Pratik Bijlani – As India’s maritime administration seeks to strengthen financial protection for seafarers, a key question is emerging across the recruitment and placement sector: where should responsibility for that protection ultimately lie? That question formed the centre of an online industry consultation organised by the International Maritime Federation (IMF), with support from the Forward Seamen’s Union of India (FSUI), on 7th September to examine DGMA Order No. 22 of 2026, particularly its proposed ₹1 crore financial requirement for RPSLs.
The consultation brought together RPSL operators and maritime stakeholders to examine the legal basis of the Order under Section 301, the proposed compliance timeline, the allocation of financial responsibility and possible alternatives, including surety or security bonds. A five-question poll also sought industry views on whether the ₹1 crore requirement should be reviewed and whether wider consultation should precede implementation.
Opening the session, IMF Vice Chairman Ms. Aishwarya Pilankar stressed that the discussion should be about finding a workable balance rather than opposing regulation itself. “Regulation is necessary, accountability is necessary, and financial security is necessary. But regulation must protect the system without unintentionally weakening the industry. We need practical, proportionate and sustainable solutions that protect seafarers while preserving the RPSL employment ecosystem for India.” she said.
IMF Chairperson Mr. Vivek Rastogi welcomed the Order’s focus on seafarer protection but questioned whether RPSLs should carry liabilities associated with risks controlled by shipowners, charterers or managers. “RPSLs are recruitment and placement agencies, not shipowners, charterers or operators. Any new financial obligation must therefore be proportionate and practical. We need consultation with the industry before implementation, so that seafarer protection is strengthened without harming legitimate Indian employment.” Rastogi said.
For FSUI General Secretary Mr. Manoj Yadav, the central issue was equally about legal clarity and proportionality. He questioned the applicability of the ₹1 crore requirement, including whether it extends to foreign-flag vessels, and argued that owner-related seafarer liabilities should be viewed in the context of the Maritime Labour Convention. “Regulation must be based on facts, clarity and consultation. The ₹1 crore requirement raises fundamental questions about its basis, applicability and proportionality. We must examine the legal framework, address insurance gaps and ensure that measures genuinely protect seafarers without imposing unfair burdens.” Yadav said.
The open discussion revealed the breadth of industry concern. Mr. Ujjwal Chaudhary supported recognised financial-security bonds as a potential alternative to bank guarantees, arguing that such mechanisms could provide protection without unnecessarily locking up RPSL working capital. Mr. Vinod Kumar questioned why manpower providers should assume liabilities outside their operational control and raised concerns about bank guarantees, insurance approvals and licensing consequences.
Capt. Jagdeep Kahlon sought greater clarity on the basis for the ₹1 crore figure, while Mr. Kuldeep Kumar warned that sudden regulatory and infrastructure requirements could disproportionately affect smaller RPSLs. Mr. Satendra Singh highlighted the financial pressure created by existing guarantees, welfare obligations and the proposed insurance requirement.
Other participants focused on legal and institutional gaps. Mr. Rakesh Johri questioned the need for additional P&I requirements where existing MLC provisions already place liabilities on owners, while Mr. Atul Jadhav argued that compensation obligations should be grounded firmly in applicable law and remain primarily with shipowners through P&I cover.
The discussion increasingly turned towards collective action. Ms. Deepa Anand proposed consolidating industry concerns into a common document supported by affected RPSLs, while Mr. Arun Kumar Saini urged stakeholders to move from discussion to a coordinated representation before DGMA. Capt. Nazir Upadhye called for wider circulation of the consultation poll and regular communication of industry conclusions to the authorities. Mr. Shahzad Mallick advocated greater engagement with DGMA, including stronger systems for verifying P&I and DMLC documentation before Form 1 issuance.
One recurring theme was the search for a mechanism that protects seafarers without undermining the companies responsible for recruiting them. The proposed surety or security-bond model emerged as one potential route, while the broader debate highlighted the need to distinguish clearly between the responsibilities of shipowners, managers, insurers and RPSLs.
The consultation ultimately reflected a maritime industry seeking regulation that is both protective and workable. With the proposed Order carrying implications for the financial viability of RPSLs and, by extension, employment opportunities for Indian seafarers, the discussion underscored the importance of consultation before implementation. The challenge now is to convert the concerns raised by stakeholders into a common, evidence-based framework that strengthens seafarer protection while preserving a sustainable and credible Indian manning ecosystem.
Marex Media