Bullying and Harassment on Board — What's Actually Changed

Two regulatory changes have landed on the industry in quick succession. The MLC 2022 amendments entered into force on 23 December 2024. The STCW Basic Training course — the PSSR module that every seafarer sits through — was amended to match, in force since 1 January 2026. Together they change what "acceptable behaviour on board" means, and what a victim can point to when it isn't.

For years, harassment on yachts sat in a grey area. Everyone knew it happened. No regulation said much about it. Complaints went to the Master, who often worked next to the person complained about. Victims left. The boat kept moving.

That cover is gone.

What changed in MLC

The ILO amended Regulation 4.3 — the one on occupational health and safety — to require that the working environment on board is "free from harassment and bullying, including sexual harassment and sexual assault."

Four words do the heavy lifting: free from, harassment, bullying, sexual assault. Each one was previously absent or implicit. Now they are binding text, enforceable by Port State Control, inspectable at every MLC audit.

The practical consequence: harassment is now an OHS hazard. It sits in the same regulatory bucket as falling overboard or a burn from a deep-fat fryer. You risk-assess it, you mitigate it, you record it, and you train people against it.

What changed in STCW — the PSSR amendment

Less widely noticed, and arguably more important for crew culture: IMO adopted amendments to the STCW Code at MSC 108 (May 2024, Resolution MSC.560(108)), adding mandatory competences on prevention of violence and harassment to Table A-VI/1-4 — the Personal Safety and Social Responsibilities (PSSR) basic training.

The amendments entered into force on 1 January 2026.

Every seafarer — from deckhand to Master — holds a PSSR certificate. It is one of the four basic safety courses alongside sea survival, fire-fighting and first aid. Historically it was also the dullest: a half-day on "working effectively as a team" with a multiple-choice quiz at the end.

The amended syllabus adds assessed competences covering:

• Basic knowledge and understanding of violence and harassment, including bullying, sexual harassment and sexual assault.
• Recognising these behaviours and their impact on individuals and the working environment.
• How to prevent, report and respond — including bystander action.
• Supervisor and leadership responsibilities.

All PSSR training delivered from 1 January 2026 must cover the new competences. Flag States differ on how holders of pre-2026 certificates are brought up to speed — some (MCA, Cayman Islands, Marshall Islands) accept a short supplementary module; others require the new full course at next revalidation.

In practice: within one STCW revalidation cycle, every seafarer on board will have sat through harassment training. That is a genuinely new baseline.

What yachts need to do

Four things. In this order.

1. A real policy. Standalone document. Plain language. Explicit about sexual harassment and sexual assault. Signed by the shipowner or managing CEO — not the Master, not the HR manager. If your current policy is a paragraph in the crew handbook, it doesn't count.

2. A complaint route that bypasses the line of command. The default is that the complainant goes to the HoD, who goes to the Master. That fails the moment the Master is the problem. You need at least two independent routes — typically a named contact on board (not in the complainant's department), plus the DPA, plus a confidential external line. Write them into the on-board complaint procedure.

3. Training before the season. Don't wait for the PSSR cycle to catch everyone. Run a session for all crew, with enhanced content for HoDs and the Master. Record attendance. Repeat annually.

4. Update the DMLC Part II. Generic wording about "a respectful workplace" will fail the next inspection. Describe what you actually do: policy title and version, complaint routes, named contacts, training frequency, investigation process.

The parts people miss

Guests and contractors. The regulation applies to the working environment, not just crew-on-crew. If a charter guest harasses a stewardess, it is still a workplace harassment incident, and the company's response is auditable.

Retaliation is the second incident. Most flag State guidance now treats retaliation — cold-shouldering, bad references, reassignment to the worst cabin — as a separate, equally serious breach. Protect complainants actively, not just on paper.

The DPA is now a confidential contact route, whether you planned it or not. Under the ISM Code, the DPA already has direct access to the highest levels of management. Most flag States now expect the DPA to be named in the complaint procedure as an independent route. Make sure yours is reachable, trained, and willing to act without going through the Master first.

Alcohol and accommodation. Reviews of incidents over the last three years point at the same two factors on yachts: alcohol at crew gatherings, and shared cabins across rank lines. Neither is regulated directly. Both are now fair game for risk assessment.

The bottom line

The regulation won't fix the culture on its own. It does three things the old regime didn't:

• It gives the complainant something concrete to point to.
• It gives Port State Control something concrete to inspect.
• It puts trained people — everyone with a post-2026 PSSR — into every rank of every crew.

For owners and managers, the question is no longer whether to act. It's whether the boat's arrangements would hold up under a serious investigation. Policy, reporting route, training, DMLC Part II. In that order. Before the next audit, and long before you need any of it for real.

Sources: ILO Amendments of 2022 to the MLC, 2006 — consolidated text (entry into force 23 December 2024); IMO Resolution MSC.560(108) — amendments to STCW Code Table A-VI/1-4, adopted May 2024, in force 1 January 2026; UK MCA MIN 729 (M)+(F) — 2026 IMO Amendment to PSSR; Cayman Islands CIGN 2022-08 and CIGN 2025-05.