EU action to combat illegal fishing : control systems in place but weakened by uneven checks and sanctions by Member States. Special report 20, 2022.
Date: 2022-12-01
Institutions: European Court of Auditors
Subjects: EU restrictive measure, catch quota, common fisheries policy, conservation of fish stocks, fight against crime, fishing regulations, illegal fishing, illicit trade, report, sea fishing, sustainable fisheries

EN 

2022 

20 

Special report  EU action to combat illegal fishing 

Control systems in place but weakened by uneven 
checks and sanctions by Member States 

 
 
 
Contents 

Executive summary 

Introduction 

Illegal, unreported and unregulated fishing 

Global response to illegal, unreported and unregulated fishing 

EU framework for combating illegal, unreported and unregulated 
fishing 

Legality does not guarantee sustainability 

Audit scope and approach 

Observations 

Import control system has reduced the risks of illegal fish on EU 
market but Member States’ checks are uneven 

EU catch certification scheme improved traceability and reinforced import 
control 

Significant differences in scope and quality of checks by Member States 
weaken the system 

EU catch certification scheme is paper-based, which reduces efficiency and 
increases risk of fraud 

EU carding system has proven useful, but often impacts countries with only 
minimal EU fish trade and loopholes exist 

Member States detected illegal fishing by national fleets and in 
national waters but sanctions are not always dissuasive 

Member State checks on national fleets and waters detected illegal fishing 

The Commission identified significant weaknesses in national control 
systems and has started to address them 

EU-funded projects helped reinforce control system 

Sanctions imposed by Member States vary and are not always dissuasive 

Conclusions and recommendations 

92-103 

2 

Paragraph 

I-V 

01-23 

04-06 

07-10 

11-20 

21-23 

24-26 

27-91 

28-63 

28-34 

35-45 

46-49 

50-63 

64-91 

64-69 

70-74 

75-83 

84-91 

 
 
3 

Annexes 

Annex I – International instruments to combat illegal, unreported 
and unregulated fishing 

Annex II – Benchmarking of EU catch certification scheme with 
similar systems in USA and Japan 

Abbreviations 

Glossary 

Replies of the Commission 

Timeline 

Audit team 

 
 
 
 
4 

Executive summary 

I Illegal, unreported and unregulated fishing (“illegal fishing”) is one of the greatest 
threats to marine ecosystems, undermining efforts to manage fisheries sustainably. 
The EU is a major global player in fisheries, both in terms of its fishing fleet (with 
around 79 000 vessels) and as the world’s largest importer of fishery products (34 % of 
total world trade in value). The EU has been committed to achieving Sustainable 
Development Goal target 14.4 to end illegal, unreported and unregulated fishing 
by 2020. This target has not been met, unsustainable fishing persists and there is a risk 
that products derived from illegal, unreported and unregulated fishing are sold on the 
EU market. 

II We examined the EU framework, action and spending aimed at preventing 
products of illegal, unreported and unregulated fishing from ending up on EU citizens’ 
plates. The European Parliament asked the ECA to report on this issue in 2018 
and 2021. With this report, we aim to contribute to policy discussions and legal 
developments regarding the fight against illegal fishing. The audit covered the period 
from 2014 to 2020. We focused on: 

o 

o 

the effectiveness of control systems for preventing the import of illegal fishery 
products ; 

the effectiveness of Member States’ control systems for checking national fleets 
and waters. 

III Overall, we conclude that the control systems in place to combat illegal fishing are 
partially effective; although they mitigate the risk, their effectiveness is reduced by the 
uneven application of checks and sanctions by Member States. 

IV Our main findings are as follows: 

(a)  The EU set up a catch certification scheme in 2008 to guarantee the legality of 

imported fishery products. However, ensuring the legality of a product does not 
guarantee that it is sustainably sourced. We found that the scheme had improved 
traceability and reinforced import control. Nonetheless, differences in the scope 
and quality of checks in Member States risk undermining the scheme’s 
effectiveness. The lack of digitalisation of the scheme reduces efficiency and 
increases the risk of fraud. 

 
 
5 

(b)  When the Commission and Council consider that the control systems in place in 

non-EU countries exporting fishery products to the EU are deficient, they can take 
action to encourage reform. We found that these actions had proven useful and 
triggered positive reform in most of the countries concerned. 

(c)  Member States are responsible for the correct application of the EU fisheries 

control system. We found that national checks often detected instances of illegal 
fishing. However, the Commission has identified significant shortcomings in 
fisheries control systems in some Member States, leading to overfishing and 
underreporting of catches. It is taking steps to address these shortcomings.  

(d)  The European maritime and fisheries fund provided support for monitoring, 

control and enforcement activities, with a total budget of €580 million. We found 
that the 23 projects we audited in four Member States were in line with priorities 
and helped reinforce the control system. 

(e)  The EU framework requires Member States to impose effective, proportionate 

and dissuasive sanctions for all serious infringements of the rules. While the vast 
majority of serious infringements detected led to sanctions, these varied 
considerably across Member States for similar infringements. In some Member 
States, sanctions were neither proportionate to the economic benefit derived 
from the infringements, nor dissuasive. 

V Based on these findings, we recommend that the Commission: 

o  monitor that Member States reinforce their control systems for preventing the 

import of illegal fishery products, and take necessary action; and 

o 

ensure that Member States apply dissuasive sanctions against illegal fishing. 

 
 
 
6 

Introduction 

01 The EU is a major global player in fisheries. It has one of the world’s largest 
fishing fleets, with around 79 000 vessels1, and accounts for 6 % of worldwide fisheries 
production from catches2. The fishing sector employs 129 540 fishers directly and 
generates an annual €6.3 billion in revenue. The Member States leading the market in 
terms of volume are Spain, Denmark, France and the Netherlands3. 

02 The EU consumes far more fishery products than it catches or farms, importing 
60 % of products consumed to satisfy demand. This makes it the world’s largest 
importer of fishery products (34 % of total world trade in value)4. 

03 In 2020, the EU imported €23 billion of fishery products. Figure 1 shows its main 
suppliers. 

1  Synopsis Report of data provided by Member States. 

2  Fisheries and aquaculture production. 

3  Eurostat Fishery Statistics. 

4  The State of the World Fisheries and Aquaculture 2020. 

 
 
                                                      
Figure 1 – Imports of fishery and aquaculture products: main suppliers 
(percentage of total volume 2020) 

7 

Greenland
2.8 %

Faroes
2.1 %

Iceland
4.0 %

Norway
26.4 %

United Kingdom
5.9 %

Russia
2.9 %

EU-27

Morocco
4.9 %

Turkey
2.0 %

China
8.0 %

India
2.3 %

Vietnam
3.4 %

United States
4.1 %

Ecuador
5.2 %

Peru
2.0 %

Argentina
2.2 %

>1 000 000 tonnes

1 000 000 – 200 000 tonnes

<200 000 tonnes

Source: ECA, based on Eurostat data. 

Illegal, unreported and unregulated fishing 

04 Illegal, unreported and unregulated fishing (“IUU fishing”), hereafter “illegal 
fishing”, encompasses a variety of fishing activities5 that contravene national and 
regional conservation and management measures and are inconsistent with flag state 
responsibilities under international law. Fishing activities are considered: 

o 

o 

o 

illegal when they are conducted without a licence or authorisation, against 
conservation and management measures, or against national laws/ international 
obligations; 

unreported when they are not reported or misreported to the relevant 
authorities; 

unregulated when they are conducted in areas with no applicable conservation 
and management measures and conducted in a manner inconsistent with State 

5  For full definition, see the International Plan of Action to Prevent, Deter and Eliminate 
Illegal, Unreported and Unregulated Fishing and FAO Port State Measures Agreement. 

 
 
 
                                                      
8 

responsibilities for the conservation of living marine resources, or when the 
fishing vessel has no nationality. 

05 The Food and Agriculture Organization (FAO) estimates that around 94 % of
global fish stocks are fully exploited or overexploited6 (see Figure 2). Illegal, 
unreported and unregulated fishing depletes fish stocks, posing one of the greatest 
threats to marine ecosystems, undermining efforts to manage fisheries sustainably7 
and pushing some to the brink of collapse8. 

Figure 2 – Exploitation of fish stocks 

6.2 %

fished below capacity

34.2 %

of fish stocks overfished

59.6 %

fished to capacity

Note: These percentages treat all fish stocks equally regardless of their biomass and catch. 

Source: ECA, based on FAO data. 

6  The State of World Fisheries and Aquaculture 2020. 

7  FAO website on illegal, unreported and unregulated fishing. 

8  One Ocean Summit: new steps strengthen EU leadership in protecting the Ocean. 

9 

06 While it is difficult to determine the exact extent of illegal, unreported and 
unregulated fishing, a study on this subject9 estimated it at 10 to 26 million tonnes 
worldwide in the early 2000s, i.e. 11 to 19 % of reported catches, worth $10 to 
$23 billion. 

Global response to illegal, unreported and unregulated fishing 

07 From net to plate, fishery products can be caught, transhipped, landed, stored, 
processed, transported and sold along highly complex, globalised supply chains. 
Combating illegal fishing therefore requires a global response from all involved, 
including sovereign nations in their capacity as flag, coastal, port and market states 
(see Figure 3). 

Figure 3 – Responsibilities of flag, coastal, port and market states 

All sovereign states can grant their flag to a fishing vessel as 
long as there is a genuine link between that vessel and the 
flag state. Flag states must exercise effective jurisdiction and 
control over all vessels flying their flag, wherever they 
operate.

Coastal states must exercise jurisdiction over all fishing 
activities in their exclusive economic zone (EEZ). Coastal 
states have primary responsibility for adopting and enforcing 
conservation and management measures in their exclusive 
economic zone.

Port states should impose conditions for the entry of 
foreign-flagged vessels into their ports and conduct 
inspections, to ensure that vessels engaged in illegal, 
unreported and unregulated fishing activities cannot land 
their catches.

Market states should ensure that imported products are not 
derived from illegal, unreported and unregulated fishing and 
ensure transparency of the marketing and trade of fisheries 
products, in line with fisheries conservation and 
management measures.

Flag state

Coastal state

Port state

Market state

Source: ECA.  

9  Estimating the Worldwide Extent of Illegal Fishing, David J. et al, 2009. 

 
 
 
                                                      
10 

08 The UN and the FAO have each developed and adopted a range of legally binding 
instruments, plans of action and voluntary guidelines. These provide an international 
framework for responsible fisheries and the fight against illegal, unreported and 
unregulated fishing. These are set out in Annex I. 

09 Regional Fisheries Management Organisations are key stakeholders in 
international fisheries management. They comprise countries with fishing interests in a 
given area and are responsible for the joint management of straddling and highly 
migratory fish stocks. Most of these organisations are empowered to set binding catch 
and fishing effort limits, technical measures and control obligations for their members. 
The EU is party to all major international instruments and a member of 18 Regional 
Fisheries Management Organisations and fisheries bodies10. 

10 The fight against illegal, unreported and unregulated fishing falls within the 
Sustainable Development Goals set by the UN General Assembly in 201511. Sustainable 
Development Goal 14, ‘Life below water’, set an ambitious target for sustainable 
fishing (14.4): ‘By 2020, effectively regulate harvesting, and end overfishing, illegal, 
unreported and unregulated fishing and destructive fishing practices (…)’. The EU has 
been committed to achieving this target to end illegal fishing by 202012. This target has 
not been met13, unsustainable fishing persists14 and there is still a risk that products 
derived from illegal, unreported and unregulated fishing (hereafter “illegal fishery 
products”) are sold on the EU market. 

EU framework for combating illegal, unreported and 
unregulated fishing 

11 Fisheries policy is an exclusive competence of the EU, meaning that only the EU 
can legislate and adopt binding acts on the conservation of marine biological resources 
under the common fisheries policy. This policy sets the rules for the management of 
the European fishing fleet and the conservation of fish stocks. For example, EU rules 

10  Regional Fisheries Management Organisations. 

11  United Nations Sustainable Development Goals. 

12  Joint Communication: 'International ocean governance: an agenda for the future of our 

oceans'. 

13  Europe Sustainable Development Report 2021. 

14  Status of marine fish and shellfish stocks in European seas. 

 
 
                                                      
11 

set quotas and minimum fish sizes for certain fisheries. The EU also regulates fishing 
gear and can prohibit fishing in certain areas or seasons. 

12 An important component of EU fisheries policy is the common market 
organisation regulation. This sets EU marketing standards for fishery products and 
consumer information requirements (labelling) to allow consumers to make informed 
purchasing choices. For example, the label must indicate the commercial designation, 
the production method, the catch area and the fishing gear. There is no EU label 
certifying the sustainability of fishery products. 

13 Under the common fisheries policy, the EU has adopted the following main 
regulatory instruments and allocated funding to combat illegal, unreported and 
unregulated fishing. 

EU regulatory framework 

14 The Illegal, unreported and unregulated fishing regulation (mainly concerning 
imports) and fisheries control regulation (mainly focusing on compliance by EU fishers) 
are the main regulatory instruments for combating illegal fishing. 

15 The illegal, unreported and unregulated fishing regulation is the main EU 
instrument for preventing, deterring and eliminating such fishing. It requires Member 
States to take action against fishing vessels and EU nationals engaged in illegal fishing 
activities anywhere in the world. The two most prominent features of this regulation 
are the catch certification scheme and the carding system. The first aims to ensure the 
legality of imports and the second identifies ‘third countries’ (non-EU countries) that 
are not cooperating in the fight against illegal fishing. 

16 The fisheries control regulation focuses on EU fleet activities, establishing an 
EU-wide control system for ensuring compliance with the common fisheries policy. It 
applies to all fishing activities in EU waters and all those carried out elsewhere by EU 
vessels. It is complemented by the regulation on the sustainable management of the 
external fishing fleet. This regulation focuses on the control of third-country fishing 
vessels operating in EU waters and EU vessels fishing elsewhere. 

17 The control regulation contains provisions for Member States and operators, with 
the objective of preventing and combating illegal fishing. These include: 

o  monitoring access to waters and to resources; 

 
 
12 

o 

o 

o 

controlling the use of fishing opportunities and capacity; 

ensuring appropriate enforcement measures in the event of infringements; 

enabling the traceability and control of fisheries products throughout the supply 
chain, from net to plate. 

18 In April 2017, the European Commission published its evaluation of the fisheries 
control regulation15, concluding that the effectiveness of the control system was 
hindered by shortcomings in the design of the regulation. The Commission proposed a 
number of amendments to the control regulation in its proposal on the revision of the 
EU fisheries control system of 31 May 201816. The proposal had not been adopted by 
May 2022. 

Use of EU funds 

19 The EU provides funding to support fisheries control. The European maritime and 
fisheries fund (EMFF) financed EU maritime and fisheries policies for 2014-2020. Under 
European Union Priority 3, ‘Fostering the implementation of the common fisheries 
policy’, the fund supported monitoring, control and enforcement activities with a total 
budget of €580 million. Its successor, the European maritime, fisheries and 
aquaculture fund, will continue to support control measures for 2021-2027. At least 
15 % of the EU financial support per Member State, totalling €797 million, is planned 
to be allocated to fostering efficient fisheries control and enforcement, together with 
reliable data for knowledge-based decision-making. These amounts are complemented 
by national co-financing. 

Roles and responsibilities 

20 The Commission’s Directorate-General for Maritime Affairs (DG MARE) is the 
main body responsible for overseeing the common fisheries policy. The European 
Fisheries Control Agency (EFCA) promotes and coordinates the development of 
uniform risk management methodologies, and organises training and coordination/ 
cooperation between national control and inspection authorities. The Member States 
are responsible for implementing key requirements of the common fisheries policy 
such as inspecting vessels, checking imports and applying sanctions. 

15  Commission report on the implementation and evaluation of regulation (EC) 1224/2009. 

16  Proposal for a new control regulation (COM/2018/368 final). 

 
 
                                                      
13 

Legality does not guarantee sustainability 

21 The legal framework described above aims to ensure that all fishery products sold 
in the EU are legal. It should guarantee to EU consumers that the products they 
consume are not derived from illegal, unreported or unregulated fishing. However, 
ensuring the legality of a product does not guarantee that it is sustainably sourced. 

22 For imported products, the EU catch certification scheme aims to ensure that flag 
states certify the legality of all imported fishery products based on their own control 
and monitoring systems. Fishing vessels must comply with the rules imposed by the 
flag state and, when applicable, the competent Regional Fisheries Management 
Organisation or coastal state. The scheme cannot ensure that these rules, adopted 
outside the EU, are sufficiently stringent to guarantee sustainability. For example, even 
when a coastal state does not impose rules to curb overfishing or environmentally 
harmful fishing practices, catches in the area are considered legal. 

23 Similarly, for the activity of the EU fleet, ensuring compliance with EU rules does 
not mean that the rules themselves are sufficient to ensure the sustainability of fish 
stocks and their habitats. The European Environment Agency reported in 2019 that the 
‘overexploitation of commercial fish and shellfish stocks continues across Europe's 
seas’. Our 2020 special report ‘Marine environment: EU protection is wide but not 
deep’17 concluded that EU actions to protect the marine environment had resulted in 
measurable progress in the Atlantic, but the Mediterranean remained significantly 
overfished. 

17  Special report 26/2020, 'Marine environment: EU protection is wide but not deep', see also 

Report on the performance of the EU budget – Status at the end of 2020. 

 
 
 
                                                      
14 

Audit scope and approach 

24 We examined the EU framework for preventing products derived from illegal, 
unreported and unregulated fishing from ending up on EU citizens’ plates. The 
European Parliament asked the ECA to report on this issue in 2018 and 2021. We also 
looked at EU spending and action from 2014 to 2020. We chose this topic because of 
the impact of illegal fishing on the sustainability of marine resources. We focused on 
the effectiveness of:  

— 

the control systems for preventing the import of fishery products derived from 
illegal, unreported and unregulated fishing into the EU, including whether the 
Commission targeted its actions to address key risks and whether Member States 
performed effective checks; 

—  Member States’ control systems for checking national fleets and waters, including 

whether EU funding targeted significant risks and achieved results. 

25 In our audit work, we: 

o 

o 

o 

o 

o 

examined reports by the Commission and relevant agencies, and actions related 
to fisheries control and enforcement; 

interviewed national authorities responsible for fisheries control in Denmark, 
Spain, France and Sweden, selected due to the size of their fishing sector and 
trade flows with third countries, the amount of EU funding they receive for 
control, and geographical balance; 

visited the Swedish authorities responsible for fisheries control, observing the 
work of the Swedish Fishery Monitoring Centre, an inspection at the fish market 
and an in-port vessel inspection. Due to the COVID-19 pandemic travelling 
restrictions, we were only able to visit Sweden on the spot during the timing 
allocated for our audit work; 

compared the scope and main features of the EU catch certification scheme with 
similar systems in the USA and Japan; 

examined 23 EU-funded projects related to fisheries control worth €26.9 million 
implemented over the 2014-2020 programme period. We selected these projects 
to cover a wide variety of expenditure and investments, such as patrol vessels, 
innovative technology and operational costs. 

 
 
26 With this report, we aim to contribute to policy discussions and legal 
developments regarding the fight against illegal, unreported and unregulated fishing. 

15 

 
 
 
16 

Observations 

27 The observations are presented in two main sections. The first covers the import 
control system for fishery products and the second Member States’ control systems for 
checking national fleets and waters. 

Import control system has reduced the risks of illegal fish on EU 
market but Member States’ checks are uneven  

EU catch certification scheme improved traceability and reinforced 
import control 

28 The EU adopted the illegal, unreported and unregulated fisheries regulation 
in 2008, creating the innovative EU catch certification scheme. See Figure 4 for details 
of the scheme. 

 
 
Figure 4 – The catch certification scheme 

1

Fish are caught at sea

17 

2

3

4

Fish are landed in port
Fish can be landed anywhere in 
the world. If they are destined for 
the EU market, the flag state must 
validate the catch certificate.

Fish may be processed
In this case, a processing 
statement must be filled in 
by the processor.

Fishery products are 
exported to an 
EU Member State
Most products arrive in the EU 
on cargo ships.

The national authority 
rejects the import
The fishery products are sent 
back, destroyed or donated.

6

5

The national authority 
accepts the import
The fishery products can be 
sold anywhere in the EU.

National authorities in the 
Member State of destination 
conduct their checks

Source: ECA. 

29 We found that this scheme closed an important control loophole, as the legality
of imported fishery products was not checked prior to its entry into force, with the 
exception of some region-specific rules, which did include a catch documentation 
scheme. Under the scheme, all marine fishery products exported to the EU must be 
accompanied by a catch certificate validated by the flag state of the fishing vessel. The 
certificate enables the traceability of fishery products throughout the supply chain to 
the entry into the EU. It is the responsibility of the flag state to certify that fishery 
products are not derived from illegal, unreported and unregulated fishing activities and 
verify their compliance with applicable conservation and management rules. 

30 We carried out a benchmarking exercise to compare the EU catch certification
scheme with similar systems in the USA and Japan. These are the second and third 

18 

largest importers in the world18. We contrasted the schemes in terms of species 
coverage, information requirements and control mechanisms. 

31 In the USA, the Seafood Import Monitoring Program (SIMP)19 established 
permitting, reporting and recordkeeping procedures for the importation of fishery 
products identified as vulnerable to illegal, unreported and unregulated fishing or 
fraud. This concerns 13 types of seafood and nearly half of all US seafood imports20. 

32 Japan currently has no national catch documentation scheme for imported 
fishery products, although a scheme is pending under a new law to combat illegal, 
unreported, and unregulated fishing. Instead, it relies on Regional Fisheries 
Management Organisations schemes21, to which the EU and USA are also contracting 
parties. The EU recognises these catch documentation schemes for seafood products 
entering its market22. 

33 We found the EU’s catch certification scheme to be the most comprehensive in 
terms of scope, information required, and validation and control processes. 

o 

o 

o 

The EU scheme has the most comprehensive coverage: almost all fishery 
products must be traceable and certified. Contrary to other schemes, the EU 
scheme covers all processed and unprocessed wild-caught marine fish imported 
from third countries into the EU market. 

The EU and US schemes have broad information requirements allowing detailed 
traceability. These schemes collect more detailed information than those set up 
by Regional Fisheries Management Organisations in many cases. 

The EU scheme has the most comprehensive validation and control system. In 
the EU, each consignment must be accompanied by a certificate validated by the 

18  National Fisheries Marine Service, Current fisheries statistics No 2019, Japan FY2019 Trends 

in Fisheries FY2020 Fisheries Policy. 

19  Magnuson-Stevens Fishery Conservation and Management Act; Seafood Import Monitoring 

Program. 

20  SIMP: Report to Congress Efforts to Prevent Seafood Harvested through IUU fishing. 

21  CCSBT, ICCAT and CCAMLR. 

22  Commission regulation (EC) No 1010/2009. 

 
 
                                                      
19 

flag state, and Member State authorities must perform risk-based checks and 
verifications. 

34 Annex II sets out further details of our benchmarking exercise (EU catch 
certification scheme and similar systems in the USA and Japan). 

Significant differences in scope and quality of checks by Member States 
weaken the system 

35 Every two years, Member States must submit a report to the Commission on their 
application of the illegal, unreported and unregulated fishing regulation. The latest 
data available is from 2019 (including data for the United Kingdom), when every 
Member State except Luxembourg submitted a report. The European Fisheries Control 
Agency produced an analysis of the Member States’ reporting, providing an overview 
of the implementation of the regulation by Member States. 

36 According to this analysis, around 2 000 foreign vessels, mainly from Norway, 
Venezuela and the Faroe Islands, landed their catches directly in an EU port in 2019. 
EU port states were required to inspect at least 5 % of landed catches and the average 
inspection rate was around 20 % for the whole of the EU, although Poland and 
Denmark failed to meet the 5 % requirement. Port inspections helped detect 
infringements in 11 % of cases, mostly concerning reporting obligations. 

37 Most imported fishery products are not landed directly from a fishing vessel in an 
EU port. Instead, the products are landed elsewhere in the world and transported to 
the EU on cargo ships. The illegal, unreported and unregulated fishing regulation 
requires checks to take place in the destination Member State rather than at the EU 
entry point. Once accepted, products can be sold anywhere in the EU. Member State 
checks must therefore be robust enough to prevent ‘control shopping’, where 
operators exploit the weakest link in the control system. This risk was highlighted by 
control authorities we interviewed in two Member States and in a 2018 study23. 

38 In 2019, Member State authorities received around 285 000 catch certificates and 
35 000 processing statements from third countries. On the basis of risk management, 

23  The impact of the EU IUU regulation on seafood trade flows. 

 
 
                                                      
20 

the illegal, unreported and unregulated fishing regulation requires Member States to 
check that: 

o 

o 

catch certificates are completed and validated by the flag state (correct signature 
and stamp); 

the flag state is authorised to export to the EU and not identified by the EU as 
non-cooperating in the fight against illegal fishing (‘red-carded’, see 
paragraph 50), and the fishing vessel is not listed as a vessel engaged in illegal 
fishing; 

o 

catch certificates for processed products specify the same species and quantity as 
the processing statement. 

39 Member States may carry out further, more detailed checks (called 
‘verifications’), based on a risk analysis. A verification is required if there is any doubt 
over catch certificate authenticity or vessel compliance with applicable rules, or any 
suspicion of illegal, unreported and unregulated fishing. 

40 The scope of the verifications depends on the control authorities in Member 
States. They may involve cross-checking all documents for consistency (e.g. catch 
certificates, processing statements, transport documents), or seeking evidence from 
external sources (valid vessel licence, authorisation to fish in the reported catch area, 
suspicion of involvement in illegal fishing by vessel owner / beneficial owner, 
consistency between trade patterns and known fishing activities, etc.). A verification 
may also include a physical inspection of the product, for example if there are doubts 
about the species. 

41 Overall, Member States reported having performed either basic or more detailed 
checks on around 64 % of the catch certificates they received. Five Member States 
(Germany, Lithuania, Malta, Portugal and Sweden) reported they had only performed 
the more basic checks, while Belgium, Finland, Italy and Romania did not report any 
information on this matter. 

42 Sometimes the verification raises doubts and Member State authorities must 
request additional information from the flag state to confirm the validity of 
importer-submitted documents. In 2019, there were more than 1 000 instances of this 
across 19 Member States. Four Member States (Hungary, Romania, Sweden and 
Slovakia) did not request additional information from any third countries 
between 2016 and 2019. 

 
 
21 

43 The illegal, unreported, and unregulated fishing regulation requires Member 
States to reject imports if they do not receive pertinent answers to their questions. 
Austria, France and Poland reported in their biennial reports that while some third 
countries answered their request fully, others simply confirmed the validity of the 
certificate and declined to provide additional documentation. 

44 In 2019, authorities in ten Member States rejected 29 imports (less than 0.01 % 
of all catch certificates received that year), mainly due to the absence of a valid catch 
certificate or inconsistencies between the document and products. In most cases, the 
products were sent back to the exporting country. 

45 Our analysis of the control systems for imported products in Denmark, Spain, 
France and Sweden confirmed that the scope and quality of checks varied significantly 
between Member States, as did the degree of sophistication of IT systems (see 
Table 1). We rank these as low, medium, and high. 

Table 1 – Import checks and verifications by four Member States 

Member 
State 
Denmark 

Level of IT sophistication 

Scope and quality of checks 

LOW 

MEDIUM 

•  no IT system for managing catch 

•  systematic basic check on all incoming catch 

certificates or performing 
checks 

•  all documents received in paper 
form, scanned and recorded in 
Excel spreadsheet 

certificates, excepting two ‘low risk’ third countries 
(only a quarter of imports checked) 
for all checked documents, comparison of information 
coherence and consistency 

• 

•  check on vessel authorisation when import of species 

and area covered by an Regional Fisheries Management 
Organisation 
frequent physical inspections 

• 
•  catch certificates with errors and imports from yellow-
carded countries subject to in-depth verification (may 
involve contacting flag state authorities) 

•  checks of importers 
•  no access to customs system 

 
 
22 

Member 
State 

Spain 

Level of IT sophistication 

Scope and quality of checks 

HIGH 

•  dedicated web platform for 
importers to input data and 
attach scanned documents 
•  automated checks and risk 
analysis using multiple risk 
parameters 

•  integration of systems for 

customs and 
management/control of illegal 
fishing 

HIGH 

• 
• 

systematic basic check on all incoming catch certificates 
systematic check on document completeness and 
coherence 

•  catch certificates with errors sent for in-depth 

second-level checks by specialised illegal fishing 
investigation unit 
frequent requests to importers and flag state 

• 
•  physical inspections possible 
•  cooperation with customs 

France 

MEDIUM 

HIGH 

•  use of customs system, no 
specific capability for catch 
certificates 

•  automated risk analysis selects 
catch certificates for in-depth 
verification based on import 
declaration 

•  scanned copies stored on 

servers, no central database, 
checks documented in system 
MEDIUM 

•  dedicated web platform for 
importers to input data and 
attach scanned documents 
•  no risk analysis or automated 

check but authority can 
document checks and validate 
certificates in system 

systematic basic check on all incoming catch certificates 

• 
•  completeness check 
•  discrepancies/ high risk trigger in-depth checks by 

specialist 

•  occasional physical inspections (including DNA analysis) 
• 

frequent verification requests to flag state 

LOW 
•  no check on catch certificates from one ‘low-risk’ third 
country (representing more than 80 % of imports) 

•  check on sample of catch certificates from other 

countries 

•  only basic checks performed 
•  no access to customs database, no checks of importers 
•  no physical inspections 
•  no in-depth checks, no verification with flag state 

Sweden 

Source: ECA. 

EU catch certification scheme is paper-based, which reduces efficiency 
and increases risk of fraud 

46 The EU catch certification scheme is still paper-based. While some third countries 
(Norway, the USA and the UK) validate and transmit electronic catch certificates, 
importers from other countries send scanned copies of documents to the Member 
State authorities. 

 
 
23 

47 There is no EU-wide database of catch certificates received by Member States, 
and information in one Member State is not available to the others. The lack of 
digitalisation and systematic information-sharing between Member States poses 
multiple challenges to the efficiency and effectiveness of the control system: 

o 

o 

o 

Slower processing time and administrative burden: Member State authorities 
must collect, process, and store all catch certificates and processing statements in 
paper form. In 2019, this represented over 300 000 documents. However, 
Germany, Spain, Finland, the Netherlands and Sweden24 have developed their 
own IT systems requiring importers to input all relevant data and attach a 
scanned copy of the documents, reducing the burden on the administration and 
the processing time for the importer. 

Fraud risk: Paper documents stamped and signed by third countries are more 
easily forged than digitally signed documents. The lack of information-sharing 
across the EU means that duplicate certificates may be fraudulently submitted in 
multiple Member States. 

Lost opportunity to automate control and cross-checks: A single database would 
allow data mining and automated alerts by cross-checking all data submitted in all 
Member States in real time. While some Member States have developed 
sophisticated IT systems with automated checks25, others are still working 
without any IT tools. 

48 To address these shortcomings, Member States repeatedly asked the Commission 
to establish an EU-wide IT system to track catch certificates and facilitate verification. 
The Commission therefore developed its ‘CATCH’ tool to help Member States detect 
fraud and abuse of the paper-based system while simplifying and speeding up checks 
and verifications. 

49 The CATCH system became available in 2019, but no Member State uses it. The 
authorities in the four Member States covered in this audit explained that they did not 
see the need or added value unless all Member States used CATCH. The Commission 
proposal amending the fisheries control regulation intends to make CATCH mandatory 
in the EU. 

24  Client Earth, Digitising the control of fishery product imports. 

25  Client Earth, Digitising the control of fishery product imports. 

 
 
                                                      
24 

EU carding system has proven useful, but often impacts countries with 
only minimal EU fish trade and loopholes exist 

50 The catch certificate scheme relies on third countries to operate effective control 
systems when certifying catches from fishing vessels flying their flag. When a flag 
state’s control system is deficient in key aspects, validated catch certificates do not 
guarantee the legality of products exported to the EU. The identification of non-
cooperating third countries, commonly known as a “red card” under the “carding 
system” is therefore essential to prevent this. The functioning of the carding system is 
presented in Figure 5. 

Figure 5 – The carding system 

If the Commission believes a third 
country may not be meeting its 
responsibilities in the fight against illegal 
fishing, it engages in informal dialogue to 
gain a more comprehensive evaluation 
and promote cooperation.

Administrative 
cooperation procedure

If shortcomings are rectified, the 
Commission lifts the yellow card, or 
proposes to the Council that it 
remove the country from the list of 
non-cooperating countries.

End of pre-identification or 
de-listing (card lifted)

Risk analysis 
The Commission carries out an 
ongoing analysis of the actions 
each third country is taking to 
fight illegal fishing. 

Source: ECA. 

Pre-identification 
(yellow card) 
If cooperation is not fruitful and 
there is enough evidence of 
important shortcomings, the 
Commission notifies the country 
that it risks being identified as a 
“non-cooperating third country”.

Identification (red card)
In case of insufficient progress, 
the Commission identifies the 
country as  non-cooperating in 
the fight against illegal fishing. 

51 The Commission developed a step-by-step methodology for its administrative 
cooperation with third countries and the procedure for identifying non-cooperating 
third countries under the illegal, unreported and unregulated fishing regulation. We 
reviewed the methodology in place to check whether the Commission focused on the 
right risks and based its decision on transparent and objective criteria. 

52 The Commission gathers information on third country action against illegal fishing 
from a wide range of sources. These include Member States, the FAO, Regional 

 
 
 
25 

Fisheries Management Organisations and non-governmental organisations. If there are 
indications that a third country may not be complying with international fisheries laws 
or its responsibilities as a flag, coastal, port or processing state, the Commission may 
decide to engage in administrative cooperation with that country in order to perform a 
more comprehensive evaluation. 

53 The Commission evaluates the country’s compliance based on a questionnaire 
sent to the country’s authorities, in most cases a European Fisheries Control Agency 
analysis of a sample of catch certificates and processing statements from that country, 
and, in agreement with the national authorities, (an) on-the-spot evaluation(s). 

54 If the Commission detects serious problems, it can support the country via 
capacity-building seminars or guidance to improve the national system. In most cases, 
the country undertakes the necessary reforms and improvements and there is no need 
to issue a formal warning. If there is enough evidence of significant shortcomings and 
the informal dialogue does not yield results, the Commission notifies the country that 
it risks being identified as a ‘non-cooperating third country’ (“yellow card”). 

55 The Commission notifies the third country with a pre-identification decision, 
setting out its reasoning (see Figure 6) based on criteria established in the regulation. 
This decision is accompanied by an action plan. It proposes measures to remedy the 
problems detected, with an initial (extendable) deadline of six months. During this 
period, the Commission continues to cooperate with the country and provide technical 
assistance. 

 
 
26 

Figure 6 – Main shortcomings identified by the Commission in carded 
countries 

• National legal framework not in line with international obligations 

• No national plan of action on illegal, unreported and unregulated 

National legal framework

fishing

Regional and multilateral 
cooperation

Fisheries management and 
conservation

• No comprehensive and effective sanctioning system 

• No provisions for the control of nationals in legislation

• No ratification of key international instruments

• No compliance with Regional Fisheries Management 

Organisations rules

• Presence of vessels on illegal fishing lists

•

•

•

•

Lack of effective monitoring, control, and surveillance system 

Shortcomings in the vessels’ registration, licensing, and 
authorisations (flag of convenience)

Lack of transposition, compliance and/or implementation of 
conservation and management measures

Inefficient controls and verifications before validating catch 
certificates and processing statements

Catch certification scheme 
and traceability

• Unreliable traceability procedures

Source: ECA, based on Commission information. 

56 While pre-identification does not involve any sanctions, the warning is generally 
sufficient to spark relevant reforms. Since launching the carding system, the 
Commission has issued yellow cards to 27 third countries. Fourteen yellow cards were 
lifted after one to four years following significant reforms in the countries concerned. 
We found evidence that the yellow card and ensuing cooperation led to positive 
changes (see Box 1). 

 
 
 
 
27 

Box 1 – Positive changes in Thailand following EU warning 

Thailand is a major hub for tuna processing, with a significant fishing fleet. 

In 2011, a Commission evaluation highlighted several weaknesses concerning the 
validation of catch certificates and processing statements in Thailand, together 
with an inadequate control system and legal framework. 

The ensuing cooperation with Thailand did not lead to significant progress and 
in 2015 the Commission issued a ‘yellow card’. 

The Thai authorities then: 

o 

o 

o 

adopted new fisheries laws and regulations in line with international best 
practice; 

imposed criminal sanctions in the most serious cases of illegal, unreported 
and unregulated fishing; 

set up a new control system and improved traceability of landings and 
processing. 

As a result, the yellow card was lifted in 2019. The Commission and the Thai 
authorities created a working group to promote continuous dialogue. 

57 Some countries that have been carded in the past are important trading partners 
with substantial exports to the EU (e.g. Thailand, Ecuador and Vietnam). Many others 
are not. The volume of fishery product trade between the EU and 14 of the 
27 countries is minimal to non-existent (see Figure 7). Some have not informed the 
Commission which body is their certifying authority and thus are not authorised to 
trade fishery products. Thus, there appears to be little risk of fish products from illegal, 
unreported and unregulated activities entering the EU market from these countries. 

 
 
Figure 7 – Trade volume with carded countries (in thousand tonnes) 

2
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Current status
(March 2022)

card lifted 

yellow-carded

red-carded

Note: Trade volume in tonnes for the year preceding the carding decision. Data provided in this Figure 
does not take into account indirect trade in fishery products from carded countries’ vessels, supplied to 
other third countries before being exported to the EU. 

Source: ECA, based on Eurostat data. 

58 The Commission justifies the focus on countries whose EU fish trade is minimal by 
the fact that they act as a ‘flag of convenience’ (see Box 2). There are multiple 
interactions between operators and competent authorities in flag, coastal, port and 
market states throughout the supply chain. Failure by these countries to meet their 
obligations therefore poses a risk of illegal, unreported and unregulated fishing 
activities and compromises traceability, which could result in products derived from 
illegal fishing being imported into the EU market. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
29 

Box 2 – Flags of convenience and illegal, unreported and unregulated 
fishing 

In its 2020 report ‘Off the Hook’26, the Environmental Justice Foundation exposes 
the lack of transparency in the global fishing sector as a key enabler of illegal, 
unreported and unregulated fishing. 

The term ‘flag of convenience’ refers to the granting of a country’s flag to foreign 
vessels for monetary gain. Flags of convenience fail to ensure that there is a 
genuine link between the vessel ownership and control and the flag country. They 
enable operators to conceal their identities and avoid sanctions when engaging in 
illegal, unreported and unregulated fishing, often by changing flags (‘flag 
hopping’). 

When these countries also fail to monitor the activities of the fishing fleet flying 
their flag, their inadequate control systems may attract operators engaged in 
illegal, unreported and unregulated fishing. 

In total, 13 countries given a yellow or red card by the Commission were listed by 
the Foundation as offering flags of convenience. 

59 In the absence of sufficient efforts by the national authorities to rectify the 
problems detected, the Commission may identify the country as a ‘non-cooperating 
third country’ (“red card”). A red card means that Member States must reject all 
imports of fishery products from that country’s vessels. Following identification, the 
Commission proposes an implementing decision to the Council listing the country as 
‘non-cooperating’. This triggers further restrictive measures once adopted, banning EU 
vessels from fishing in the waters of the listed country and denouncing existing 
fisheries partnerships. 

60 There is no international legal basis to prevent the reflagging of a fishing vessel, 
nor to prevent third country vessels from operating in the exclusive economic zone of 
carded countries. Therefore, a loophole limiting the economic impact of red cards is 
that vessels flagged by a ‘non-cooperating’ flag state can nonetheless reflag elsewhere, 
and third-country vessels can still operate in that country’s exclusive economic zone. In 
both cases, their certified catches can be legally exported to the EU. 

26  Off the hook - How flags of convenience let illegal fishing go unpunished. 

 
 
                                                      
30 

61 Of the 27 procedures initiated since 2012, six resulted in a red card (see example 
in Box 3). Three of these countries have since been delisted. 

Box 3 – EU measures taken against Comoros 

Comoros boasts a vast exclusive economic zone in a tuna-rich area. In 2006, the EU 
and Comoros signed a fisheries partnership agreement allowing EU vessels to fish 
in Comorian waters. 

Comoros was issued a yellow card in 2015, followed by a red card in 2017. The 
main reason was an inability to meet its flag state responsibilities. 

o 

o 

The national authorities did not exercise control over the activities of the 
Comorian fishing fleet. They had no information on location, catches, 
landings or transhipments outside their waters. 

The Regional Fisheries Management Organisations repeatedly identified 
compliance issues and evidence of illegal fishing activities concerning 
Comorian vessels between 2010 and 2015. 

o  Despite this, Comoros did not sanction the vessels involved and its legal 
framework did not explicitly define illegal, unreported and unregulated 
fishing or provide for enforcement measures and sanctions. 

o  National authorities had delegated the management of the fishing fleet 

register to multiple representatives around the world, which offered an ‘open 
registry’ or flag of convenience. 

Until the Council listing is removed and the red card lifted, imports of fishery 
products from Comorian-flagged vessels are banned, and EU vessels cannot fish in 
Comorian waters. 

62 The Commission can propose that the Council delist a red-carded country when 
the main shortcomings identified have been resolved and there is a political 
commitment to sustain efforts in combating illegal fishing and complying with 
international law. 

63 After a yellow or a red card has been lifted, the Commission continues to 
cooperate with the country and identify any backsliding as it arises. In Panama and 
Ghana, for example, the Commission followed up after lifting the yellow card and 
found reduced efforts to combat illegal, unreported and unregulated fishing. These 
two countries were pre-identified for a second time. 

 
 
31 

Member States detected illegal fishing by national fleets and in 
national waters but sanctions are not always dissuasive  

Member State checks on national fleets and waters detected illegal 
fishing 

64 Member States are responsible for the correct application of the EU fisheries
control system to ensure compliance with the common fisheries policy27. They must 
control fishing activities within their waters, and those of fishing vessels flying their 
flag, regardless of location. Around 20 % of catches by EU vessels take place in third 
countries or on the high seas28. 

65 Figure 8 shows the resources allocated to control of fishing activities in EU waters
or by the EU fleet. 

Figure 8 – Control capacity in the EU 

1 200
patrol vessels

14 400
inspectors

76
aircraft

48 %
performed at 
port/landings

345 510 inspections
between 2015-2019

4 %
during transport

26 %
on markets

22 %
at sea

Source: ECA, based on the Report on the application of Council regulation (EC) No 1224/2009. 

66 In five sea basins (the Eastern Atlantic and Mediterranean Sea, the Black Sea, the
Baltic Sea, the North Sea, the Western Waters of the North Eastern Atlantic), certain 
fisheries are subject to Specific Control and Inspection Programmes (SCIPs). These 
programmes include common objectives, priorities and procedures for inspection 
activities by all Member States involved. To encourage closer collaboration and the 
exchange of best practices between Member States, the European Fisheries Control 

27  Control regulation. 

28  Fishing outside the EU. 

32 

Agency coordinates Joint Deployment Plans, where inspectors from different Member 
States participate in inspections. In 2020, 38 450 inspections were carried out by 
Member States and reported to the Agency as part of Joint Deployment Plans, 
detecting 2 351 infringements29. 

Picture 1 – Patrol vessel chartered by the European Fisheries Control 
Agency 

© European Fisheries Control Agency, 2005-2021. 

67 Member States report on the results of their control activities every five years. 
From 2015 to 2019, they conducted 345 510 inspections, with 13 %30 identifying at 
least one suspected infringement and 6 % at least one suspected serious infringement. 
In total, Member States reported 69 400 infringements during this period, with over 
76 % detected by just three Member States and the UK: Italy (46 %), the UK (12 %), 
Greece (11 %) and Spain (8 %). 

68 Figure 9 shows a breakdown of serious infringements by fishery activity. 

29  EFCA Annual Report for the year 2020. 

30  Synopsis Report of data provided by Member States. 

 
 
 
                                                      
Figure 9 – Proportion of serious infringements by category (2015-2019) 

33 

7 %
Obstruction of work of 
officials/observers

1 % Other

2 %
Falsification or concealment of 
markings, identity or registration

24 %
Fishing in a closed area or 
during a closed season, in 
excess of a quota or 
beyond a closed depth

9 %
Fishing without a valid 
licence, authorisation or 
permit

34 %
Failure to fulfil 
obligations to record 
and report catch data

13 %
Use of prohibited or 
non-compliant gear

2 %
Directed fishing for stocks 
subject to a moratorium or 
for which fishing is prohibited

7 %
Taking on board, 
transhipping or landing 
undersized fish

1 %
Concealing, tampering with or 
disposing of evidence relating to an 
investigation

Source: ECA, based on European Parliament data. 

69 Misreporting of catches remains a major issue in EU fisheries. One aspect is the 
failure to report unwanted catches (see Box 4). 

 
 
 
 
34 

Box 4 – Illegal discards and unreported catches 

It is common practice in the fishing industry to throw back unwanted catches at 
sea. These may be unwanted due to low commercial value or may be subject to a 
quota. As most discarded fish do not survive, the actual number of fish dying is far 
greater than landing and sales figures indicate. Another practice called “high 
grading”, consists of throwing back fish with commercial value for which the vessel 
has quotas, with the objective of optimising catches of larger specimens (grades) 
of the same species, which are sold at higher prices. 

Landing obligation 
Fishing vessels must land and report all catches of certain species (barring 
exemptions) and deduct them from any applicable quotas. The aim is to 
encourage the fishing industry to adopt more selective fishing practices and help 
scientists gather accurate data on actual exploitation of fish stocks. 

Lack of enforcement 
Control and enforcement are challenging, as discards cannot easily be detected by 
traditional inspections. While some Member States31 are piloting remote 
monitoring, the scale is insufficient. Reports32 reveal that illegal discards are 
commonplace and compliance with the landing obligation is low. 

In 2021, the Commission reported ‘extensive, illegal and undocumented discarding 
of catches in several sea basins’33. 

The Commission identified significant weaknesses in national control 
systems and has started to address them 

70 The Commission is responsible for overseeing and enforcing the correct 
application of the fisheries control regulation and common fisheries policy rules by all 
Member States34. It evaluates Member States through verifications, autonomous 
inspections and audits. 

31  Bulgaria, Cyprus, Germany, Denmark, Estonia, Spain, Croatia, Ireland, Italy, Latvia, Malta, 

the Netherlands, Portugal. 

32  For example, Landing obligation: First study of implementation and impact on discards, 

Report on control regulation. 

33  Report on the application of Council regulation (EC) No 1224/2009. 

34  Report on the application of Council regulation (EC) No 1224/2009. 

 
 
                                                      
35 

71 In 2021, the Commission reported on the results of its oversight of Member 
States from 2015 to 2019 period35. Its focus was on the proper weighing, registration 
and traceability of catches, control of the landing obligation, monitoring and control of 
the external fleet, and verification of engine power. All these measures are 
indispensable for the proper monitoring of quota uptake and resource sustainability. 

72 The Commission’s work has ‘highlighted significant shortcomings’ in the Member 
States in which they audited control of catch weighing, registration and traceability 
(Denmark, Ireland, Belgium and the Netherlands). These shortcomings led to 
overfishing and underreporting of catches. 

73 The Commission is taking remedial action. Between 2015 and 2020, the 
Commission opened 34 informal cases in its online ‘EU Pilot’ problem resolution 
platform to address identified weaknesses with Member States. It also drew up sixteen 
action plans with Member States36 to address deficiencies in catch registration, 
sanctioning systems, risk-management processes, computerised data 
validation/automated cross-checking systems and traceability requirements. 

74 Between 2015 and 2021, the Commission initiated eleven infringement 
procedures (legal action) against Member States regarding failures to effectively 
implement the landing obligation, adequately control their external fleet or fisheries, 
apply an effective sanctioning system in case of serious infringements, or control catch 
registration and weighing systems. 

EU-funded projects helped reinforce control system 

75 The European maritime and fisheries fund provides support for monitoring, 
control and enforcement activities, with a total budget of €580 million for the 
2014-2020 programme period. 

76 The latest data (end 2020) shows that Member States selected operations worth 
€440 million for control measures37. Measures eligible for funding included the 

35  Report on the application of Council regulation (EC) No 1224/2009. 

36  Belgium, Bulgaria, Cyprus, Germany, Estonia, Greece, Finland, Croatia, Italy, Lithuania, 

Malta, the Netherlands, Romania, Sweden (twice), Slovenia. 

37  EMFF implementation report 2020. 

 
 
                                                      
36 

installation and development of control technology, the modernisation and purchase 
of patrol vessels and aircraft, operational costs and the development of innovative 
control techniques (see Figure 10). 

Figure 10 – EU spending on control measures by category (in million 
euros) 

115

78

78

77

Control technology
(e.g. vessel detection and IT systems) 

Other control means
(e.g. weighing equipment) 

Operational costs for specific control 
and inspection programmes

Patrol vessels, aircrafts and helicopters

Components for data transmission

31

Programmes for exchanging and 
analysing data

23

Action plan to overcome 
shortcomings in control system

17

Others

21

Source: ECA, based on EMFF implementation report 2020. 

77 We selected a sample of 23 projects worth €27 million in total (with €22.4 million 
co-financed by the EU), allocated to control and enforcement in Denmark, Spain, 
France and Sweden. The projects selected covered IT development, patrol vessels, 
innovative technology and operational costs (see Figure 11). Of the 23 sampled 
projects, 20 were implemented by public bodies and three by private beneficiaries. 

 
 
 
37 

Figure 11 – Selected projects by category 

Planned EU funds 
used by category
(in million euros)

8.5

Number of projects 
by category

5

3

5.3

7

5.1

1.8

1.1

0.6

5

1

2

Specific control and inspection programmes/ Joint deployment plans
Vessels for inspection
Purchase, installation and development of technology
Innovative technology
Operating centres for inspection
Traceability equipment

Source: ECA. 

78 For each of these projects, we assessed whether the objectives met the needs 
identified by the managing authority in the national Operational Programmes for the 
European maritime and fisheries fund or the EU-level priorities for control and 
enforcement38. We performed a documentary check on each project, analysing 
application, selection procedures, implementation and costs. In each case, we found 
that all projects selected were in line with the national or EU priorities, and helped 
reinforce the Member States’ control systems. 

79 Five projects in our sample, worth €8.5 million in total, covered some of the costs 
linked to the participation of control authorities in Joint Deployment Plans or specific 
control activities. EU funds financed elements such as vessel maintenance, salaries and 
fuel for patrols. Member State authorities we interviewed confirmed that EU funding 
was essential to support these operations. Across the EU, Joint Deployment Plans 
enabled the detection of 2 351 infringements in 2020, as explained in paragraph 66. 

80 Three projects, worth €5.31 million in total, concerned the acquisition or 
upgrading of patrol vessels. This included a new patrol vessel and the replacement of 
six engines in four boats for the Galician Coastguard Service, and the renovation of a 
patrol vessel in France for use in the Indian Ocean. We verified that the authorities had 
organised tendering procedures to minimise costs and that these vessels would be 
used primarily for fisheries control. 

38  Commission implementing decision 2014/464/EU. 

 
 
 
                                                      
38 

81 Seven projects, worth €5.1 million in total, concerned the ‘purchase, installation 
and development of technology’. This mainly consisted of IT investments for control 
authorities to help them better target and perform their checks. The projects we 
selected included the use of artificial intelligence models for risk-based control, the 
development of a website for reporting illegal fishing, and multiple IT systems aimed at 
analysing and sharing fisheries data. The control authorities we interviewed confirmed 
that these tools were useful for their operations. 

82 We selected five innovative projects, worth €1.83 million in total, aimed at 
finding cost-effective ways to improve control. Figure 12 below presents four of these 
projects. 

 
 
Figure 12 – Innovative projects to combat illegal fishing 

39 

Drones can be useful for detecting fishing activities or illegal 
traps near coastlines, in lakes or inland waters. However, 
drones capable of long distance flight are rarely used for 
control at sea. While they have the potential to replace 
expensive manned aircraft, they have to be robust enough to 
fly in rough weather conditions. One of our selected projects 
concerned the testing of a specific drone for detecting illegal 
fishing in France. 

Satellites are used by all control authorities to track the 
activity and position of all vessels equipped with a Vessel 
Monitoring System (VMS). In these cases, satellites are used 
for data transmission at sea. One of our selected projects 
explored an innovative way to use satellite surveillance in the 
vast French Southern and Antarctic Territories. The project 
used pictures taken by a satellite from the Copernicus 
programme and used artificial intelligence to detect fishing 
vessels operating illegally.

One selected project was the design and testing in Spain of an 
autonomous surface vehicle powered by clean energy. 
Thanks to multiple sensors, this unmanned vessel can 
perform ocean research, while providing the coast guard with 
a discreet and autonomous surveillance system.

One selected project was the development and testing by 
Denmark of remote electronic monitoring to better control 
the landing obligation. Fourteen Member States are now 
testing systems combining the use of cameras and detector 
to be able to capture and analyse images of catches brought 
on board the vessels and ensure that bycatches are not 
discarded illegally.

The use of drones for 
fishery control

Satellite monitoring
for vessel detection

Autonomous surface 
vehicle

Remote electronic 
monitoring

Source: ECA. 

83 Other projects selected involved the acquisition of containers for storing seized 
equipment such as illegal gear, construction of operation centres for fisheries 
inspectors, and investments by private operators in traceability systems. 

 
 
 
40 

Sanctions imposed by Member States vary and are not always dissuasive 

84 The preamble to the illegal, unreported and unregulated fishing regulation 
recognises that the consistently high number of serious infringements of fisheries 
policy rules in EU waters or by EU operators is largely due to insufficiently dissuasive 
Member State sanctions. It added that the wide variety of sanctions across Member 
States encouraged illegal operators to cherry-pick the maritime waters or territory of 
the most lenient Member States. To address this weakness, the regulation introduced 
provisions to reinforce and standardise sanctions across the EU. 

85 The EU rules on sanctions apply to all ‘serious infringements’. It is up to each 
Member State authority to determine whether a specific infringement should be 
deemed serious, taking account of criteria such as the damage caused, its value, the 
extent of the infringement and prior offences. Serious infringements concern illegal 
activities such as fishing without a licence or authorisation, failure to report catches, 
fishing in a closed area or with no quota allocation, and using illegal gear39. Non-
compliance with the landing obligation may also be considered a serious 
infringement40. 

86 The EU rules require Member States to impose effective, proportionate and 
dissuasive sanctions for all serious infringements. One key principle is that the overall 
level of sanctions should effectively ‘deprive those responsible of the economic 
benefits derived from their serious infringements’. The value of the damage caused to 
fishing resources and the marine environment should also be considered. 

87 To promote a level playing field across the EU, the legislation introduced a 
penalty system for serious infringements. When a serious infringement is detected, the 
authorities must apply penalty points to the holder of the fishing licence and the 
master of the vessel. Above a specific threshold, defined in the regulation, the licence 
is suspended or withdrawn. 

88 In 2019, the Commission conducted a study on the sanction systems of all 
Member States for infringements of common fisheries policy rules41. It is based on 

39  illegal, unreported and unregulated fishing regulation. 

40  Control regulation. 

41  Study on the sanctioning systems of Member States for infringements to the rules of the 

common fisheries policy. 

 
 
                                                      
41 

data provided by Member State authorities covering 2015 to 2019. The study 
highlighted numerous positive findings. 

o 

The vast majority (92 %) of serious infringements detected led to an investigation 
or prosecution. 

o  Of all infringements investigated or prosecuted, 92 % led to sanctions. 

o 

The time taken for enforcement was usually short, with sanctions for serious 
infringements applied within ten months of detection on average. Member States 
that predominantly use criminal rather than administrative proceedings recorded 
longer times. 

89 The study also highlighted numerous gaps in the application of sanctions by 
Member States, undermining the effectiveness of the control system and the level 
playing field. These are listed below: 

o 

o 

o 

o 

a significant difference in the percentage of infringements qualified as ‘serious’ 
due to differing national criteria. Such infringements are therefore sanctioned 
differently; 

considerable variation in fines foreseen in national legislations, with maximum 
amounts ranging from €1 624 (Romania) to €600 000 (Spain) for administrative 
sanctions, and from €10 224 (Bulgaria) to €16 000 000 (Estonia) for criminal 
sanctions. In practice, the average fine imposed for a similar infringement ranged 
from around €200 (Cyprus, Lithuania, and Estonia) to more than €7 000 (Spain). In 
some Member States whose fishing fleets comprise large vessels or operate 
outside EU waters (Greece, Lithuania, Latvia), maximum fines are very low in 
relation to activity level, raising doubts as to their proportionality and deterrent 
effect; 

some Member States (Cyprus, Lithuania, Romania) frequently issue warnings in 
lieu of a fine for non-serious infringements, while others (Denmark, Spain) do so 
even for serious infringements; 

considerable variation in use of accompanying sanctions (e.g. confiscation of 
fishery products/illegal gear, suspension of fishing licence), which were only 
applied frequently by some Member States (Belgium, Denmark, France, Italy, the 
Netherlands); 

 
 
42 

o 

significant variation in application of the penalty points system, with some 
Member States (Greece, Romania, Croatia, Ireland) never or rarely applying 
points for serious infringements (contravening the fisheries control regulation). 

90 Based on our assessment of the results of this study and our own audit work; we 
conclude that there is no level playing field across the EU. Most seriously, in some 
Member States, sanctions are not proportionate to the economic benefit derived from 
the infringements, and are insufficient for deterrent effect. This is unfair to law-abiding 
operators and creates a risk of persistent non-compliance. 

91 In its 2018 proposal for the revision of the fisheries control system, the 
Commission proposed a number of changes to the existing legislation to better 
standardise sanctions for common fisheries policy infringements across Member 
States. These include more specific criteria for determining the gravity of 
infringements, the automatic qualification of certain infringements as serious, and the 
stipulation of standardised minimum and maximum sanctions for serious 
infringements. 

 
 
 
43 

Conclusions and recommendations 

92 Illegal, unreported and unregulated fishing depletes fish stocks, posing one of the 
world’s greatest threats to marine ecosystems, undermining efforts to manage 
fisheries sustainably and pushing some to the brink of collapse. Combating illegal 
fishing should offer EU consumers a guarantee that the products they consume are not 
derived from illegal, unreported and unregulated fishing. However, while necessary, 
ensuring the legality of a product is not sufficient to ensure that it is sustainably 
sourced. 

93 We examined EU spending and action aimed at preventing products of illegal, 
unreported and unregulated fishing from reaching EU citizens. We covered the control 
systems for preventing the import of illegal fishery products into the EU and Member 
States’ control systems for checking national fleets and waters. 

94 Overall, we conclude that the control systems in place to combat illegal fishing 
are partially effective; although they mitigate the risk, their effectiveness is reduced by 
the uneven application of checks and sanctions by Member States. 

95 The EU adopted the illegal, unreported and unregulated fishing regulation in 
2008, setting up the EU catch certification scheme. We found that the scheme 
improved traceability and reinforced the control of imports (paragraphs 28-29). 
Compared to similar systems, the EU scheme is the most comprehensive in terms of 
scope, information required, and validation and control processes (paragraphs 30-34). 

96 Member States’ authorities should perform risk-based checks to ensure that all 
imports are accompanied by valid catch certificates, verifying the information on each 
certificate. We found that significant differences in the scope and quality of checks and 
verifications by Member States undermined the effectiveness of the system and led to 
a risk of operators exploiting the weakest link (paragraphs 35-45). 

97 The EU catch certification scheme is still paper-based. There is no EU-wide 
database recording all catch certificates received by Member States. This reduces the 
efficiency and effectiveness of the control system and creates a risk of fraud. A digital 
EU-wide solution developed by the Commission became available in 2019, but 
Member States are not using it. The Commission proposal amending the fisheries 
control regulation intends to make CATCH mandatory in the EU (paragraphs 46-49). 

 
 
44 

98 When a flag state’s control system is deficient in key aspects, validated catch 
certificates cannot guarantee that products exported to the EU are not derived from 
illegal, unreported and unregulated fishing. The identification of ‘non-cooperating 
third countries’, commonly known as a “red card” under the “carding system”, is 
essential to prevent illegal products from entering the market. We found that the 
carding system had proven useful, triggering reform in most of the third countries 
concerned. While the carding system often impacts countries whose EU fish trade is 
minimal, these countries often act as ‘flags of convenience’ and consequently create a 
risk of illegal fishing (paragraphs 50-63). 

Recommendation 1 – Monitor that Member States reinforce 
their control systems for preventing the import of illegal fishery 
products, and take necessary action 

To enhance control of imported products, the Commission should work with the 
Member States to: 

(a)  pursue the digitalisation of the catch certification scheme and develop automated 

checks and risk alerts to support control activities; 

(b)  work with Member States towards the uniform use of risk identification criteria 

and monitor whether checks and verifications by Member States focus on the 
risks identified; 

(c)  monitor that the scope and quality of checks applied by Member States are 
sufficient to address the risks, and take necessary action to remedy any 
shortcomings. 

Target implementation date: 2026 

99 Member States must control fishing activities in their waters and those carried 
out elsewhere by fishing vessels flying their flag. Data shows that national checks often 
detected instances of illegal fishing, although three Member States and the UK 
detected around 75 % of all infringements reported. Misreporting of catches is the 
most common infringement by the EU fleet, followed by fishing in closed areas or with 
no quota allocation, and using illegal gear. There is ample evidence that enforcing the 
landing obligation is a challenge and that illegal discards at sea persist (paragraphs 64-
69). 

 
 
45 

100 The Commission’s work has identified significant shortcomings in some 
Member States’ control of catches weighing, registration, and traceability. These 
shortcomings have led to overfishing and underreporting of catches and the 
Commission is taking steps to address them (paragraphs 70-74). 

101 The European maritime and fisheries fund has provided support for monitoring, 
control and enforcement, with a total budget of €580 million for the 2014-2020 
programme period. We selected a sample of 23 projects dedicated to control and 
enforcement in four Member States. We found that these projects were in line with 
defined national or EU priorities and helped reinforce the control system 
(paragraphs 75-83). 

102 The EU framework requires Member States to impose effective, proportionate 
and dissuasive sanctions for all serious infringements. One key principle is that the 
overall level of sanctions must effectively ‘deprive those responsible of the economic 
benefits derived from their serious infringements’ (paragraphs 84-87). 

103 The vast majority of serious infringements detected led to an investigation or 
prosecution resulting in timely sanctions. However, the level of sanctions varied 
considerably across Member States for similar infringements. Comparison of the 
application of sanctions in national systems revealed the absence of a level playing 
field across the EU. Most seriously, in some Member States, sanctions are not 
proportionate to the economic benefit derived from the infringements, and are not 
dissuasive (paragraphs 88-91). 

 
 
46 

Recommendation 2 – Ensure that Member States apply 
dissuasive sanctions against illegal fishing 

The Commission should work on the uniform and effective application of a dissuasive 
sanctioning system for illegal fishing across Member States by: 

(a)  checking that Member States apply sanctions for serious infringements;  

(b)  checking that the value of the sanction applied by Member States is no less than 
the economic benefit derived from the infringement and is dissuasive enough to 
prevent repeat infringements; 

(c)  checking that the application of the penalty point system across Member States is 

harmonised; 

Target implementation date: 2024 

(d)  take necessary action to remedy any shortcomings. 

Target implementation date: 2026 

This Report was adopted by Chamber I, headed by Ms Joëlle Elvinger, Member of the 
Court of Auditors, in Luxembourg at its meeting of 14 July 2022. 

For the Court of Auditors 

Klaus-Heiner Lehne 
President 

 
 
 
 
 
 
 
47 

Annexes 

Annex I – International instruments to combat illegal, 
unreported and unregulated fishing 

Binding instruments

UN Convention on the Law of the Sea 
(UNCLOS)
This convention, adopted in 1982, defines 
the rights and responsibilities of nations 
with respect to their use of the world’s 
oceans, establishing guidelines for 
businesses, the environment, and the 
management of marine natural resources. 

UN Fish Stocks Agreement (UNFSA)
This agreement, adopted in 1995, 
complements the UNCLOS and aims to 
ensure the long-term conservation and 
sustainable use of straddling and highly 
migratory fish stocks. It specifies the duties 
of flag states including those related to 
fishing vessel registration, fishing 
authorisations, and fishery control, 
monitoring and surveillance.

FAO Compliance Agreement
This agreement, adopted in 1993 with entry 
into force in 2003, promotes compliance 
with international fisheries conservation 
and management measures and aims to 
prevent the flagging of vessels fishing on 
the high seas under the flags of states that 
are unable or unwilling to enforce them. 

FAO Agreement on Port States 
Measures to Prevent, Deter and 
Eliminate IUU fishing (PSMA)
This agreement from 2009 entered into 
force in 2016 and aims to prevent vessels 
engaged in IUU fishing from using ports and 
landing their catches, thereby reducing the 
incentive of such vessels to continue to 
operate and blocking fishery products 
derived from IUU fishing from reaching 
national and international markets.

FAO
UN

1980

1982

1990

1995

2000

2001

2003

2010

2015

2016

2017

2020

Voluntary instruments

FAO Code of Conduct for Responsible 
Fisheries
This code of conduct adopted in 1995 lays 
down principles and international 
standards of behaviour for responsible 
fishing practices to ensure sustainable 
exploitation of aquatic living resources in 
harmony with the environment. It 
includes provisions on the duties of all 
coastal states, flag states, port states and 
market states, and the role of RFMOs. 

FAO International Plan of Action to 
Prevent, Deter and Eliminate IUU 
Fishing (IPOA-IUU)
This plan of action from 2001 is a toolbox 
to combat IUU fishing, calling upon all 
countries to develop and implement a 
consistent National Plan of Action against 
IUU fishing. 

FAO Voluntary Guidelines for Flag 
State Performance (VGFSP)
These guidelines from 2015 provide 
guidance to strengthen and monitor 
compliance by flag States with their 
international duties and obligations 
regarding the flagging and control of 
fishing vessels. 

FAO Voluntary Guidelines on Catch 
Documentation Schemes (VGCDS)
These guidelines from 2017 advise 
importing countries on how they can 
implement catch documentation schemes 
in their fight against IUU activities in an 
attempt to tackle the problem from a 
market and trade perspective. 

48 

Annex II – Benchmarking of EU catch certification scheme with similar systems in USA and Japan 

Coverage 

Information requirements 

Validation and control system 

The EU scheme has the most comprehensive 
coverage: all fishery products must be traceable 
and certified. 

o 

o 

The EU scheme covers all processed and 
unprocessed wild-caught marine fish 
imported from third countries into the 
EU market (with some exemptions for 
products of minor importance in the fight 
against illegal fishing), as well as from EU 
countries if re-imported after processing 
outside the EU. 

The US seafood monitoring programme 
(SIMP) covers 13 types of seafood 
identified as being most vulnerable to 
illegal, unreported and unregulated 
fishing and seafood fraud. This 
represents nearly half of all US 
seafood imports42. 

The EU and US schemes have broad information 
requirements allowing detailed traceability. 

o 

o 

o 

o 

All schemes require the collection of 
basic product information: vessel, flag, 
species and quantities caught. 

Only the EU and US schemes require 
information on processed weight. 

The CCAMLR scheme is the only scheme 
not to require information on precise 
catch area (accepting ‘high seas’ or 
coastal state exclusive economic zone), 
fishing gear and method. 

The ICCAT and CCSBT schemes do not 
require information on the fishing 
licence, authorisation to fish, vessel 
identifier number or port of landing. 

The EU scheme has the most comprehensive 
validation and control system (certification by flag 
state and checks by national authorities at EU 
destination). 

o 

o 

In the USA, importers are responsible for 
ensuring the legality  of the products. 
There is no role for the flag State to 
validate the information provided by the 
operators. Fisheries control authorities 
conduct both random and targeted 
audits of seafood products covered by 
the programme47. 

In the EU, each consignment must be 
accompanied by a certificate validated by 
the flag state. In addition, Member State 
authorities must ensure that imports of 
fishery products are accompanied by a 

42  SIMP Report to Congress Efforts to Prevent Seafood Harvested through IUU fishing. 

47  Compliance Guide for the Seafood Import Monitoring Program. 

 
                                                      
49 

Coverage 

Information requirements 

Validation and control system 

o 

Currently, Japan monitors the four 
species covered by regional schemes: 
southern bluefin tuna, Atlantic bluefin 
tuna, Antarctic toothfish and Patagonian 
toothfish43. A new law will introduce a 
catch documentation scheme for other 
species considered as vulnerable seafood 
imports44. Initially it will be applicable to 
four species with the possibility of 
extending the scope. 

o 

The EU scheme is mainly paper-based. 
The US scheme requires importers to 
report key data in a national system, 
keeping paper or electronic records. 
While ICCAT and CCAMLR use digital 
systems45, CCSBT is not yet fully 
digitalised46. 

o 

valid catch certificate, and perform risk-
based checks and verifications. 

Each Regional Management Organisation 
has its own control and validation rules. 
Both CCAMLR48 and ICCAT49 require flag 
states to certify catches. Members must 
ensure that their authorities examine the 
documentation of each shipment. 
CCSBT50, members must carry out audits, 
including inspections of vessels, landings 
and, where possible, markets to validate 
the information in the documentation. 

43  A comparative study of key data elements in import control schemes aimed at tackling IUU fishing in the top three seafood markets. 

44  Japan to Require Catch Documents for Imports of Vulnerable Marine Species. 

45  Recommendation by ICCAT on an electronic Bluefin Tuna Catch Documentation Programme (eBCD). 

46  Resolution on the implementation of a CCSBT Catch Documentation Scheme. 

48  Conservation Measure 10-05 (2018), Catch Documentation Scheme for Dissostichus spp. 

49  Recommendation 18-13 by ICCAT on an ICCAT Bluefin Tuna Catch Documentation program. 

50  Resolution on the Implementation of a CCSBT Catch Documentation Scheme. 

 
 
                                                      
50 

Abbreviations 

CCAMLR: Commission for the Conservation of Antarctic Marine Living Resources 

CCSBT: Commission for the Conservation of Southern Bluefin Tuna 

EFCA: European Fisheries Control Agency 

EMFF: European maritime fisheries fund 

FAO: Food and Agriculture Organization 

ICCAT: International Commission for the Conservation of Atlantic Tunas 

IUU: Illegal, unreported and unregulated 

 
 
 
 
51 

Glossary 

Carding system: The EU’s method of identifying non-EU countries whose measures for 
deterring illegal fishing are inadequate, and penalising them with a formal warning 
(‘yellow card’) or an import ban (‘red card’). 

Catch certification scheme: Requirement that all fisheries exports to the EU carry 
certificates, validated by the fishing vessel’s flag state, to prove that they come from 
legal catches. 

Common fisheries policy: The EU’s framework for managing fish and fishing, designed 
to ensure sustainable fish stocks and a stable income for the fishing community.  

European maritime and fisheries fund: EU fund that supports fishers in the transition 
to sustainable fishing, and coastal communities in diversifying their economies. 

Exclusive economic zone: Area of sea, immediately beyond the territorial waters of a 
coastal country, in which that country has certain rights and duties under the UN 
Convention on the Law of the Sea. 

Flag state: Country in which a sea-going vessel is registered. 

Joint deployment plan: Control and inspection arrangements for priority fishing areas 
using resources pooled by Member States. 

Landing obligation: Requirement for fishing vessels to bring ashore all catches of 
certain species, and to report them and deduct them from any applicable quotas. 

Regional fisheries management organisation: Intergovernmental organisation with 
the authority to establish fisheries conservation and management measures in 
international waters. 

 
 
 
 
Replies of the Commission 

52 

https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=61941 

Timeline 

https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=61941 

 
 
 
 
 
 
 
 
 
 
  
 
53 

Audit team 

The ECA’s special reports set out the results of its audits of EU policies and 
programmes, or of management-related topics from specific budgetary areas. The ECA 
selects and designs these audit tasks for maximum impact, considering the risks to 
performance or compliance, the level of income or spending involved, forthcoming 
developments and political and public interest. 

This performance audit was carried out by Audit Chamber I - Sustainable use of natural 
resources, headed by ECA Member Joëlle Elvinger. The audit was led by ECA Member 
Eva Lindström, supported by Katharina Bryan, Head of Private Office, and 
Johan Stalhammar, Private Office Attaché; Paul Stafford, Principal Manager; 
Frédéric Soblet, Head of Task; Paulo Faria, deputy Head of Task and 
Kartarzyna Radecka-Moroz, Radostina Simeonova and Anna Zalega, Auditors. 
Marika Meisenzahl provided graphical support. 

From left to right: Johan Stalhammar, Frédéric Soblet, Eva Lindström, Katharina Bryan, 
Paul Stafford. 

 
 
 
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ISBN 978-92-847-8634-3  ISSN 1977-5679  doi:10.2865/563 
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Illegal, unreported and unregulated fishing is one of the greatest 
threats to marine ecosystems, undermining efforts to manage 
fisheries sustainably. We examined the EU framework, action and 
spending aimed at preventing illegal fishery products from ending 
up on EU citizens’ plates. Overall, we conclude that the control 
systems in place to combat illegal fishing are partially effective; 
although they mitigate the risk, their effectiveness is reduced by 
the uneven application of checks and sanctions by Member 
States. We recommend that the Commission monitor that 
Member States reinforce their control systems for preventing the 
import of illegal fishery products, and ensure that Member States 
apply dissuasive sanctions against illegal fishing. 

ECA special report pursuant to Article 287(4), second 
subparagraph, TFEU.