Work Permit Exemption for Foreign Seafarers
Foreign seafarers working on vessels registered with the Turkish International Ship Registry (TUGS) and operating outside Turkish cabotage routes may be eligible to work in Türkiye with a Work Permit Exemption Certificate, provided that the relevant conditions are met.
This exemption is regulated under Article 48/1-l of the Regulation on the Implementation of the International Labour Force Law.
The relevant application category in the Ministry of Labour’s online system is “Other Application Types → Seafarer.”
Who Can Benefit from a Work Permit Exemption?
A foreign seafarer may be eligible for a work permit exemption under Article 48/1-l if the following conditions are met:
- The vessel is registered with the Turkish International Ship Registry (TUGS),
- The vessel operates outside Turkish cabotage routes,
- The foreign national is working as a seafarer on the vessel,
- The required Certificate of Conformity (Uygunluk Onayı Belgesi) has been obtained from the relevant authority.
The Ministry of Labour specifically defines this category as foreign seafarers working on vessels that are registered with TUGS, operate outside cabotage routes and have obtained the required Certificate of Conformity from the relevant authority.
If these conditions are not met, the application may not qualify under Article 48/1-l.
What Is the Turkish International Ship Registry (TUGS)?
The Turkish International Ship Registry (TUGS) is a ship registry established under Law No. 4490 on the Turkish International Ship Registry.
For the seafarer work permit exemption, it is important that the vessel is not simply Turkish-flagged, but is specifically registered with TUGS, as required under the relevant regulation.
The vessel’s registry status should therefore be checked before submitting an application.
What Does “Operating Outside Cabotage Routes” Mean?
For a work permit exemption under Article 48/1-l, the vessel must operate outside Turkish cabotage routes.
The vessel’s actual activities and routes should therefore be reviewed before the application.
Being a Turkish-flagged vessel or being owned by a company operating in Türkiye does not, by itself, qualify the vessel or the seafarer for this exemption.
What Is the Certificate of Conformity?
The Certificate of Conformity (Uygunluk Onayı Belgesi) is one of the requirements for a work permit exemption under Article 48/1-l.
The Ministry of Labour requires foreign seafarers working on TUGS-registered vessels operating outside cabotage routes to have the required Certificate of Conformity issued by the relevant authority.
Seafarers’ qualifications and certification are also subject to the applicable international STCW Convention and relevant Turkish regulations.
For this reason, the seafarer’s documents and the relevant administrative requirements should be reviewed before applying.
Seafarer’s Documents
The seafarer’s qualifications and other relevant documents are important when assessing the application.
The type of documents required and whether the seafarer’s certificates are recognised in Türkiye may depend on the individual case and the applicable arrangements between Türkiye and the relevant country.
The seafarer’s passport, seafarer certificates and other relevant documents should therefore be checked before the application.
How Long Is the Work Permit Exemption Valid?
For seafarers covered by Article 48/1-l, the work permit exemption is issued based on the duration of the employment or service contract.
The Ministry of Labour’s official exemption table specifies the exemption period for this category as the “duration of the employment/service contract.”
The exemption period must also be 60 days shorter than the validity period of the foreigner’s passport or equivalent travel document.
Does the Work Permit Exemption Replace a Residence Permit?
Yes.
A valid Work Permit Exemption Certificate serves as a residence permit for the period of its validity.
Foreign nationals holding a valid work permit exemption may also enter and leave Türkiye during the validity period of the exemption.
However, periods spent in Türkiye under a work permit exemption are not counted as periods of residence or work permit status for the purposes of calculating statutory residence or work permit periods.
How to Apply for a Seafarer Work Permit Exemption
Applications for a seafarer work permit exemption are submitted electronically through the e-Muafiyet system of the Ministry of Labour.
Before applying, it is important to confirm that both the vessel and the foreign seafarer meet the requirements of Article 48/1-l.
Depending on the application, the following information and documents may be reviewed:
- The vessel’s TUGS registration,
- The vessel’s activities and routes,
- The foreign seafarer’s passport details,
- Seafarer qualifications and relevant certificates,
- Certificate of Conformity,
- Employment or service contract,
- Employer or company information,
- Any other documents required for the application.
Submitting the application under the correct category and with the required documents is important for the proper processing of the application.
Work Permit Exemption or Regular Work Permit?
A foreign seafarer does not necessarily need to apply for a regular work permit in every case.
If the vessel and the foreign seafarer meet the requirements of Article 48/1-l of the Regulation on the Implementation of the International Labour Force Law, the seafarer may work in Türkiye under a Work Permit Exemption Certificate instead of a regular work permit.
If the exemption requirements are not met, a regular work permit may be required depending on the nature and circumstances of the work in Türkiye.
For this reason, the applicable work authorisation should be determined before starting the application process.
Seafarer Work Permit Exemption Services | RL Turkey
At RL Turkey, we provide professional assistance to foreign seafarers and companies employing foreign seafarers in Türkiye.
Our services include:
- Reviewing the vessel’s registry status,
- Assessing the vessel’s activities and routes,
- Reviewing the foreign seafarer’s documents and qualifications,
- Assessing the Certificate of Conformity requirements,
- Preparing the required documents and information,
- Submitting the e-Muafiyet application,
- Following up on the application process.
If you are unsure whether your seafarer requires a regular work permit or a Work Permit Exemption Certificate, RL Turkey can review your situation and determine the appropriate application process.
