Energy supply, agriculture, international trade, defence: when we think about national resilience, there are some obvious start points. 

But fisheries don’t always make the list - and that is a mistake. Fishing might be a relatively small part of the UK economy but it plays a disproportionate role in domestic security, coastal livelihoods and environmental stewardship. 

READ: THE CATCH

It also sits at the junction where domestic regulation meets international supply chains. That makes governance both particularly important and vulnerable. And UK governance currently falls short in implementing the highest standards.

Fragile

ClientEarth analysed the public availability of information about the ultimate beneficiary ownership (UBO) of commercial fishing vessels fishing UK waters, which we have published in a report called 'Whose Boat is This?' 

The findings are sobering. The short story is that, for around three-quarters of the commercial fishing vessels we analysed, the UK government does not publicly identify who really owns those vessels to a clear and satisfactory extent. 

At a time of increasing focus on sovereignty, the UK cannot fully account for who is exploiting its marine resources. This creates the potential for commercial vessel owners to operate through complex corporate structures and hide behind shell companies, masking UBO. It would be wrong to dismiss this opacity as a technical detail, for three important reasons.

Domestic security. The geopolitical environment is more unstable than it has been for some time. Wars continue to cause economic stress, and global relations between states are unpredictable and unsettled.

One of the effects is that supply chains that may once have been considered more dependable are now potentially fragile. Clarity about who controls key parts of the food system matters.

Over-exploitation

Because we cannot readily trace clear ownership arrangements of commercial vessels fishing our waters, we are limiting our control and increasing exposure to economic and public safety risks. It is unclear whether regulators can say with confidence who is profiting from access to UK waters and it is difficult or impossible for the public to find out. 

As a result, the UK public interest in the relationship between the financial flows associated with UK commercial fishing activities and the UK economy is undercut.

Opaque ownership can also make it harder to identify links to illicit finance or sanctions evasion: the UK cannot rule outlinks to organised crime, sanctioned entities, or hostile actors.

Enforcement. Rules ultimately depend on their ability to be enforced. And they can only be enforced if the authorities know who should be held responsible and accountable.

Illegal, unreported and unregulated (IUU) fishing has been recognised internationally as a major driver of stock depletion and ecosystem damage. In UK waters, fish stocks are already under pressure from climate change and historic commercial over-exploitation. 

Transparency

Allowing anonymity to persist makes that problem harder to address.Where ownership cannot be identified, effective sanctions become difficult, or even impossible, to apply in practice. As a result, repeat offenders can evade scrutiny. None of this is unique to the UK, but the UK has the regulatory capacity to do better.

Our fishing industry. Unknown actors who operate in UK waters have the potential to undercut responsible operators by avoiding labour standards, safety requirements and compliance costs. That exposes workers to exploitation with limited avenues for redress, as well as distorting competition.

Undeterred IUU fishing also weakens the integrity of seafood markets, reducing confidence in quality and sustainability claims.

The good news is that the UK already has a fundamental regulatory framework in place that, with some straightforward improvements, could do much more to crack down on IUU fishing through greater UBO transparency.

Accountability

The authorities should require disclosure of UBO information at commercial vessel registration and licensing stages, and that information should be publicly accessible. 

The enforcement of company disclosure requirements must also be strengthened Importantly, the UK should close the loopholes that currently allow anonymity to persist, by restricting access to UK waters for commercial vessels with opaque ownership.

Regulation works best when it is coherent and predictable. At present, the lack of transparency in fisheries ownership sits uneasily with the UK’s wider approach to governance, and with its stated commitment to tackling illegal fishing internationally.

This is about ensuring access to a public resource comes with accountability. In a system governed by law, that should be an uncontroversial proposition.

This Author

Kyle Lischak is the head of ClientEarth UK.