Skippered rental: what the law requires

Bareboat or skippered: two regimes

Information article, based on the official texts consulted on 26 September 2026. It replaces neither legal advice nor the opinion of the competent State services for your case.

Sources: decree 84-810, art. 1, II, French Transport Code (code des transports), art. L5423-8 and L5423-10. An NUC makes tourist or sporting trips, never a regular line service, with at most 12 passengers on a motor boat and 30 on a sailing boat.

What the boat must have

• A permis d’armement (manning permit), mandatory for any vessel in professional use (French Transport Code, art. L5232-1); it replaced the former rôle d’équipage (crew list).
• An approval and a navigation permit, issued by a ship safety centre (French Ministry of the Sea); in the Mediterranean, those in Marseille and Sète (DIRM Méditerranée).
• The Division 241 rules: since June 2026, an “NUC” label in white on a red background at least 20 cm high, the home port entered on the navigation permit, a number of passengers set by the authority (Division 241, 2026 update).

What the skipper must have

No one may work on board a vessel manned for professional pleasure boating without the required qualifications (decree 2015-723, art. 3). Pleasure boating licences, coastal (côtier) or offshore (hauturier), do not give the right to navigate professionally (French Ministry of the Sea).

The certificate required depends on the boat and the area: check it in the annex to decree 2015-723 or with the ship safety centre.

Employee or contractor: the skipper’s status

The French Transport Code counts among seafarers the people at sea, “employed or self-employed”, who operate the vessel (art. L5511-1). The ENIM (the French seafarers’ social security scheme) flowchart distinguishes (ENIM):

• the employed skipper, under a maritime employment contract (contrat d’engagement maritime), declared by the shipowner;
• the self-employed skipper providing a service, who registers themselves — the ENIM states that micro-entreprise status is incompatible with its scheme;
• holders of the small certificates, who fall under the general social security scheme.

A skipper provided separately on a boat rented bareboat is an arrangement that none of the texts consulted settles: have it validated by the ship safety centre and the ENIM before offering it.

The risk if you get it wrong

Taking passengers on board for payment on a boat that is not an NUC, or without a certificate of command, “is a serious offence of illegally exercising command and may be reclassified as undeclared work” (French Ministry of the Sea). On the insurance side, the mandatory insurance for passenger carriers only covers vessels authorised to carry more than 12 passengers and contracts of carriage (2021 DGTIM note): check with your insurer that skippered rental is actually covered.

“Disguised skippering”, and the new Division 241

The nautical press calls the most common case “disguised skippering”: an owner who rents out their boat and acts as skipper without the boat being an NUC (commercially used pleasure vessel) or the owner a professional seafarer. Carrying passengers for payment in these conditions “is a serious offence of illegally exercising command and may be requalified as undeclared work” (Figaro Nautisme, 2019 investigation).

Division 241, which governs NUCs, was entirely rewritten by the arrêté (ministerial order) of 21 May 2026 (Journal officiel of 6 June 2026): every approved vessel receives an “NUC” label displayed visibly on its hull (art. 241-1.06), the division no longer refers to Division 245, and it incorporates the maximum number of passengers (French Ministry of the Sea). The permis d’armement (manning permit) remains the navigation document for professional vessels; the rôle d’équipage (crew list) disappeared with the law of 20 June 2016 (French Ministry of the Sea).

In SunSea Hub

The staff directory tracks skippers, their qualifications and their expiry dates; an independent skipper’s contract is signed electronically and stays attached to their record. See Fleet.

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