Overview

On 18 July 2025, the Directorate General of Shipping (DGS), India, issued Circular 31/2025—a policy that has ignited intense debate within the Indian seafaring community. The circular addresses the challenge of fraudulent and unapproved maritime certifications among Indian seafarers but imposes wide-reaching restrictions that may affect over 10,000 professionals1 ,2 ,3.

Key Provisions of Circular 31/2025

Ban on Unapproved Certifications: Indian seafarers holding Certificates of Competency (CoC) or Proficiency (CoP) from unapproved or non-recognized foreign maritime authorities cannot be employed by RPSL (Recruitment and Placement Service Licence) agents.
Recognized Certificates: Only certificates issued by DGS-approved Indian maritime institutes, or by countries with mutual recognition agreements under STCW I/10 with India, are considered valid.
India has signed bilateral agreements for mutual recognition of CoCs/CoPs with several countries. This means that certificates issued by these maritime administrations are generally accepted for Indian seafarers serving on foreign-flagged ships. According to the latest information, these include:
- Malaysia
- UAE (United Arab Emirates)
- South Korea (Republic of Korea)
- Sweden
- United Kingdom (UK)
- Iran (Islamic Republic of Iran)

Certificates from Specific “White List” Countries (with verification): In addition to the countries with formal bilateral agreements, DGS Circular 31 of 2025 also states that Indian seafarers holding CoC/CoP and modular course certificates issued by the following countries may be accepted for recruitment if the certificates were obtained by attending training in these countries and their authenticity can be verified online from the respective maritime administration:
- Singapore
- Australia
- New Zealand
- Canada
- Ireland
Fraudulent Certificates: The circular explicitly targets and invalidates CoCs/CoPs obtained through fraudulent means or from unapproved/unrecognized maritime administrations. Countries that have been specifically mentioned as sources of problematic certificates include Honduras, Panama, Gabon, Togo, and Belize. Seafarers holding certificates from these jurisdictions (often acquired through agents or non-approved institutes) will now be ineligible to sail under the DGS’s oversight and face severe penalties.

Penalties: Use of invalid certifications can lead to cancellation of a seafarer’s Continuous Discharge Certificate (CDC), deactivation of INDoS number, and permanent debarment from service.
Port Monitoring: Port State Control Officers are directed to rigorously check crew documents for compliance during vessel calls at Indian ports1 ,4.

Intended Rationale

Eliminate Fraudulent Practices: The circular responds to years of complaints about fake CoCs and stranded Indian seafarers on dubious “flags of convenience” vessels, often linked to fraudulent certifications1 ,5.
Enhance Safety and Compliance: Indian authorities aim to align with international maritime standards by curbing the “certification shopping” industry, which undermines competence and vessel safety.
Support Indian Training: The move is designed to reinforce confidence in India’s own maritime training infrastructure1 ,6.

Legal Contradictions

High Court of Madras – WP 28350 of 2017

The Madras High Court, in WP 28350 of 2017 (video order dated 01.09.2022), made the following critical observation in Para 9:

“The Centre government is not empowered to prevent an Indian citizen from seeking direct employment with a foreign ship owner. Any blanket prohibition infringes upon the constitutional rights of citizens.”7 ,8

Following a legal challenge to DG Shipping’s earlier prohibition, the court ruled it unconstitutional to restrict the right of Indian seafarers to be employed directly by foreign ship owners—even if not routed via an RPSL. The government’s attempt to regulate such direct employment was found to exceed statutory authority7 ,9, and the judgment was upheld by a division bench10.

Circular 31/2025: Legal Standing

The new circular appears to conflict with the Madras High Court’s precedent, especially in how it criminalizes certifications that may be legitimately obtained from third countries. There are widespread concerns regarding:

Jurisdictional Overreach: The circular tries to impose India’s standards on Indian citizens working on foreign-flagged vessels, potentially exceeding the regulatory powers recognized by law and by the court1 ,7.
Potential Violation of Rights: Blanket restrictions on all forms of foreign-issued certifications (regardless of their legitimacy) risk infringing upon constitutionally guaranteed rights, as stated by the Madras High Court.

Impact on Indian Seafarers

Large-Scale Job Losses: Estimates suggest between 10,000 and 20,000 Indian seafarers could be rendered jobless, particularly those working on foreign-flagged ships with certifications from countries not recognized under India’s I/10 mutual agreements2 , 11 , 3.
Disrupted Careers: Many seafarers obtained foreign certifications through legitimate pathways well before the new circular—a move now jeopardizing their livelihoods without a proper transition plan.
Confusion and Uncertainty: The exclusion of certain “White List” countries (like Singapore and Canada) from India’s I/10 regime has caused confusion and anxiety among those with such certifications1.

Social Media and Industry Reaction

Outrage and Petitions: Social media is awash with protests—posts and petitions decrying the policy as both unfair and economically devastating for families reliant on seafarer incomes11 ,2 ,3.
Webinars and Advocacy: Unions and advocacy groups are organizing webinars, workshops, and petition drives calling for amendment or reversal of the circular12.
Division within Industry: Some senior mariners support the move as necessary for compliance and safety, while younger and mid-career seafarers view it as an attack on their basic rights and job security6 ,13.

Implementation Challenges

Global Enforcement Issues: Shipping is a transnational industry. Attempting to police Indian citizens serving on foreign-flag vessels runs into jurisdictional and enforcement obstacles.
Workarounds and Loopholes: Overly strict rules may push seafarers into unregulated pathways, including informal arrangements that escape regulatory oversight—thus undermining the aim of improved compliance1.
Legal Backlash: Failure to reconcile the circular with court rulings exposes stakeholders to fresh rounds of litigation, and may weaken India’s international maritime reputation.

Recommendations and Solutions

1. Broaden I/10 Mutual Recognition

Expedite bilateral agreements with all reputable “White List” maritime countries to ensure Indian seafarers are not arbitrarily disqualified for holding recognized foreign certificates.

2. Nuanced Regulation Instead of Blanket Bans

Target fraudulent and unaccredited certifications directly, rather than penalizing all holders of non-Indian certificates.
Enable exceptions or recognition pathways for seafarers with demonstrated legitimate training and experience abroad.

3. Legislative Clarity and Compliance with Judiciary

Any new regulations should be in strict alignment with established court rulings, especially upholding constitutional rights to work and seek employment abroad.

4. Support and Transition Assistance

Provide guidance and upskilling opportunities for affected seafarers, including support to convert or regularize legitimate foreign certifications under Indian standards.

5. Stronger Action Against Agents, Not Seafarers

Ramp up action against fake recruitment agents and unapproved training institutes, instead of targeting the end-beneficiaries—Indian seafarers.

Conclusion:
DG Shipping Circular 31/2025 represents a major policy crossroad for Indian seafarers. While the intent—to fight certificate fraud and boost standards—is worthy, the implementation urgently needs a rights-based, internationally aligned, and judicially sound approach if it is to protect both Indian jobs and the nation’s maritime reputation1 ,11 ,2 ,7.

Check sources for further reference –

DG Shipping Circular 31 of 2025: Impact, Legality, and Solutions