A Panamanian-flagged merchant vessel navigating international waters, emblematic of the Panama Ship Registry’s return to the Paris MoU White List. This milestone, announced in July 2026, underscores Panama’s strengthened maritime governance, enhanced Port State Control performance, and commitment to the highest standards of safety and regulatory compliance.
For centuries, the sea has been the great equalizer. It does not ask where you come from. It does not check your passport before a storm. It does not apply a cost-of-living index when a fire breaks out in the engine room.
Yet, on vessels flying the flags of developed nations, a Filipino or Indonesian seafarer can earn less than one-fifth of what a European colleague receives—for the same work, on the same ship, responding to the same alarms.
This is not market efficiency. This is discrimination. And it is time we called it what it is.
The Numbers That Shame an Industry
Consider this: an Indonesian seafarer on a Dutch-flagged vessel received USD 4.05 per overtime hour. His European colleague, standing watch on the same bridge, sleeping in the same quarters, facing the same perils, received USD 18.50. In a single month, with 173 overtime hours, the difference reached approximately USD 2,500 from overtime alone.
Same ship. Comparable work. Same alarms. Same fire. Same sea. But nearly five times the pay.
The usual defense? The cost of living is lower in the seafarer’s home country. But here is the inconvenient truth: during the contract, that seafarer is living on the ship. When both go ashore in Antwerp, the bus does not charge an Indonesian price. The restaurant does not check nationality before presenting the bill. The shop does not sell a cheaper SIM card to a Filipino.
The cost-of-living argument collapses under the weight of its own illogic.
A Ruling That Shakes the Foundations
On 18 August 2025, the Netherlands Institute for Human Rights (CRvdM) issued a landmark ruling that could reshape global maritime labor. It held that collective labor agreements applying the “country-of-residence” principle—which results in vastly lower wages for Southeast Asian seafarers—constitute unlawful discrimination under the Dutch Equal Treatment Act.
In one case, the pay structure amounted to direct discrimination based on nationality. In another, the residence-country principle created indirect discrimination against seafarers from the Philippines and Indonesia.
The ruling is not a binding court judgment. Judges are not obliged to follow it. But it has already triggered massive compensation claims, and claim foundations are now demanding extensive personnel and payment records from shipping companies.
Shipowners are running scared. Their reaction reveals everything: If equal treatment is enforced, ships may leave the Dutch flag.
Think about what that means. Companies are threatening to abandon a jurisdiction because they would no longer be permitted to preserve unequal pay. This is not healthy globalization. This is commercial fascism dressed as competitiveness.
The Changing Tide of International Law
For decades, shipowners and trade unions have justified these pay disparities by invoking the opinio juris—the belief that international law permits differential pay based on nationality. In 1997, the Equal Treatment Commission accepted this argument.
But the CRvdM now states that the opinio juris has changed.
The Maritime Labour Convention (MLC) of 2006, adopted by the International Labour Organization, includes Guideline B2.2.2.4(a): “Equal remuneration for work of equal value shall apply to all seafarers serving on the same ship, without discrimination based on race, colour, sex, religion, political opinion, national origin or social origin.”
While not binding, this provision confirms a growing international consensus: equal work deserves equal pay, regardless of where the worker comes from.
Moreover, the Dutch Minister of Social Affairs and Employment has repeatedly made reservations when declaring collective agreements generally binding—stating explicitly that equal treatment legislation takes precedence over the country-of-residence principle.
The legal foundation for discrimination is crumbling.
The Moral Case
Beyond the law, there is a deeper question: what kind of industry do we want to be?
The shipping industry demands equal competence, responsibility, sacrifice, and accountability from every seafarer. It demands that a Filipino officer protect the vessel, the cargo, the environment, and every life on board with the same skill as a European officer. Yet when payroll is prepared, dignity is distributed according to birthplace.
A collective agreement does not make discrimination acceptable. A thirty-year tradition does not become justice. International competition cannot excuse paying one human being less for work of equal value.
The sea does not recognize passports. Fire does not apply a cost-of-living index. A collision does not ask whether the officer comes from Europe, the Philippines, or Indonesia. If a seafarer is qualified enough to protect the ship, that seafarer is qualified enough to be paid fairly.
What Happens Next
The CRvdM’s ruling is not the final word. Dutch courts will make their own assessments, and legal battles will likely unfold over years. But the direction of travel is clear.
Shipping companies should seek legal counsel before responding to claim foundations demanding information. They should prepare for a future where equal pay is the norm, not the exception.
More importantly, they should ask themselves a harder question: are they on the right side of history?
The Courage to Act
Injustice prevails when good people recognize it but remain silent. Fortunately, there are those who choose to act. Through her research and courage, Dr. Viola Heutger stands with everyone who refuses to let discrimination hide behind tradition and commercial convenience.
Congratulations, Dr. Heutger. You have illuminated a shameful practice, and you have given seafarers hope that the sea might finally become the equalizer it has always pretended to be.
Same ship. Same rank. Same work. Same risk.
Equal pay.
Anything less is discrimination. And discrimination has no place on the waters that connect us all.
One thought on “Equal Pay for Equal Work at Sea: The Injustice That Sails On”
  1. This is a well-argued piece. What stands out most is the collapse of the cost-of-living defense once you consider that seafarers of all nationalities are living and working in the same shipboard environment during contract, the “cheaper at home” logic simply doesn’t hold up mid-voyage. For emerging maritime labor markets like Kenya’s, where we’re pushing to get more graduates certified and placed internationally, rulings like this matter beyond the Dutch flag, they set a reference point for how future bilateral and regional labor agreements might be negotiated. Worth watching whether IMO/ILO frameworks start referencing the CRvdM’s reasoning directly.

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