Open consultation

Strengthening seafarer protections

Published 5 June 2026

This document sets out proposals for new regulations under the Seafarers’ (Wages and Working Conditions) Act to strengthen pay and safe working protections on international services calling at UK ports.

We’re seeking views on:

• the scope of the measures
• how they should operate in practice
• how compliance should be monitored and enforced

Introduction

Seafarers play a vital role in the UK economy, transporting people and goods to and from our international neighbours. Since P&O Ferries dismissed almost 800 mostly British seafarers in order to replace them with foreign agency workers on worse terms and conditions, there has been greater focus on the disparity in worker protections for seafarers working on international services and those working only in UK waters on in land-based roles.

This consultation seeks views on the use of new powers under the Seafarers’ (Wages and Working Conditions) Act 2023, as amended by the Employment Rights Act 2025.

In 2024, the Seafarers’ Wages Act 2023 was brought into force. It required operators of international services calling at a UK port at least 120 times a year to pay their seafarers who were not entitled to the national minimum wage an equivalent rate for work in UK waters, known as a national minimum wage equivalent (NMWe).

This requirement was established as a condition of port access and requires harbour authorities to request declarations from operators confirming that they are paying the correct rate, or they must pay a surcharge and ultimately risk refusal of access to the port if they do not comply.

The amended legislation includes new powers that require payment of the equivalent of UK national minimum wage (NMWe) outside of UK waters. The act also allows us to make regulations making broader requirements on remuneration and safe working on international services calling at a UK port at least 120 times a year (or more frequently if specified in the Regulations), including:

• minimum/maximum periods of work

• fatigue management

• safety related training

Since the Seafarers’ Wages Act 2023 was introduced to Parliament, the international legislative landscape has changed. On 26 July 2023, France adopted Law No. 2023-659, which allowed the Council of State to specify by decree the maximum period of service on board for passenger ships operating regular international routes calling at a French port, and to make pay requirements.

On 29 March 2024, Decree No. 2024-297 brought this legislation into force. It specified that seafarers aboard services entering French ports from the UK and Channel Islands 120 or more times per year must have a maximum period of service aboard of 14 days, followed by an equal period of rest, or in the case of those undergoing training, 21 days followed by an equal period of rest. It also specified that seafarers’ must be paid French minimum wage during the journey.

We propose making regulations requiring:

• payment of national minimum wage equivalent on the whole journey on all UK-France and UK-Channel Islands services calling at a UK port 120 times a year

• that seafarers on services across the Channel must have a maximum period of service aboard of 14 days, followed by an equal period of rest, or in the case of those undergoing training, 21 days followed by an equal period of rest

In the longer term, it is our ambition to seek agreement with other neighbouring countries to legislate outside of UK territorial waters on routes to their ports, as we have done with France. The UK will continue to champion seafarers’ rights at the international level, while going as far as we can domestically to strengthen their protections.

As these new protections will be introduced under the Seafarers’ (Wages and Working Conditions) Act 2023, they will use the same compliance mechanism as the existing Seafarers’ Wages Regulations 2024. As with the existing requirements, complying with the new remuneration and safe working regulations will therefore be a condition of access to ports.

Harbour authorities will be under a duty to request remuneration and safe-working declarations from operators of services in scope. If the operator does not provide a declaration, the harbour authority must impose a surcharge in respect of each occasion on which a vessel operating the service calls at the port. If the surcharges are not paid, the port will have to refuse access to the operator.

On services in scope of the new regulations, the remuneration declarations will replace the existing equivalence declarations. The same time periods for requesting and providing declarations will apply, as will the same timescales for imposing and paying surcharges and refusing access. The same surcharge tariff will also apply to operators who fail to provide the new declarations.

Scope

Sections 4A(4) and 4E(8) of the Seafarers’ (Wages and Working Conditions) Act allow the regulations to apply differently to different services. We propose that this first set of regulations apply only to services between the UK and France. This will cover the most intensive international ferry routes to the UK.

It will be limited in such a way because at present, France is our only neighbouring country with whom we have reached an agreement to legislate on services to, beyond UK waters. Our ambition is to extend these regulations to other international services to other neighbouring countries, but we will only do that once we have their agreement.

The powers in section 4A and section 4E allow us to apply the remuneration and safe working requirements to ships providing a service calling at a UK port at least 120 times, or a higher number of times if the regulations specify. It is proposed that these regulations would apply to services calling at the UK port at least 120 times per year, as with the existing Seafarers’ Wages Act and the French regulations. This frequency requirement will bring into scope all passenger ferry services and small numbers of container services.

Question on scope

Do you agree or disagree that the safe working and remuneration declarations should apply to all sea services between the UK and France and Channel Islands, that visit a UK port at least 120 times a year?

Remuneration regulations

Current position: national minimum wage equivalent

Currently, seafarers who call regularly (at least 120 times per year) at a UK port must be paid UK minimum wage equivalence whilst in UK waters through the Seafarers’ Wages Act (SWA). If the operator does not provide a declaration to the harbour authority confirming that they are doing this, they will be liable to pay a surcharge.

However, seafarers do not have that entitlement outside of UK waters unless they meet the following criteria:

• workers working or ordinarily working in the UK (including UK internal waters)

• workers working or ordinarily working in UK territorial waters, unless they are on ships exercising the right to innocent or transit passage

• workers on UK flagged ships, so long as they are ordinarily resident in the UK and work to at least some extent in the UK

• workers working or ordinarily working in connection with the seabed/subsoil of the UK sector of the continental shelf, again unless they are on ships exercising the right to innocent or transit passage

Outside of UK waters, these seafarers do not have minimum wage protections under UK law and are therefore vulnerable to being paid low wages for this duration of the journey. These proposals aim to address this for seafarers for certain services.

Since the Seafarers’ Wages Act 2023 was introduced to Parliament, the French government has passed its own legislation regulating wages on cross-Channel passenger ferry services. It requires the French minimum wage to be paid across the whole journey, as well as imposing requirements on roster patterns.

Table 1 shows the current NMW/NMWe rates from April 2026.

Table 1: NMW/NMWe rates 2026

Age /status	Rate of pay
Apprentice rate	£8.00
16 to 17	£8.00
18 to 20	£10.85
21 and over	£12.71

Proposal: remuneration

Section 4A of the Seafarers’ (Wages and Working Conditions) Act provides powers to make regulations relating to remuneration on services defined by regulations.

The proposal is to require payment of the UK national minimum wage equivalent on services calling at a UK port at least 120 times per year for the whole journey. This means that it will be enforceable in UK law and the UK is not relying on French enforcement of its legislation. It will also provide an uplift in pay as it will require UK minimum wage (which is currently higher than the French minimum wage) to be paid for the whole route, not just in UK waters.

The regulations on calculating national minimum wage equivalent will replicate the national minimum wage regulations and in so doing will be similar to the existing Seafarers’ Wages Regulations.

The only difference will be that on cross-Channel routes, the calculation in regulation 17 will not include the top up for the UK additional rate, as NMWe will apply beyond UK waters. There will simply be one rate which applies to the whole route.

The same approach to deductions will also be taken, minus adjustments for the UK additional rate. This means that as with the seafarers’ wages regulations, the accommodation offset that applies to the NMW, allowing deductions to be made for accommodation without reducing pay for the purposes of calculation NMW, does not apply.

The Department for Business and Trade will be responding to the Low Pay Commission’s recommendation in its 2022 report to remove the accommodation offset for seafarers from the national minimum wage regulations in due course.

As with the existing regulations, the rate will mirror the National Minimum Wage Regulations and will be uprated annually, following recommendations from the Low Pay Commission.

It is possible that in the future, these powers could be used on other routes to UK ports, but we will not do this unless we have agreement with other neighbouring countries.

The equivalent of the national minimum wage will be set out in the regulations. It will mirror the UK national minimum wage, which is uprated from 1 April every year.

The power to make remuneration regulations could be used to regulate other types of remuneration beyond wages. We do not include further uses of the powers in these proposals for regulation since we do not have agreement with international partners at this time. But we could consider using these powers in the future.

Questions: remuneration

Do you agree with the use of the remuneration regulations to require payment of the equivalent of national minimum wage for the entirety of cross-Channel routes?

Are there other types of remuneration that these powers should be used to regulate?

Are there any parts of the existing seafarers’ wages regulations that ought to be adapted for in their application in remuneration regulations to the whole of the journey between UK and France?

Safe working regulations

Maximum period of service: current position

Section 4E of the Seafarers (Wages and Working Conditions) Act 2023 provides powers to make regulations relating to safe working conditions for seafarers. These regulations may specify conditions relating to working patterns and rest requirements, for managing and mitigating fatigue including:

• the adoption of fatigue management plans

• safety-related training

At present, UK law on maximum periods of service aboard for seafarers closely follows the provisions of the Maritime Labour Convention, 2006, which sets international minimum standards for seafarer living and working conditions.

The convention requires that states make provision to limit seafarers’ maximum period of service aboard, after which they must be repatriated to less than 12 months. In line with international practice our law limits this to 12 months, less the number of days of statutory paid leave to which they are entitled. In practice, this means that seafarers’ maximum period of service aboard is around 11 months.

Historically, cross-Channel passenger services have operated short maximum periods of service such as 1 or 2 weeks at sea, followed by similar periods of rest ashore. However, in recent years the Dover-Calais route has seen some operators adopt operating models with seafarers serving aboard for as long as 17 weeks before having a significant period of rest.

Long hours and long periods at sea are normal for some operations, but the government does not consider these appropriate for frequent passenger services crossing one of the world’s busiest shipping lanes.

On 26 July 2023 France adopted Law No. 2023-659 which allowed the Council of State to specify by decree the maximum period of service on board for passenger ships operating regular international routes calling at a French port.

On 29 March 2024, Decree No. 2024-297 was issued to implement the law and specified that seafarers aboard services entering French ports from the UK and Channel Islands 120 or more times per year, must have a maximum period of service aboard of 14 days, followed by an equal period of rest, or in the case of those undergoing training, 21 days followed by an equal period of rest.

Safe working regulations: proposal

We intend to use these powers in agreement with the state or states on the route . At this time, this means we propose to apply requirements in relation to services operating between the UK and France and the Channel Islands, but we may in future cover other routes.

We propose to use the powers to mirror the French legislation by requiring in UK law that seafarers working aboard services entering ports in the UK 120 or more times per year from France or the Channel Islands must have a maximum period of service aboard of no more than 14 days, followed by an equal period of leave, or 21 days for those in training.

This means this requirement for routes between the UK and France will be enforceable in UK law and facilitate greater cooperation with the French authorities. It will also mean that this requirement will apply to services operating between the UK and the Channel Islands which are not currently captured by the French law.

A longer maximum period of service of 3 weeks followed by an equal period of rest is permitted for those in training to support them to gain the duration of seagoing service required for seafarer certifications under the Convention on Standards, Training, Certification of Watchkeeping, 1978 (STCW).

We are using these powers at this time in a way that aligns with the French legislation and do not propose in the first set of implementing regulations to adopt measures in relation to fatigue management plans or safety-related training. However, it is possible that in future we may use the powers in that way.

We would in particular welcome input on whether it is felt it would be beneficial to require fatigue management plans and what if any elements of such plans should be prioritised.

Safe working regulations: questions

Do you agree with a maximum period of service aboard of no more than 14 days, followed by an equal period of leave?

Do you agree that those in training should have a maximum period of service aboard of no more than 21 days, with an equal period of leave?

Do you think it would be beneficial to require fatigue management plans?

What, if any, elements of fatigue management plans should be required?

Declarations, surcharges and refusal of access

Declarations

We propose that for services the remuneration and safe working requirements apply to (UK-France services calling at the UK port at least 120 times per year), the existing equivalence declaration in the Seafarers’ Wages regulations 2024 would no longer be required and would be replaced by a:

• remuneration declaration for the wage requirements

• safe working declaration

The form of these declarations will be set out in the regulations.

The timescales for requesting and providing remuneration and safe working declarations would mirror those for the existing equivalence declarations set out in the Seafarers’ Wages regulations 2024.

Harbour authorities would have to request declarations within 28 days of the start of the year to which the declaration relates or, if later, within 28 days of having reasonable grounds to believe an operator is in scope of the requirements. The operator would then have 3 months to provide the declaration.

The declarations would confirm that seafarers on the service are meeting the requirements of the remuneration and safe working declarations during the relevant year. The relevant year will be the same as that applying to equivalence declarations (1 December to 30 November). The first relevant year would start on 1 December 2026.

If the operator does not provide a declaration, or if a service is operated inconsistently with a declaration, the act sets out that the harbour authority will require them to pay a surcharge. The same surcharges and timescales for payment would apply as in the seafarers’ wages regulations.

As with equivalence declarations in the seafarers’ wages regulations, the declaration must be provided in the prescribed form which will be set out in the regulations. The form will require operators to confirm that they are complying with the requirements set out in the regulations.

Surcharge tariff

The intention is that the surcharge is at a level such that it incentivises the payment of NMW equivalent and compliance with the safety regulations.

In the existing seafarers’ wages regulations, the tariff is based on the gross tonnage (GT) of the ships providing the service. There are separate rates for ships with a passenger carrying capacity of 12 or fewer and those with a passenger carrying capacity of more than 12. These factors may be seen as a proxy for the likely number of seafarers on board and for the commercial scale of the service.

For ships which are certified to carry 12 or fewer passengers the tariff is:

• 5p per GT up to a maximum of 50,000 GT

• 1p per GT in excess of 50,000 GT

For ships which are certified to carry more than 12 passengers the tariff is:

• 10p per GT up to a maximum of 50,000 GT

• 2p per GT in excess of 50,000 GT

It is proposed that the surcharge in respect of remuneration and safe working regulations should also be based on GT. The number of seafarers on board is still a relevant factor as to whether the surcharge would act as a deterrent and GT is a simple metric for harbour authorities to access and apply.

As it will be more costly for operators to comply with the new remuneration regulations and safe working regulations which apply across the whole journey, than with equivalence declarations, a higher surcharge is necessary in order to incentivise compliance.

It is also possible that an operator may be liable for a surcharge for failure to provide a safe working declaration but not for a remuneration declaration, or vice versa.

Since the costs of complying with the different regulations will differ, we propose different surcharge rates for each set of requirements, in order to ensure that the surcharge remains proportionate.

The proposed surcharge rates in respect of failure to provide both a remuneration and safe working declaration are set out as follows.

Remuneration

For ships which are certified to carry 12 or fewer passengers, the proposed tariff is:

• 9p per GT up to a maximum of 50,000 GT

• 1p per GT in excess of 50,000 GT

For ships which are certified to carry more than 12 passengers the proposed tariff is:

• 18p per GT up to a maximum of 50, 000 GT

• 2p per GT in excess of 50,000 GT

Safe working

For ships which are certified to carry 12 or fewer passengers, the tariff is:

• 20p per GT up to a maximum of 50,000 GT

• 1p per GT in excess of 50,000 GT

For ships which are certified to carry more than 12 passengers the tariff is:

• 40p per GT up to a maximum of 50,000 GT

• 2p per GT in excess of 50,000 GT

Imposing and paying surcharges

Under the existing regulations, when a surcharge applies, harbour authorities must notify operators about the imposition of a surcharge within 14 days, beginning with the day on which the duty to impose the surcharge arises. This is intended to allow operators to bundle up a number of surcharges in a single surcharge notification.

Operators then have 60 days from beginning with the day after the day on which the surcharge notification was sent.

The harbour authority must then notify the Secretary of State (in practice, via the MCA) within 7 days, beginning with the day on which the surcharge notification is sent to the operator. The MCA will publish details of surcharges that have been imposed on its website.

It is proposed that the same requirements should apply to surcharges relating to remuneration and safe working regulations.

Refusal of access

As under the existing seafarers’ wages regulations, failure to pay a surcharge would result in the harbour authority refusing access to the operator. The same process would apply as in the Seafarers’ Wages Regulations. A harbour authority must send a refusal of access notification to the operator so that it is received by the operator within the period of 5 days beginning with the day 45 days after the day on which the surcharge notification was sent.

Questions: Declarations, surcharges and refusal of access

Do you agree that the timescales for providing safe working and remuneration declarations should be the same as those for the existing equivalence declarations?

Do you agree that the same relevant year should apply for safe working and remuneration declarations as for equivalence declarations?

Do you agree with the proposed surcharge tariff for

A) remuneration declarations

B) Safe working declarations

Do you agree with the timescales for communicating refusal of access?

Full list of questions

Question: Do you agree or disagree that the safe working and remuneration declarations should apply to all sea services between the UK and France and the UK and Channel Islands that visit a UK port at least 120 times a year?

Question: Do you agree with the use of the remuneration regulations to require payment of the equivalent of the National Minimum Wage for the entirety of routes from the UK to France and the Channel Islands?

Question: Are there other types of remuneration that these powers should be used to regulate?

Question: Are there any changes from the existing Seafarers’ Wages Regulations relating to the calculation on NMW that should be applied to the remuneration regulations?

Question: Do you agree with a maximum period of service aboard of no more than 14 days, followed by an equal period of leave?

Question: Do you agree that those in training should have a maximum period of service aboard of no more than 21 days, with an equal period of leave?

Question: Do you think it would be beneficial to require fatigue management plans?

Question: What, if any, elements of fatigue management plans should be required?

How to respond

We will only accept responses received before the closing date: 11:59pm on 17 July 2026.

The easiest way to respond is to use the online response form. It includes the option to save and continue your response if you are unable to complete it in one go.

If you cannot use the online form, email or post your response to us:

Email to:

seafarerprotections@dft.gov.uk

Write to:

Seafarers’ protection consultation
Great Minster House
33 Horseferry Road
London, SW1P 4DR

If you send your response by email or post:

• answer the questions asked in the consultation and, if required, provide further comments and evidence
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What will happen next

We will publish a summary of responses and the government response on the homepage for this consultation. Paper copies will be available on request.

If you have questions about this consultation, please contact seafarerprotections@dft.gov.uk.

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