for a set of universal labour standards acceptable to ship-owners, seafarers and Governments.

As regards your specific enquiries;

In the 12 months leading up to MLC coming into force for all Isle of Man registered commercial ships, regardless of size, the Ship Registry has required ship-owners to submit copies of the Seafarers’ Employment Agreement (SEA), (a new requirement under MLC) and any collective bargaining agreements that formed part of the SEA. These are reviewed by the Ship Registry to ensure compliance with the requirements of MLC and amended as required with copies of the submitted documents being retained by the Registry. The surveyors now review the SEAs held by the seafarers during inspections of the ships to ensure that they remain in compliance with the MLC.

The MLC provides for seafarers to have an on-boardcomplaints procedure, one element of which is the right to bring a complaint regarding any alleged breach of the Convention directly to the flag state, in this case the Isle of Man Ship Registry. In 2014 the Ship Registry received five such complaints directly from seafarers of which four involved non-payment of agreed wages or fulfilment of termination conditions. In three of the cases the intervention from the Ship Registry resulted in the seafarer’ complaints being upheld and payment to them totalling 19920 Euros. The on-board complaints procedure must contain the contact details of the Ship Registry; it is supplied to all seafarers and ensuring ship owners’ compliance in this respect forms part of the on-board inspection process. Further, the MLC also provides for seafarers to have access to an onshore complaints procedure that can be used by organisations on their behalf

Isle of Man employment law extends, in general, to seafarers on Isle of Man registered ships, who are ordinarily resident on the Island other than those who are employed wholly outside the Island. Clearly it would be impracticable to extend domestic Isle of Man employment law to international seafarers who may be working thousands of miles away from the Island or to provide access to Isle of Man institutions such as the Employment Tribunal or the Manx Industrial Relations Service.

As pointed out earlier the Isle of Man Ship Registry has been carrying out audits under ILO 178 since 2006 and in respect of certain provisions of the MLC since August 2013. Every commercially operated ship required an initial MLC inspection between August 2013 and August 2014 and if this had not been carried out the ships would have been in breach of the Convention and liable to be detained from sailing. The inspection regime involved Isle of Man surveyors visiting 457 ships worldwide and these ships are now required to have an MLC inspection carried out twice within a five year cycle. Carrying out the initial inspections in the required timescale was a considerable undertaking and only achievable through the professionalism and dedication of the Isle of Man surveyors.

Copies of all the reports submitted to the ILO are publicly available on the Ship Registry website (www.iomshipregistry.com/formsdocs/reports/). (It is of note that the Island was one of the first flag states to submit an annual MLC report). The Registry also publicises any deficiencies found by inspectors, a practice which both ship-owners and seafarers’ organisations have found to be of use, and has received praise for its openness in sharing this information. (See further at https://www.gov.im/ded/shipregistry/mlc/mlcupdates.xml).

I trust that the above information will reassure you that the Ship Registry actively enforces regulatory requirements that apply to seafarers and that it takes its responsibilities to seafarers very seriously indeed.

Lhiuish dy firrinagh

Hon. Laurence Skelly,
Minister for Economic Development”

The Celtic League welcomes the very full and detailed nature of the response.

Related link here:


J B Moffatt (Mr)

Director of Information
Celtic League



The Celtic League was established in 1961and has branches in the six Celtic Countries. It works to promote cooperation between these countries and campaigns on a broad range of political, cultural and environmental matters. It highlights human rights abuse, monitors all military activity and focuses on socio-economic issues



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