Brazil Clarifies Hiring Rules for Cruise Ship Crew

Brazil’s Labor Committee within the Chamber of Deputies has approved a measure stating that Brazilian crew members recruited by agencies to work on cruise ships are not considered employees under Brazilian labor legislation (CLT).

In practical terms, this means their contracts are not regulated by Brazil’s domestic labor code. Instead, they fall under international maritime employment standards.

The proposal still must pass through the Constitution, Justice and Citizenship Committee, and later receive approval from the full Chamber and the Senate before it can take effect.

While this development aims to give cruise operators more legal certainty, it does not resolve the immediate challenges faced by Brazilian applicants.

By late 2024, several major cruise brands, including Princess Cruises, had already stopped hiring Brazilian crew members. Some candidates who were close to completing their onboarding were abruptly notified that their roles had been canceled.

Applicants reported being told that companies were temporarily avoiding Brazilian hires due to “high legal risk.” Others said recruitment agencies paused the processing of Brazilian applications without offering a reason. These sudden freezes have left many people frustrated and unsure about their career prospects with affected applicants saying they felt “punished for something they did not do,” while others worried that cruise lines might shift long-term hiring toward other nationalities.

Crew members already working onboard remain covered under the MLC, but those trying to join the industry are facing the greatest impact.

If the proposal eventually becomes law, it could give cruise operators the legal reassurance they have requested for years. It would formally confirm that employing Brazilian crew does not subject companies to CLT requirements.

However, cruise lines generally wait for complete legal certainty before adjusting hiring policies. Even after the proposal is enacted, companies may choose to observe how Brazilian courts interpret and apply the new rule before reopening recruitment.

Well before the new legislation was drafted, Brazil experienced a rise in court cases brought by former cruise ship employees. Many former crew members sought CLT rights through Brazilian labor courts, arguing they were entitled to overtime pay, FGTS deposits, severance, and other protections.

Several rulings in favor of ex-crew members surprised the industry. These decisions indicated that, under certain conditions, CLT regulations could be applied to contracts traditionally governed by international maritime law.

From the standpoint of cruise companies, this introduced substantial legal and financial uncertainty:

• If Brazilian courts applied CLT retroactively,
• Companies could be exposed to major liabilities for both past and future contracts.

This risk is what triggered the suspension of Brazilian hiring. Cruise lines paused recruitment to shield themselves until the legal landscape became more predictable.

The new proposal is intended to resolve these concerns, but it comes after many companies have already adjusted their recruitment strategies.