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The Underreporting Blindspot: Enforcing the eNAVIK and Indian Seafarer Tracking in High-Risk Maritime Zones

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The 2026 geopolitical conflict in West Asia brought repeated attacks on merchant vessels in the Arabian Gulf, the Strait of Hormuz and the Gulf of Oman, threatening major energy and international commercial shipping routes. For India, the consequences of such disruptions extend beyond energy supply and directly affect the safety of Indian seafarers serving on both Indian and foreign-flagged vessels (Directorate General of Maritime Administration 2026a). The attacks on Liberia-flagged Motor Tankers Al Bahiyah and MT Mombasa at the Strait of Hormuz on July 14, 2026, which killed 1 Indian crew member and injured 10 (Press Information Bureau, Government of India 2026b), demonstrated how a crisis centred on a maritime chokepoint can have serious effects on the people operating the vessels and how difficult it is to identify the exposed population on a foreign vessel.

Later on, the Directorate General of Maritime Administration (DGMA) built a comprehensive framework under the ‘Seafarer-First’ initiative accounting for every Indian seafarer regardless of a vessel’s flag (Press Information Bureau, Government of India 2026a). However, its success relies largely on manual information supplied by shipping companies and recruitment agencies. This article evaluates India’s institutional response and argues that to effectively protect its citizens, the maritime security architecture must transition from a model of passive corporate compliance to an active framework anchored in seafarer self-reporting and automated data cross-verification.

India’s Reactive Policy Evolution Through the Conflict

As the conflict intensified, India’s initial regulatory steps were advisory in nature. The DGMA directed shipping companies and Recruitment and Placement Services License (RPSL) agencies in June to restrict deployment to high-risk maritime zones and permit only emergency crew changes with the consent of seafarers (Directorate General of Maritime Administration 2026b). Vessels operating in the region were also mandated to follow a daily online reporting routine, and Company Security Officers (CSOs) were asked to submit crew lists for ships already stationed there (Directorate General of Shipping 2026a). By August, maritime administrators required stakeholders to coordinate Hormuz transits through the Directorate’s communication centre.

This sequence demonstrates an adaptive yet fragmented institutional cycle, as the administration was forced to continuously modify its operational restrictions because it lacked real-time visibility of human presence on the water.

The Structural Gap: Vessel Tracking VS Crew Visibility

Therefore, the main gap is a structural decoupling of vessel tracking from human tracking. Daily Ship Reporting Forms submitted by ships navigating the Gulf region and satellite-based systems like Long Range Identification and Tracking (LRIT) help monitor physical vessel positions and transit timestamps (Directorate General of Shipping 2024). However, these advanced tracking systems are built to locate vessels and not the seafarers boarding them.

Before departure, recruitment agencies file a Form-1 on the Directorate’s portal, which updates the Bureau of Immigration (BoI) every three hours (Directorate General of Administration, n.d.) alongside manual emails of static crew lists from CSOs to estimate daily crew numbers per vessel. To integrate this process, the government launched the Seafarer Tracking Module on the eNAVIK portal (Directorate General of Maritime Administration 2026a) that uses permanent Indian National Database of Seafarers (INDoS) numbers and Continuous Discharge Certificate (CDC) records assigned to the crew. However, its operational design depends largely on voluntary, manual corporate updates from recruiting agencies, giving the employer total discretion over whom to confirm. The user guide states that companies can skip automated imports, manually add crew later, or unilaterally delete entries under the guise of clerical error, and that system logins exist only for agencies and shipowners, excluding seafarers entirely.

This design could fail against commercial reality as shipping companies often face powerful economic incentives to underreport crew admissions, like avoiding surging war-risk insurance premiums from global P&I clubs or evading administrative penalties for operating in restricted zones. Furthermore, concerning seafarer abandonment, the Directorate has also acknowledged persistent discrepancies between ships listed on official pre-departure Form-1 filings and the actual foreign vessels seafarers board (Directorate General of Shipping 2026b). In an active high-risk maritime zone, such administrative gaps leave the state blind to exposed citizens.

Strengthening The Reliability of Seafarers’ Data

The remaining challenge is ensuring that the information updated in the mechanism remains complete, up to date and actionable, which can be done through three operational measures:

  • Expand Seafarer Self-Reporting:

While the eNAVIK portal currently functions as a reactive grievance redressal module, its existing infrastructure must be expanded to include a proactive ‘High-Risk Check-in Module’. Leveraging seafarer’s INDoS numbers who enter conflict zones (‘Difference between Indos, SID, and CDC | Sea and Beyond’, n.d.) should be empowered to digitally check in, confirming their presence on board using the vessel’s IMO (International Maritime Organisation) number. This data must remain confidential from employers to prevent reprisals, establishing an unalterable, bottom-up validation line that companies cannot alter or suppress.

  • Automated Inter-Agency Data Cross-Verification:

Currently, RPSL agencies file a pre-departure Form-I on the DGMA portal, which pushes data to the BoI every three hours for passport clearance. However, this one way data flow from DGMA to Immigration has no automated return loop that confirms exit logs back to DGMA in order to verify against active eNAVIK lists.

This structural gap also highlights seafarer abandonment where crew members clear airport immigration under Form-I filings for one ship, but are subsequently placed on entirely different foreign vessels abroad (Directorate General of Shipping 2026b). Therefore, a two way Application Programming Interface (API) link should be established between the BoI exit logs and the eNAVIK portal. When an immigration exit log indicates a seafarer departing for maritime transit under a specific IMO number, but does not appear on that ship’s crew list on eNAVIK within 48 hours of the expected joining date, the system should automatically flag a discrepancy on the dashboard.

  • Enforce Statutory Penalties for Non-Compliance:

Under Section 301 of the Merchant Shipping Act, 2025, authorities hold binding powers to issue directions, with non-compliance carrying penalties extending upto five lakh rupees (Ministry of Ports, Shipping and Waterways 2026a). Furthermore, under Sections 281 and 282 governing penalty imposition, appeals and compounding, alongside Rule 11 of the Merchant Shipping (Recruitment and Placement of Seafarers) Rules, 2026, the Directorate must conduct random audits on RPSL agencies, and any minor reporting delays should trigger a financial penalty, while deliberate data suppression to avoid war risk premiums must result in license suspension (Ministry of Ports, Shipping and Waterways 2026b).

Conclusion

India’s response to the West Asia crisis demonstrates a vital shift toward a coordinated and seafarer-centred framework. Accounting for every Indian seafarer cannot rest on trust and manual agency compliance alone. Building on the DGS’s five-part anti-fraud plan which targets document falsification and unauthorized recruitment intermediaries, these digital tracking mechanisms will provide the enforcement backbone needed to prevent corporate underreporting. Thus, transitioning into a verified framework combining expanded seafarer self-reporting, two way automated inter-agency data checks and rigorous statutory enforcement would make India’s tracking architecture a robust mechanism capable of safeguarding its maritime workforce before the next disruption reaches the same scale.

References

Keerthana Rajeev is a Research Intern in the International Relations vertical at CPPR.

Views expressed by the authors are personal and need not reflect or represent the views of the Centre for Public Policy Research (CPPR).

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