Auditing At-Sea Forced and Child Labour Eligibility

Understanding MSC forced and child labour eligibility rules

The Marine Stewardship Council mandates that all fishery applicants and at-sea certificate holders demonstrate compliance with strict human rights and labour eligibility criteria. Under Clause 7.4.8.4 of the MSC Fisheries Certification Process version 2.3 and Clause 1.1.7 of version 3.0, any fishery containing an entity convicted of forced or child labour within the preceding two years is ineligible for certification. This policy safeguards supply chain integrity and ensures that sustainable seafood claims reflect ethical working conditions at sea.

To operationalise these requirements, the Marine Stewardship Council requires clients to complete and submit the MSC At Sea Forced and Child Labour Eligibility Requirements Reporting Template. This reporting mechanism applies to all wild-capture fisheries and at-sea Chain of Custody operations seeking initial assessment, reassessment, or ongoing surveillance. Quality leads and compliance managers must ensure this document is submitted in good faith, reflecting known operational facts across the entire Unit of Assessment.

Failure to meet labour eligibility criteria carries severe regulatory consequences for certificate holders. Under Clause 7.4.3.g and Clause 7.4.10.j of the MSC General Certification Requirements version 2.7, Conformity Assessment Bodies must suspend a fishery or Chain of Custody certificate if it includes an entity that fails to conform to labour policy. Clause 7.4.15 mandates a minimum suspension period of three months, or until the client proves complete conformance with eligibility rules.

Structure and completion of the self-description template

The reporting template consists of two distinct parts designed to capture both legal compliance and detailed operational practices. Section 1 requires a direct confirmation regarding whether any entity in the fishery client group has been implicated in a conviction for forced or child labour in the last two years. Section 2 requires a comprehensive self-description of policies, regulatory frameworks, and private sector measures that protect fishing crew from exploitation.

Clients must complete Section 2 in English, which serves as the official language of the Marine Stewardship Council. Every field across the fourteen designated reporting categories must contain relevant detailed entries or an explicit entry of not applicable accompanied by a short justification. Once completed, the Conformity Assessment Body uploads the template to the official scheme database for public release alongside the Public Certification Report.

Completing the document requires systematic collaboration between fishery management, vessel owners, and fleet operators. Internal auditors must review each field against objective evidence to ensure entries accurately represent vessel operations and flag state oversight.

• Gather all vessel owner details, client group cost-sharing agreements, and flag state maritime labour regulations across the Unit of Assessment.
• Verify that no associated entities or vessels have incurred court convictions or legal penalties for forced or child labour during the prior twenty-four months.
• Populate all fourteen fields of Section 2 in clear English, providing specific operational details regarding recruitment, crew contracts, minimum age checks, and repatriation.
• Review the completed document with the Conformity Assessment Body prior to publication on the Marine Stewardship Council database.

Evaluating key compliance fields and evidence requirements

Compliance leads must understand the specific evidence needed to support each field within Section 2 of the template. Auditors examine whether the self-description accurately aligns with national statutory obligations, flag state oversight, and company-level crew management systems.

Key risk areas include recruitment fee structures, document retention policies, and worker grievance pathways. The table below outlines core template requirements, auditor verification focus points, and necessary documentation.

Managing convictions, self-declarations, and audit actions

When an entity within a fishery client group becomes implicated in a conviction for forced or child labour, internal compliance protocols must immediately take effect. Under MSC Fisheries Standard version 3.0 Clause 1.1.5 and Clause 1.1.5.1, any vessel implicated in a conviction for a serious crime—including human trafficking or forced labour—must be excluded from the Unit of Assessment, Unit of Certification, and fishery certificate for two years.

The client group must immediately notify the Conformity Assessment Body upon learning of any relevant conviction. Under Clause 7.4.7 of the Fisheries Certification Process, excluding a convicted vessel outside scheduled surveillance triggers an expedited audit by the certifier to confirm exclusion and update official certification documentation.

Example

During an internal compliance review, a tuna purse seine fishery client discovers that a subcontracted vessel operator within its client group was convicted in court six months ago for using forced migrant labour on board. The compliance lead immediately informs the Conformity Assessment Body and initiates the mandatory vessel exclusion process. The client removes the vessel from the official fleet roster, revokes its access to the fishery certificate, and submits an updated Scope Declaration. The certifier conducts an expedited audit, verifies that the vessel no longer lands fish under the certificate, and republishes the updated certificate documentation within thirty days, allowing the remaining fishery client group to maintain valid certification.

Before your audit

• Verify that no vessel or entity in the client group has a forced or child labour conviction in the last two years.
• Complete all unshaded fields in Sections 1 and 2 of the reporting template in English.
• Provide clear written justifications for any field marked as not applicable.
• Collate sample crew contracts, manning agency agreements, and wage deduction policies for review.
• Ensure vessel captains maintain written protocols allowing crew free access to personal identity documents.
• Check that national minimum age requirements and young worker protections are clearly documented.
• Confirm that grievance reporting pathways, such as worker hotlines or seafarer ministry contacts, are active.
• Submit the finalised template to your Conformity Assessment Body before the audit report announcement date.

Questions people ask

Who must complete the MSC forced and child labour reporting template?

All fishery applicants, at-sea Chain of Custody certificate holders, and client group members seeking certification or reassessment against Marine Stewardship Council standards must complete the template.

What happens if a fishery fails to submit the completed labour template?

The Conformity Assessment Body cannot publish the assessment report or grant certification until the client submits a fully completed template meeting all reporting instructions.

Does completing the self-description template mean the fishery is certified against a social standard?

No, the template is a self-declared transparency document published on the Marine Stewardship Council website and does not constitute third-party social certification.

What is the penalty if an entity in the fishery is convicted of forced labour during the certificate cycle?

The certificate holder must exclude the convicted entity for two years, and failure to do so results in certificate suspension under General Certification Requirements for a minimum of three months.

Reference documents

• MSC At Sea Forced and Child Labour Eligibility Requirements Reporting Template version 3.0
• MSC General Certification Requirements version 2.7
• MSC Fisheries Certification Process version 2.3
• MSC Fisheries Certification Process version 3.0
• MSC Fisheries Standard version 2.01
• MSC Fisheries Standard version 3.0