What is the Work in Fishing Convention (ILO C188) and what does it require?

The Work in Fishing Convention, known as ILO C188, is an international labor treaty adopted by the International Labour Organization in 2007 that sets minimum working and living standards for people who work on fishing vessels. It covers areas like hours of rest, medical care, crew agreements, and safe working conditions aboard commercial fishing boats. The convention applies to vessels of a certain size and to workers engaged in commercial fishing operations at sea. The sections below unpack who it covers, what it requires, how it’s enforced, and what it means for your seafood supply chain.

Which countries have ratified ILO C188 and does that affect global supply chains?

As of 2026, around 20 countries have formally ratified ILO C188, including France, Norway, South Africa, Argentina, Morocco, and Bosnia and Herzegovina. Ratification means a country has committed to bringing its national laws in line with the convention’s standards and to inspecting vessels flying its flag or calling at its ports accordingly.

That list may seem small relative to the size of the global fishing industry, but the practical reach of ILO C188 extends well beyond ratifying countries. The European Union has incorporated the convention’s core requirements into EU law through Directive 2017/159, which means all EU member states are bound by equivalent rules regardless of whether they individually ratified the ILO instrument. That single step significantly expanded the convention’s real-world footprint.

For global supply chains, the impact is felt through port state control. Vessels calling at ports in countries that have ratified C188 could be subject to inspections, even if the vessel’s flag state has not ratified the convention. This means a fishing vessel operating under a flag of convenience may still face scrutiny the moment it enters a port in a compliant jurisdiction. Seafood companies sourcing from vessels that regularly transit European or other ratifying-country ports should take note: non-compliance could result in vessel detention, delayed shipments, or supply disruptions.

Who does ILO C188 apply to — which vessels and workers are covered?

ILO C188 applies to all persons employed or engaged in any capacity on board a commercial fishing vessel, including the skipper and all crew members. The convention covers fishing vessels that are 24 meters in length and over that operate on the high seas or in waters outside the flag state’s jurisdiction. Some provisions also extend to smaller vessels depending on national implementation.

The convention is specifically focused on commercial fishing, meaning it does not cover recreational or subsistence fishing. Workers covered include not just deckhands but also fish processing crew members working on board, engineers, and other support staff whose work is tied to the vessel’s fishing operations.

It’s worth noting that national laws implementing C188 may extend coverage to smaller vessels or additional categories of workers. In the EU, for example, Directive 2017/159 applies to all fishing vessels operating in EU waters and to EU-flagged vessels operating anywhere, regardless of length. If you source from vessels operating in or around EU jurisdictions, a broader set of workers and vessels may be covered than the baseline ILO text suggests.

What are the minimum standards ILO C188 sets for fishing crew?

ILO C188 sets minimum standards across several key areas of crew welfare, including minimum age, medical fitness, crew agreements, hours of rest, accommodation, food and water, medical care, and repatriation rights. Together, these provisions establish a baseline for what acceptable working conditions look like on a commercial fishing vessel.

Here is a breakdown of the main areas the convention covers:

Minimum age: No person under 16 may work on a fishing vessel. Stricter limits apply for hazardous work.
Medical fitness: Crew members must hold a valid medical certificate confirming fitness for sea service.
Crew agreements (fishers’ work agreements): Every fisher must have a written work agreement that clearly sets out their terms of employment, including pay, leave entitlements, and conditions for termination.
Hours of rest: The convention requires a minimum of 10 hours of rest in any 24-hour period and 77 hours in any 7-day period, with some flexibility for emergency situations.
Accommodation and food: Vessels must provide adequate accommodation, sanitation, and sufficient food and drinking water for the duration of the voyage.
Medical care: Vessels must carry appropriate medical supplies, and crew must have access to medical care both on board and ashore.
Repatriation: Fishers have a right to be repatriated at no cost to themselves when their work agreement expires or is terminated.
Occupational safety and health: Vessels must meet basic safety standards to reduce the risk of accidents and work-related illness.

These are minimum floors, not ceilings. Voluntary standards like the FISH Standard for Crew and certification schemes such as Fair Trade USA often go further by adding auditing requirements, grievance mechanisms, and worker voice provisions on top of what C188 mandates.

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How is compliance with ILO C188 monitored and enforced at sea?

Compliance with ILO C188 is monitored primarily through flag state inspections, port state control, and, where applicable, labor inspections in the flag state itself. Flag states are responsible for ensuring that vessels flying their flag meet the convention’s requirements, while port states may inspect foreign-flagged vessels when they call at port.

Port state control is one of the more practical enforcement tools. When a fishing vessel enters a port in a country that has ratified C188 or implemented equivalent legislation, port authorities may board the vessel to check crew agreements, hours-of-rest records, medical certificates, and accommodation conditions. If deficiencies are found, the vessel could be detained until they are corrected.

In practice, enforcement varies considerably between jurisdictions. Some authorities in regions with strong maritime governance apply rigorous inspections, while enforcement in other areas may be limited by resources or political will. At-sea monitoring is particularly challenging because fishing vessels often operate in remote waters far from any inspection infrastructure. This is one reason why satellite-based vessel monitoring systems and independent observer programs have become increasingly relevant tools for verifying conditions beyond what port inspections alone can confirm.

What’s the difference between ILO C188 and other seafood labor standards like FISH Standard for Crew or SMETA?

ILO C188 is a binding international treaty that sets legal minimum standards for fishing crew welfare. The FISH Standard for Crew and SMETA (Sedex Members Ethical Trade Audit) are voluntary certification and auditing frameworks that go beyond legal minimums to assess and verify labor conditions in more detail. The key distinction is that C188 is law-based, while the others are market-driven tools designed to provide buyers with audited evidence of compliance.

ILO C188 tells flag states what their laws must require. It does not, by itself, generate the kind of documented, auditable evidence that seafood buyers, retailers, and certification bodies typically need to verify labor conditions in a supply chain. That is where frameworks like FISH Standard for Crew and SMETA become useful.

The FISH Standard for Crew, developed specifically for the fishing sector, audits vessels against criteria that align with ILO C188 but also include additional elements such as freedom of association, recruitment practices, and worker grievance mechanisms. An audit under this standard produces a documented assessment that a buyer can use as evidence of due diligence.

SMETA is a broader ethical trade audit framework used across many industries, including seafood processing. It covers labor, health and safety, environment, and business ethics. SMETA audits are often used at the processing facility level rather than on the vessel itself, making it complementary to rather than a replacement for vessel-level standards like FISH Standard for Crew.

In practical terms, a seafood company demonstrating labor compliance will often need to show conformance with C188 as a legal baseline and then layer on audited certification evidence from one or more voluntary standards to satisfy buyer due diligence requirements.

How does ILO C188 relate to IUU fishing and forced labor risk in seafood supply chains?

ILO C188 and IUU (illegal, unreported, and unregulated) fishing are closely linked because vessels that operate outside legal frameworks often violate labor standards at the same time. Research and industry experience consistently show that IUU fishing and forced labor tend to co-occur: vessels that evade catch reporting, use unauthorized fishing areas, or operate without proper licensing are also more likely to rely on exploitative labor practices to keep costs low.

The connection matters for supply chain risk. A vessel implicated in IUU fishing may simultaneously be in violation of C188’s crew welfare requirements, and vice versa. Buyers who source from such vessels could face reputational damage, regulatory scrutiny, and potential legal exposure under legislation like the EU Forced Labour Regulation or the US Uyghur Forced Labor Prevention Act, which increasingly extend their reach into seafood supply chains.

Satellite vessel monitoring systems (VMS) and AIS data play an important role here. Irregular vessel behavior at sea, such as dark vessel periods, unexpected transshipment events, or fishing in prohibited zones, can indicate both IUU risk and conditions under which labor abuses are more likely to occur. Combining satellite analytics with observer data and social compliance audits gives supply chain managers a more complete picture of risk than either tool provides alone.

What documentation do seafood companies need to demonstrate ILO C188 compliance?

To demonstrate ILO C188 compliance, seafood companies typically need a combination of vessel-level documentation and crew-level records that together show the vessel and its operator meet the convention’s minimum standards. The specific documents required will depend on the jurisdiction, the buyer’s due diligence requirements, and any applicable certification scheme.

The core documentation set generally includes:

Fishers’ work agreements: Written contracts for each crew member covering pay, working hours, leave, and conditions of termination.
Hours-of-rest records: Logs showing that crew members received the minimum rest periods required under C188.
Medical certificates: Valid certificates for each crew member confirming fitness for sea service.
Vessel safety certificates: Documentation confirming the vessel meets applicable safety standards.
Crew lists and identity documents: Verified records of who is on board, which also support checks against forced labor indicators.
Social compliance audit reports: Where applicable, audit reports from FISH Standard for Crew, SMETA, or similar frameworks that document conditions on board.
Observer or electronic monitoring (EM) reports: Independent at-sea observations that corroborate vessel behavior and crew conditions.

Assembling this documentation manually is time-consuming and prone to gaps, particularly when vessels operate across multiple fishing trips, flag states, and jurisdictions. Increasingly, buyers and retailers expect this evidence to be digitally organized, traceable to specific batches or voyages, and available on demand rather than assembled retrospectively at the point of audit.

This is where SmarTuna’s digital traceability platform adds direct value. It links social compliance certifications, observer reports, and crew welfare evidence to individual Raw Material IDs at the point of vessel discharge, making ILO C188-related documentation audit-ready from the first mile rather than something that has to be chased down after the fact.

Frequently Asked Questions

How should a seafood company get started with ILO C188 compliance if it has never assessed its supply chain before?

The best starting point is a supply chain mapping exercise to identify which vessels, flag states, and fishing grounds your sourcing covers, since risk exposure varies significantly depending on these factors. From there, request the core documentation set from your suppliers — fishers’ work agreements, hours-of-rest records, and medical certificates — and benchmark what you receive against C188’s minimum standards. Where gaps exist, work with suppliers to close them before layering on a voluntary audit framework like FISH Standard for Crew to generate auditable evidence of compliance. Starting with documentation requests is low-cost and immediately reveals where your highest-risk relationships are.

What happens if a vessel in my supply chain is detained under ILO C188 during a port state control inspection?

A vessel detention means the vessel cannot leave port until the identified deficiencies are corrected to the satisfaction of port authorities, which can result in delayed shipments, spoiled catch, and significant operational disruption for both the vessel operator and downstream buyers. As a seafood company sourcing from that vessel, you may face supply gaps, reputational questions from retail customers, and potential scrutiny under due diligence legislation if the deficiencies point to systemic labor violations. It is worth including vessel detention history as a supplier qualification criterion and requesting copies of any port state control inspection reports as part of your routine supplier onboarding process. Proactive documentation checks before vessels transit high-scrutiny ports can help surface compliance gaps before they become detention events.

Does ILO C188 apply to fish processing workers on land-based facilities, or only to crew working on vessels?

ILO C188 applies specifically to workers employed or engaged on board commercial fishing vessels, so land-based processing facility workers fall outside its direct scope. For shore-side processing operations, the more relevant frameworks are SMETA, SA8000, or national labor law — all of which address factory-level conditions including wages, working hours, and health and safety. That said, a comprehensive labor compliance strategy for seafood supply chains needs to cover both vessel and facility levels, since risks and applicable standards differ at each tier. Using vessel-level standards like FISH Standard for Crew alongside facility-level audits like SMETA gives buyers a complete picture across the full supply chain.

Can a vessel flagged to a country that hasn't ratified ILO C188 still be held to its standards?

Yes — through port state control, a vessel can be inspected against C188 standards whenever it calls at a port in a country that has ratified the convention or enacted equivalent legislation, regardless of the vessel’s flag state. EU ports are a particularly important example: all vessels entering EU ports are subject to Directive 2017/159 requirements, which mirror C188, meaning flag-of-convenience vessels are not exempt simply because their flag state hasn’t ratified. Additionally, buyer contracts and certification scheme requirements can impose C188-equivalent standards as a commercial condition of doing business, creating another layer of obligation beyond what flag state law alone requires. This means the practical reach of C188 is considerably broader than the list of ratifying countries suggests.

What are the most common mistakes seafood companies make when trying to demonstrate ILO C188 compliance to buyers or auditors?

The most frequent mistake is treating compliance documentation as something to be assembled retroactively at the point of audit rather than collected systematically at the point of vessel discharge or voyage completion. By the time an audit request arrives, crew agreements may have expired, hours-of-rest logs may be incomplete, and vessels may have changed operators — making it extremely difficult to reconstruct a clean evidence trail. A second common error is confusing legal compliance with auditable compliance: a vessel may technically meet C188’s standards, but without documented, third-party-verified evidence, buyers and certification bodies have no reliable way to confirm it. Building documentation collection into your procurement workflow from the first mile, rather than leaving it to suppliers to provide on request, closes both of these gaps.

How does crew nationality or recruitment origin affect ILO C188 compliance and forced labor risk?

Crew nationality and recruitment pathways are significant risk factors because workers recruited through unregulated labor brokers or from countries with weak labor protections are more vulnerable to debt bondage, document confiscation, and other forced labor indicators — even on vessels that nominally comply with C188’s written standards. ILO C188 requires written fishers’ work agreements but does not itself regulate the recruitment process in depth, which is why complementary standards like FISH Standard for Crew include specific provisions on recruitment fees and broker practices. When assessing supply chain risk, it is worth asking suppliers to disclose crew nationalities, recruitment agencies used, and whether recruitment fees were charged to workers — since fee-based recruitment is one of the clearest early indicators of forced labor exposure. Cross-referencing this information with vessel behavior data from AIS and VMS systems provides a more complete risk picture.

Is ILO C188 compliance likely to become a legal requirement for seafood imports in major markets like the EU or US in the near future?

The regulatory direction in both the EU and US is clearly moving toward mandatory human rights and labor due diligence in supply chains, and seafood is explicitly in scope for several key instruments. The EU Forced Labour Regulation, which entered into application in 2027, enables the prohibition of products made with forced labor from the EU market, and the EU’s broader Corporate Sustainability Due Diligence Directive (CSDDD) requires large companies to identify and address human rights risks across their supply chains. In the US, the Uyghur Forced Labor Prevention Act has already been applied to seafood shipments, and there is growing congressional and agency interest in extending forced labor enforcement to fishing supply chains more broadly. Companies that establish robust ILO C188-aligned documentation and auditing practices now will be significantly better positioned to meet these emerging legal requirements than those who wait for formal mandates to take effect.

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