India’s latest order protects seafarers but creates immediate crewing, routing and contractual consequences for ships trading through the Gulf.
India’s maritime regulator has directed shipowners, ship managers and Recruitment and Placement Service Licence companies not to deploy Indian seafarers on vessels whose voyages involve passage through the Strait of Hormuz until further orders.
The instruction is contained in DGMA Circular 36 of 2026, dated 15 July 2026, following further attacks on merchant vessels and casualties involving Indian seafarers in the Persian Gulf region.
This is not a routine security advisory.
India is one of the world’s largest suppliers of maritime personnel, with more than 300,000 Indian seafarers employed across international fleets. Any restriction affecting their deployment through one of the world’s most strategically important shipping routes has consequences far beyond the Indian crewing market.
What the Order Actually Says
The circular directs:
- Shipowners
- Ship-management companies
- RPSL crewing companies
to avoid deploying Indian seafarers on vessels undertaking voyages involving passage through the Strait of Hormuz until further orders.
It also requires masters operating in the Persian Gulf, the Strait of Hormuz and adjoining waters to maintain heightened security vigilance, monitor navigational warnings and security advisories continuously, and apply the vessel’s Ship Security Plan and company procedures in accordance with the ISPS Code.
The wording matters.
The circular does not declare the Strait of Hormuz closed to shipping, nor does it prohibit ships carrying Indian crew from navigating where an immediate safety or operational decision must be made. It is principally a deployment restriction, aimed at preventing companies from assigning or sending additional Indian seafarers into voyages involving the strait.
It should therefore not be reduced to the inaccurate headline that “Indian seafarers are banned from Hormuz.” The regulatory focus is on the decisions made by employers, managers and crewing agencies before deployment.
Why India Has Taken This Step
The regulator identified recent attacks involving several merchant vessels, including Mombasa B, Al Bahyah, GFS Galaxy, MT Wedyan and Al Rekayyat. It stated that the incidents had significantly increased the risks faced by seafarers and commercial ships operating in the conflict-affected area.
Reuters reported that two Indian seafarers had been killed in regional attacks during the days preceding the order. The regulator concluded that continuing attacks and casualties required stronger precautions to safeguard Indian personnel serving on ships in the region.
This represents an important shift in regulatory posture.
Earlier security guidance generally concentrated on vigilance, voyage planning, watchkeeping and compliance with ship-security procedures. Circular 36 moves beyond operational caution and intervenes directly in the crewing decision.
The message is clear: where the risk cannot be adequately controlled, deployment itself should not take place.
The Immediate Effect on Shipowners and Managers
Owners and managers employing Indian crew must now examine every proposed crew change against the vessel’s expected voyage.
It is not enough to consider the port where the seafarer will join. The company must assess whether the vessel’s subsequent employment is expected to involve passage through Hormuz.
A seafarer joining in Fujairah, Jebel Ali, Muscat or another regional port could still fall within the restriction if the vessel is scheduled to proceed into or out of the Persian Gulf through the strait.
Companies should therefore review:
- Voyage instructions
- Charter commitments
- Expected loading and discharge ports
- Crew-change locations
- Joining flights and visas
- Relief schedules
- Vessel employment after joining
- Contingency plans if trading orders change
A crew deployment that appears compliant when booked may become problematic if charterers later nominate a Gulf port.
Crewing and commercial departments can no longer operate independently on these voyages. Deployment decisions must be checked against the vessel’s current and reasonably foreseeable trading pattern.
Existing Crews Present the Harder Problem
Preventing new deployment is operationally simpler than protecting thousands of Indian seafarers who may already be serving on ships inside the Persian Gulf or positioned west of the strait.
Reuters cited the Forward Seamen’s Union of India as estimating that more than 15,000 Indian seafarers remained west of Hormuz at the time of reporting. The union raised concerns about how personnel already exposed to the conflict zone would be protected or relieved.
Circular 36 does not automatically repatriate those seafarers or resolve the practical difficulties associated with crew relief.
For existing crew, the company must assess:
- Whether the vessel can safely remain in its present location
- Whether an alternative crew-change port is available
- Whether replacement personnel can legally and practically join
- Whether the ship can be rerouted
- Whether the seafarer’s contract will need to be extended
- Whether consent is required for continued service in a high-risk area
- Whether additional insurance or compensation applies
- Whether medical, welfare and communication arrangements remain adequate
Extending contracts simply because replacements are unavailable is not a complete solution.
Fatigue, anxiety, family pressure and prolonged exposure to a conflict zone can affect judgement and operational performance. Welfare considerations must form part of the vessel’s safety assessment.
A Crewing Restriction Can Become an Operational Restriction
A ship may be technically capable of trading through Hormuz but unable to maintain a safe and compliant crew rotation.
This is where a personnel directive begins to influence vessel deployment.
A manager heavily dependent on Indian officers and ratings may need to arrange alternative nationalities for future crew changes. That process can involve different certification checks, flag-State endorsements, visa requirements, travel routes, wage structures and employment conditions.
It may also disrupt established crew matrices.
Replacing one individual is not always straightforward. Tankers, gas carriers and specialised vessels may require personnel with vessel-specific experience, cargo endorsements and familiarity with the company’s safety-management system.
A rapid substitution that satisfies the minimum certificate requirement may still weaken onboard competence.
Owners must avoid solving one risk by creating another.
Chartering and Contractual Consequences
The order also has commercial implications.
A vessel fixed for Gulf employment may experience additional crew-change costs, delays or difficulty maintaining required manning levels. Owners may need to evaluate whether charterparty provisions address:
- Changes in government regulations
- War-risk trading
- Crew replacement expenses
- Deviation for crew changes
- Delay caused by security restrictions
- Charterers’ employment orders
- Unsafe-port or unsafe-place considerations
- Additional insurance premiums
- Seafarers’ refusal to enter a high-risk area
Liability will depend on the wording of the relevant charterparty and the facts of the voyage.
Owners should not assume that every additional cost automatically falls to charterers. Charterers should equally avoid assuming that an employment order remains reasonable merely because the port is technically open.
The restriction makes early dialogue essential.
Commercial instructions should be reviewed by operations, crewing, marine, legal and insurance teams before the vessel is committed to a voyage that may be difficult to crew safely.
What Masters Must Do Differently
The circular places specific emphasis on the master’s responsibility to maintain heightened vigilance.
That means more than forwarding security emails to the bridge team.
The master should ensure that the vessel is actively monitoring:
- Navigational warnings
- Coastal-State instructions
- Company security updates
- Maritime-security reporting centres
- Traffic patterns
- AIS-related guidance
- Suspicious approaches
- Drone, missile or small-craft threats
- Changes to port and anchorage security
The Ship Security Plan must remain operational rather than documentary.
Additional measures may include restricting external access, increasing bridge and deck watchkeeping, testing communication systems, reviewing emergency stations, minimising unnecessary deck exposure and ensuring that the crew understands the response to attack, fire, flooding or abandonment.
Security decisions should be recorded clearly, particularly where the master believes that commercial instructions expose the ship or crew to unacceptable danger.
What Shipping Companies Should Do Now
Companies employing Indian seafarers should take immediate, documented action.
1. Freeze Non-Compliant Deployment
Any joining arrangement involving a vessel expected to transit Hormuz should be stopped and reviewed before the seafarer travels.
2. Identify Every Exposed Seafarer
Companies should produce a vessel-by-vessel list of Indian personnel currently operating in the Persian Gulf, Hormuz and adjoining waters.
3. Review Crew-Change Plans
Relief arrangements should be tested against port access, flight availability, visa requirements, replacement competence and the vessel’s voyage schedule.
4. Reassess Voyage Risk
A generic regional risk assessment is insufficient. Each vessel requires an assessment based on its route, cargo, speed, freeboard, flag, ownership profile and operating pattern.
5. Communicate Directly With Crew
Seafarers should receive verified information from the company rather than being left to depend on social media or informal reports.
6. Review Contracts and Insurance
Employment agreements, collective bargaining provisions, war-risk clauses, P&I guidance and charterparty responsibilities should be checked before further commitments are made.
7. Prepare for Rapid Deterioration
The company should define who has authority to reroute the vessel, suspend operations, arrange evacuation or escalate the matter to flag, coastal and national authorities.
A Necessary Decision With Wider Consequences
The DGMA order places seafarer safety ahead of routine crew availability.
That is justified when merchant ships and their crews are being exposed to direct attack. Seafarers should not be treated as an interchangeable labour supply that can be deployed into a conflict area because the voyage remains commercially attractive.
At the same time, the restriction demonstrates how quickly geopolitical risk can move from the security department into crewing, chartering and fleet operations.
A strait does not need to be formally closed for shipping to be severely disrupted.
When crews cannot safely join, insurers reassess exposure, governments issue restrictions and owners question the acceptability of orders, the route’s practical capacity begins to narrow even while vessels continue to transit.
Final Thoughts
DGMA Circular 36 is more than an Indian crewing notice. It is a warning to the wider shipping industry that the human element can no longer be separated from voyage-risk calculations in the Gulf.
Owners and managers must now prove that their security controls, crew-change plans and commercial decisions are aligned.
The critical question is no longer only whether a vessel can pass through Hormuz.
It is whether the company can justify sending its seafarers there.