Information Note On The Draft Directive Regarding The Manning Of Ships With Seafarers

In line with the letter of the Directorate General of Maritime Affairs of the Ministry of Transport and Infrastructure dated 19 January 2026 and numbered 3351728, we hereby present our assessments and opinions regarding the "Draft Directive on the Manning of Ships with Seafarers" ("Draft Directive") prepared by the Directorate General, for your information.

The Draft Directive constitutes a comprehensive regulatory initiative aimed at strengthening alignment with international maritime legislation, reducing operational costs, and enhancing digitalization and flexibility in implementation. The Draft has been prepared with the purpose of reinforcing consistency between current national regulations and the principal international conventions to which Türkiye is a party, notably the International Convention for the Safety of Life at Sea (SOLAS), the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW), and the Maritime Labour Convention (MLC 2006). In this context, the Draft Directive appears, in its overall framework, to be a positive and well-considered regulatory effort.

Clarification of the Scope Provision

In the Draft Directive, the scope article has been revised, and the previously ambiguous expression "regardless of whether it is registered in any Turkish ship registry" has been removed. It has been replaced with the phrase "Turkish-flagged vessels registered in the Turkish Ship Registry or the Registration Ledger." This amendment clearly defines the vessels to which the Directive applies and eliminates uncertainties encountered in practice.

Addition and Elaboration of the Definitions Article

The inclusion of a comprehensive "Definitions" article in the Draft Directive is welcomed, as it aims to ensure consistency in implementation. The detailed structuring of definitions and the explicit reference to STCW provisions provide clarity and consistency in the classification of crew members and the determination of watchkeeping qualifications.

The clear distinction of crew groups based on STCW II/4, II/5, III/4, and III/5 competencies; the explicit definitions of terms such as officer, rating, and support personnel; and the concrete specification of technical concepts such as gross tonnage, near-coastal voyage, and propulsion power all enhance legal certainty for both the administration and the maritime sector.

Furthermore, the reference to applicable national legislation and the international conventions to which Türkiye is a party for terms not defined within the article contributes to coherence and consistency in interpretation.

Flexibility in Manning Requirements and the Discretion Granted to the Directorate General of Maritime Affairs of the Ministry of Transport and Infrastructure

With the Draft Directive, the provisions on the manning of ships have been comprehensively restructured; the previously scattered, repetitive, and interpretation-dependent rules have been replaced with a more systematic, itemized, and coherent framework.

• The specification that the certification of periodically unattended machinery spaces will now be carried out by authorized organizations is a technically sound amendment.
• The change allowing voyages with crew shortages in foreign ports to be completed at the "first or most suitable port" instead of strictly the "first Turkish port" introduces significant operational practicality, particularly for internationally trading vessels.
• The explicit reference to the relevant regulations when determining the competency requirements for masters and chief engineers/chief officers on vessels operating in local traffic strengthens legal coherence, while the express confirmation that minimum manning remains the operator's responsibility provides clarity.
• The addition of new manning rules for private yachts, vessels powered by alternative energy sources, non-commercial passenger ships, and offshore support vessels broadens the scope of the regulation in line with the sector's technological and structural evolution.

In parallel, the Directorate General of Maritime Affairs of the Ministry of Transport and Infrastructure discretionary authority to reduce manning numbers or qualification levels—taking into account vessel type, voyage area, technical capabilities, and operational conditions—has been preserved and placed within a more structured framework. However, to prevent arbitrary application, it would be beneficial for this discretion to be supported by objective criteria, clearly defined application and evaluation procedures, supplementary secondary legislation where possible, and an explicit mechanism for objections, ensuring legal predictability and consistency in practice.

Electronic Submission and Inspection of Seafarers' Lists – Transition to a Digital System

In the Draft Directive, this provision has been entirely restructured, and the former requirement for physical submission and approval has been removed, modernizing the process through a digital reporting system. Under the previous regime, the master was required to physically submit the seafarers' list to the port authority for approval. Under the Draft Directive, however, electronic submission through the Port Management Information System (PMIS) within the framework of the Ports Regulation is now permitted.

This amendment enables the verification—via PMIS—of whether seafarers' lists and qualification certificates comply with the "Minimum Safe Manning Certificate," thereby reducing bureaucratic burden, accelerating procedural steps, and significantly enhancing the effectiveness of inspections.

Transition Period

The Draft Directive introduces a six-month compliance period for existing "Minimum Safe Manning Certificates" that do not align with the new provisions. This transition period is considered reasonable and appropriate, as it provides the sector with a gradual and manageable timeframe to adapt to the updated regulatory framework.

Critical Risk Areas and Points Requiring Attention

• Safety Concerns: The Draft Directive proposes reducing the number of watchkeeping officers from two to one on cargo vessels over 15,000 GT. This change may introduce additional navigational risks, particularly in high-traffic and high-risk waterways such as the Istanbul and Çanakkale Straits.

• Minimum Manning on Small Vessels: Allowing vessels under 18 GT—particularly fishing vessels—to operate with only a single crew member may be inadequate in terms of emergency response, personal safety, and occupational health and safety. Since a single individual may not realistically be able to perform navigation, operational duties, and emergency response simultaneously, reconsideration of this provision would be prudent.

• Unattended Machinery Spaces: Although the Draft Directive envisages certification of periodically unattended machinery spaces by "authorized organizations," it does not define the criteria, procedures, or oversight mechanisms applicable to such certification. This lack of clarity may lead to uncertainties in practice. It would therefore be beneficial to set out the relevant technical requirements, certification standards, and inspection processes through secondary legislation.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.