The Federation of Trade Unions of Transport Trade Unions of Ukraine, the second largest representative trade union association at the national level and the largest public organization representing the interests of transport workers, expresses its respect to you and addresses the following.
On January 1, 2026, amendments to the Code on the Training, Certification, and Watchkeeping of Seafarers (hereinafter referred to as the amendments) came into force in accordance with Resolution MSC.560(108) of the International Maritime Organization, adopted on May 23, 2024. On this basis, on November 7, 2025, the State Service of Maritime and Inland Water Transport and Shipping of Ukraine (hereinafter referred to as the Shipping Administration) published a notice on its official website about the need for all seafarers to undergo the new training system approved by the amendments or additional safety training, taking into account the changes made. At the same time, the notice stated that all valid safety training certificates issued by Ukrainian seafarer training institutions will remain valid for the period specified therein only if the seafarer training institutions provide additional training in the specified areas of competence in preventing and responding to violence and harassment, including sexual harassment, bullying, and sexual violence. It should also be noted that all communications from the Maritime Administration on this issue are accompanied by information that these measures are being taken “despite the absence in national legislation of provisions on the expiry of initial safety training certificates in the event of changes in international legislation.”
The Federation of Trade Unions of Transport Trade Unions of Ukraine, as an active participant in the international trade union movement, as well as its founder, the Trade Union of Maritime Transport Workers of Ukraine, as a full member of the International Transport Workers' Federation and the European Transport Workers' Federation, representing the interests of more than 80,000 Ukrainian seafarers and employees of the national maritime infrastructure, consider it an unconditional priority for Ukraine to fulfill its obligations under international treaties, in particular those whose key objective is to introduce decent working conditions. At the same time, we believe that the aforementioned decision of the Shipping Administration poses significant risks to the economic security of the state, given that thousands of Ukrainian seafarers, in the context of a full-scale armed invasion, may prematurely lose access to their jobs due to the premature invalidation of documents confirming their qualifications. Moreover, a study of international experience in implementing the above amendments shows that European Union countries are finding ways to avoid creating barriers to access to jobs for their citizens in the context of introducing amendments. An example of this is the official letter from the Maritime Safety Administration of the Ministry of Maritime Affairs, Transport, and Infrastructure of Croatia dated November 10, 2025, No. 530-04-3-1-25-1, which states that all certificates issued by Croatia before December 31, 2025 (i.e., before the amendments come into force) will be considered valid for their entire period of validity without any restrictions or additional steps on the part of their holders. As for checking whether seafarers meet the new standards, this will be done during the scheduled renewal of such certificates. At the same time, Ukrainian seafarers currently rank fifth in the world and are among the top three European countries in terms of the number of national merchant fleet crews, so creating obstacles to their access to jobs will inevitably lead to a global labor shortage.
Unfortunately, the efforts made by the trade union side to resolve this issue through working procedures have not yielded the desired results to date. Given the critical security and socio-economic situation in which our country finds itself as a result of many years of aggressive armed invasion, as well as the key role played by Ukrainian sailors in ensuring the export of Ukrainian goods and supplying the Ukrainian economy, we appeal to you, Dear Prime Minister, regarding the need for you to instruct the relevant ministries and agencies to intervene in this situation, study it further, and facilitate the adoption of a decision on this issue that, in the context of the ongoing war, will not create unnecessary barriers to Ukrainian sailors' access to jobs.
At the same time, The Federation of Trade Unions of Transport Trade Unions of Ukraine and the Trade Union Marine Transport Workers’, as co-founders of the Joint Representative Body of Trade Unions at the national level and signatories to the General Agreement between the Government, employers, and trade unions, undertake to take all possible additional steps to maximize Ukraine's fulfillment of its international obligations regarding the compliance of its workers with the highest standards of safety and proper conduct in the workplace.
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