REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the Commission's assessment of the Member States’ programmes of measures as updated under Article 17 of the Marine Strategy Framework Directive (2008/56/EC)
Date: 2025-02-04
Institutions: Directorate-General for Environment, European Commission
Subjects: EU Member State, EU action, biodiversity, climate change, climate change policy, environmental protection, marine ecosystem, marine environment, marine pollution, prevention of pollution

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.2.2025  COM(2025) 3 final  REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the Commission's assessment of the Member States’ programmes of measures as updated under Article 17 of the Marine Strategy Framework Directive (2008/56/EC)                           {SWD(2025) 1 final}  
 
 
CONTENTS 

1. 

2. 

3. 

INTRODUCTION .................................................................................................. 1 

STATE OF THE SEAS IN EUROPE................................................................... 3 

TACKLING THE TRIPLE PLANETARY CRISIS .......................................... 8 

3.1  TOWARDS ZERO POLLUTION IN THE SEAS AND OCEAN ................... 10 

3.2  BRINGING MARINE NATURE BACK INTO OUR LIVES ......................... 13 

3.3  TACKLING THE CLIMATE CRISIS .............................................................. 18 

4. 

ENSURING SOCIO-ECONOMIC SOUNDNESS............................................ 20 

5.  GOVERNANCE AND REGIONAL COOPERATION ................................... 20 

6.  CONCLUSIONS AND OUTLOOK ................................................................... 24 

7.  RECOMMENDATIONS ..................................................................................... 25 

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1.  INTRODUCTION 

The  seas  and  ocean  are  vital  to  the  quality  of  our  –  and  future  generations’  –  lives, 
livelihoods  and  economies.  They  also  perform  a  significant  function  in  carbon 
sequestration, regulating the climate and helping reduce the impact of climate change. 
Ocean health can make a difference to our resilience to the triple planetary crisis, namely 
climate  change,  biodiversity  collapse  and  pollution.  The  current  use  of  Europe’s  seas, 
however,  is  not  sustainable.  Unabated  pressure  on  and  the  deterioration  of  the  marine 
ecosystems are making it difficult to achieve our overarching objective of clean, healthy 
and productive seas. 

Over the past 12 years, EU Member States have developed marine strategies to comply 
with the Marine Strategy Framework Directive (MSFD) (1). The Directive requires them 
to assess the status  of their  marine environment,  draw up monitoring programmes, set 
environmental  targets  and  implement  measures  to  achieve  the  Directive’s  key  goal  of 
securing the ‘good environmental status’ (GES) of all EU marine waters. This was to be 
achieved by 2020. The Directive sets out specific descriptors (2) that define the concept 
of  GES,  such  as  conserving  biodiversity  or  tackling  anthropogenic  pressure  such  as 
underwater noise, eutrophication, seabed damage, marine litter and contaminants.  
A  Commission  Decision (3)  in  force  since  June  2017  requires  Member  States  to  meet 
common criteria and methodological standards when determining ‘good environmental 
status’ in quantitative terms for their marine waters. Importantly, the MSFD explicitly 
requires Member States to cooperate with their neighbours in each marine region or sub-
region,  preferably  through  existing  regional  institutional  cooperation  structures (4),  to 
ensure that the measures implemented are coherent and coordinated (5). 
The  European  Green  Deal  ( 6 )  sets  overarching  priorities  including  protecting  our 
biodiversity and ecosystems, therefore bolstering this work by pursuing the ambition to: 

reduce air, water and soil pollution;  

- 
-  move to a circular economy;  
- 
- 

improve waste management; and  
ensure the sustainability of our blue economy and fisheries sectors.  

(1) Directive 2008/56/EC of the European Parliament and of the Council of 17 June 2008 establishing a 
framework for community action in the field of marine environmental policy (Marine Strategy Framework 
Directive). See EUR-Lex - 32008L0056 - EN - EUR-Lex (europa.eu). 
2 The 11 qualitative descriptors are defined in Annex I  to the Marine Strategy Framework Directive and 
further  specified  in  Commission  Decision  2017/848/EU.  They  include  D1–  Biodiversity,  D2  –  Non 
indigenous species (NIS), D3 – Commercial fish and shellfish, D4 – Food webs, D5 – Eutrophication, D6 
– Sea-floor integrity, D7 – Hydrographical changes, D8 – Contaminants, D9 – Contaminants in seafood, 
D10 – Litter, D11 – Energy, including underwater noise. 
(3)  Commission  Decision  (EU)  2017/848  laying  down  criteria  and  methodological  standards  on  good 
environmental  status  of  marine  waters  and  specifications  and  standardised  methods  for  monitoring  and 
assessment. See: EUR-Lex - 32017D0848 - EN - EUR-Lex (europa.eu). 
(4) Including the structures set up under Regional Sea Conventions. 
(5)  Article 4  of  Directive 2008/56/EC  lists  the  EU  marine  regions  and  subregions.  The  four  EU  marine 
regions are the Baltic Sea, North-East Atlantic Ocean, the Mediterranean Sea and the Black Sea. 
(6) A European Green Deal (europa.eu). 

1 

 
 
The EU’s biodiversity strategy (7), the zero pollution action plan (8) and the marine action 
plan (9) are the key policy instruments adopted to pursue these aims. 

The  MSFD  is  part  of  a  broader  agenda  on  water  resilience.  The  2024-2029  Political 
Guidelines  for  the  next  College  announced  the  adoption  of  a  new  European  Water 
Resilience Strategy to strengthen Europe’s water security by preserving water quality and 
quantity in the EU and beyond, enhancing the competitive innovative edge of our water 
industry,  and  addressing  the  root  causes  of  water  challenges,  including  pollution, 
biodiversity loss, and the impacts of climate change. Clean, healthy and productive seas 
and  oceans  are  central  to  our  green  and  digital  transition  and  for  the  EU’s  long-term 
prosperity. The MSFD can also make a direct contribution to achieve the objectives of 
the  forthcoming  ‘Ocean  pact’  announced  by  President  von  der  Leyen  in  her  Political 
Guidelines for the next Commission mandate to ‘boost the blue economy and ensure the 
good governance and sustainability of our oceans in all of their dimensions’. 

This is the first time under the new policy framework that the Commission assesses the 
second programmes of measures under the MSFD. The assessment is performed in close 
coordination with the assessments of the third river basin management plans (RBMPs) 
and  the  second  flood  risk  management  plans  under  the  Water  Framework  Directive 
(WFD) and the Floods Directive (FD) (10). To accelerate effective implementation, the 
Commission aims to encourage a more integrated and coherent approach in implementing 
freshwater and marine water legislation, in line with a ‘source-to-sea’ approach (11). 

The  assessment  therefore  focuses  in  particular  on  ensuring  that  implementation  of  the 
MSFD is consistent with the WFD. It should be noted, however, that the requirements of 
the  two  directives  differ.  The  WFD/FD  report  thoroughly  assesses  the  state  of  EU 
freshwater bodies based on data reported by the Member States and the measures they 
have taken to improve. The MSFD report, required by Article 16 of the MSFD, by contrast 
only  assesses the Member States’ programmes of measures. The two  reports  therefore 
differ slightly in scope so the comparisons are made on the common elements.  

Although  the  programmes  of  measures  were  developed  before  the  Nature  Restoration 
Law was adopted (12), the implementation of the latter will certainly influence the third 
cycle of implementing the MSFD. 

and 

Pollution 

final.  Available 

for  Air,  Water 

Soil',  COM/2021/400 

(7) Biodiversity strategy for 2030 (europa.eu). 
(8) Communication from the Commission, Pathway to a Healthy Planet for All EU Action Plan: 'Towards 
Zero 
at: 
https://environment.ec.europa.eu/strategy/zero-pollution-action-plan_en. 
(9) Communication from the Commission, EU Action Plan: Protecting and restoring marine ecosystems for 
sustainable and resilient fisheries, COM/2023/102 final. Available at: EUR-Lex - 52023DC0102 - EN - 
EUR-Lex (europa.eu)  
(10) Report from the Commission to the Council and the European Parliament on the implementation of 
the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Third river basin 
management plans Second flood risk management plans, COM(2025) 2 
(11)  Source-to-sea approach refers to the establishment of governance that increases collaboration and 
coherence across the source-to-sea system and reduces alteration of key flows (water, pollution, sediment, 
materials, biota, ecosystem services) resulting in measurable economic, social and environmental 
improvement across freshwater, coastal, nearshore, transitional and marine environments. It considers the 
entire source-to-sea system – stressing upstream and downstream environmental, social, and economic 
linkages and stimulating coordination across sectors and segments. 
(12) Regulation (EU) 2024/1991 of the European Parliament and of the Council of 24 June 2024 on nature 
restoration and amending Regulation (EU) 2022/869, OJ L, 2024/1991, 29.7.2024. 

2 

 
 
Purpose and structure 

This report presents the main outcomes from the Commission’s assessment of the second 
programmes of measures, which all Member States had to report by 31 March 2022 (13). 
These programmes are an update since the first implementation cycle and take account of 
the  latest  assessment  of  the  state  of  marine  waters  and  the  Commission’s  2018 
recommendations on the measures (14). A more detailed analysis of the Member States’ 
programmes of measures, the degree of regional coherence, country-specific conclusions 
and recommendations are provided in the accompanying staff working document (15). 

The analysis is structured along the triple planetary crisis of pollution, biodiversity loss 
and climate change (16). The aim is to assess whether the measures put forward by the 
Member States are sufficient to tackle the specific forms of pressure in their marine waters 
and to contribute to achieving GES. It also makes a set of key recommendations to guide 
further improvements. Some of the key messages and recommendations presented in the 
conclusions complement those presented in the WFD/FD report. 

Only five Member States reported by the deadline of March 2022. A further nine reported 
with up to one year of delay and three reported with over a year of delay but still in time 
to  be  included  in  this  assessment (17).  In  total,  the  Commission  was  able  to  assess  the 
programmes of measures from 17 (out of 22) coastal Member States: Belgium, Germany, 
Ireland,  Spain,  Estonia,  France,  Italy,  Cyprus,  Latvia,  Lithuania,  Netherlands,  Poland, 
Portugal, Romania, Slovenia, Finland and Sweden. Delays and failures to report limited 
the Commission’s ability to perform comprehensive regional coherence assessments. 

The programmes of measures for the five remaining Member States (Bulgaria, Croatia, 
Denmark, Greece and Malta) will be published on the EEA WISE-Marine Platform (18). 
The Commission will also prepare country-specific assessments and recommendations, 
which will be shared with the Member States directly. The assessment of Member States’ 
programmes will also feed into the 2024 Zero Pollution Monitoring and Outlook Report, 
the ongoing review of the MSFD (19), and other work to implement the EU’s biodiversity 
and climate adaptation strategies. 

2.  STATE OF THE SEAS IN EUROPE 

Approximately 40% of the EU’s population lives in coastal areas. For these communities, 
the seas and ocean are directly linked to culture, identity and their sense of belonging (20). 

(13) See Article 13(9) of Directive 2008/56/EC. 
(14) Report from the Commission assessing Member States’ programmes of measures under the Marine 
Strategy Framework Directive, Brussels, 31.7.2018 COM(2018) 562 final. 
(15)  Commission Staff Working Document accompanying the document Report from the Commission to 
the Council and the European Parliament on the Commission’s assessment of the Member States’ 
programmes of measures as updated under Article 17 of the Marine Strategy Framework Directive 
(2008/56/EC), SWD(2025) 1.  
(16) See What is the Triple Planetary Crisis? | UNFCCC. 
(17) On time – BE, IT, RO, SE, FI; up to 6 months delay – NL, DE, FR, PL, ES; up to 1 year delay – IE, 
PT, SI, EE; by 1 September 2023 – CY, LT, LV. 
(18)  MSFD reports and assessments (europa.eu). 
(19)  Protecting the marine environment – review of EU rules (europa.eu). 
(20) Marine (europa.eu). 

3 

 
 
 
Decades of overfishing, discharges of nutrients, contaminants and litter, intense maritime 
traffic  and  several  other  forms  of  anthropogenic  pressure,  combined  with  the  growing 
impacts of climate change, have severely degraded the condition of marine ecosystems. 

These  increasing  pressures  jeopardise  the  benefits  from  Europe’s  seas  and  ocean  that 
future generations are entitled to and will need for their lives, livelihoods and economies. 

In 2018, Member States carried out the first assessment of the state of their marine waters 
under  the  MSFD,  analysing  the  extent  to  which  pressures  from  human  activities  are 
impacting  marine  life  and  ecosystems  and  progress  towards  achieving  GES  (21).  This 
together with other sources of information gave the Commission a comprehensive picture 
of the state of the marine environment in 2020, the deadline for achieving GES.  

Despite improvements in some areas, the conclusion then was clear: GES had not been 
achieved  in  all  European  marine  waters (22).  On  the  positive  side,  however,  the  ever-
increasing trends in certain types of pressures across Europe’s seas can still be reversed. 
In particular, they can be reversed by implementing effective measures under the MSFD, 
some of which build on other long-standing policy and legal frameworks (e.g. the Birds 
and  Habitats  Directive,  Maritime  Spatial  Planning  Directive,  the  Water  Framework 
Directive and the common fisheries policy). 

A striking example  is  the estimated 29% reduction of  beach litter  between 2015-2021 
across all EU sea basins (23), with an even more significant 45% reduction in the Baltic 
Sea. Although most sea basins have yet to reach GES, this scale of reduction in 5 years is 
a  success  story,  demonstrating  that  joint  action  works.  There  are  a  number  of  factors 
explaining this result, including very strong public support for action, high level political 
commitments to reverse the trend (e.g. the 2018 plastics strategy, the 2021 zero pollution 
action plan under the European Green Deal) and a solid legal basis for authorities to take 
action (along with the MSFD, the 2019 Single Use Plastic (SUP) Directive and the 2019 
Port Reception Facilities Directive). The added value of the MSFD in this process is clear: 

- 

- 

the public and political campaigns to act against litter and plastic used MSFD data 
to back up their messages; 
the same data was used in the impact assessment and the adoption of the Single 
Use Plastics Directive, and helped raise public awareness; 

-  given that the 29% reduction took place even before the SUP Directive was in 
force, at least part can be attributed to the measures planned under the first MSFD 
implementation cycle; 
the 29% reduction can be assessed and communicated clearly due to the collective 
efforts of Member States, EU institutions and agencies (24) and civil  society to 
collect and produce high quality, comparable data. 

- 

(21) See the Commission Communication, Commission Notice on recommendations per Member State and 
region on the 2018 updated reports for Articles 8, 9 and 10 of the Marine Strategy Framework Directive 
(2008/56/EC) 2022/C 118/01. See: EUR-Lex - 52022XC0314(01) - EN - EUR-Lex (europa.eu). 
(22)  Report  from  the  Commission  on  the  implementation  of  the  Marine  Strategy  Framework  Directive 
(Directive 2008/56/EC), COM/2020/259 final, EUR-Lex - 52020DC0259 - EN - EUR-Lex (europa.eu). 
(23) European Commission, Joint Research Centre, MSFD Technical Group on Marine Litter, Hanke, G., 
Walvoort, D., Ruiz-Orejón, L. F., van Loon, W. M. G. M., Giorgetti, A., Molina-Jack, M. E., Vinci, M., 
European Coastline Litter Trends 2015–2021 – Methodology development and trend results for the Marine 
Strategy  Framework  Directive,  Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
JRC138907. 
(24) E.g. the European Environment Agency (EEA), the European Maritime Safety Agency (EMSA), and 
the European Marine Observation and Data Network (EMODnet). 

4 

 
 
The analysis of the second programmes of measures for marine litter shows that Member 
States are taking further action to tackle the problem of beach litter: this should support 
the positive trend of continuous reductions (see Section 3.1). 

For  other  topics,  such  as  marine  pollution  or  biodiversity  loss,  progress  towards  GES 
since 2018 will be assessed after the Member States report their third assessment of the 
state  of  marine  waters  in  October  2024.  In  the  meantime,  the  regional  assessments 
produced  by  the  four  Regional  Sea  Conventions  (RSCs)  -  i.e.  the  Helsinki  ( 25),  the 
OSPAR (26), the Barcelona (27) and the Bucharest Conventions (28) - provide a wealth of 
recent information about the state of EU seas. 

•  Baltic Sea Basin 

The  third  HELCOM  holistic  assessment ( 29 )  published  in  October  2023  provides  a 
comprehensive overview of the state of the Baltic Sea’s ecosystem from 2016-2021. It 
shows little to no improvement over that period, highlighting the need for continued and 
improved coordinated measures. 

-  Pollution pressures remain at a high level. Eutrophication is still a major problem, 
affecting different levels of the food web and contributing to ecosystem degradation. 
There are signs of improvements in some areas, particularly in the south-western sub-
basins,  but  there has been  an  alarming further deterioration in  central parts  of the 
Baltic Sea. Pressure from hazardous substances remains high in most areas across the 
region, with high concentrations of certain contaminants (30) predominantly found in 
fish and mussels. There are indications of some improvements, with reductions seen 
in chemical concentrations in animals in a number of areas. For beach litter, 11 out 
of  16  sub-basins  are  above  the  threshold  value  of  20  litter  items  per  100 m  of 
beach (31) and therefore are not in good environmental status. One of the main drivers 
of underwater noise is ship noise, where there are considerable variations in space 
(shipping  lanes  are the  most affected) and time (ship noise  is more widespread in 
winter than in summer). 

- 

In terms of biodiversity, several marine species (including mammals and birds) and 
habitats are not in a good status across the whole Baltic Sea and at all levels of the 
food web. Three commercial fish stocks have declined since the last assessment and 
only one has improved. However, action on biodiversity conservation has increased 
and the region is on track to reach the global target to protect 30% of areas by 2030. 

-  The  effects  of  climate  change  are  already  evident  with  the  forecasted  warming 
expected to soon lead to further harmful impacts, accelerating the urgent need to take 
measures to build ecosystem resilience and to mitigate the negative impacts. 

Despite the overall conclusion that the Baltic Sea state has not improved, the assessment 
shows that, when well designed and effectively implemented, coordinated measures to 
reduce pressure do deliver tangible results. The progress report on the commitments taken 

(25) See https://helcom.fi/. 
(26) See https://oap.ospar.org/en/. 
(27) See https://www.unep.org/unepmap/who-we-are/barcelona-convention-and-
protocols?%2Ffr%2Fwho-we-are%2Fbarcelona-convention-and-protocols=. 
(28) See http://www.blacksea-commission.org/_convention.asp. 
(29) See State of the Baltic Sea 2023 – HELCOM. 
(30)  Polybrominated diphenyl ethers (PBDEs), Tributyltin (TBT), Mercury and Copper. 
(31)  EU Member States agree on threshold value to keep Europe’s beaches clean - European Commission 

(europa.eu). 

5 

 
 
 
under  ‘Our  Baltic  declaration’,  published  for  the  second  ‘Our  Baltic’  conference  in 
September 2023 (32), confirms that these are fundamental steps. 

•  Mediterranean Sea Basin 

In December 2023, the Barcelona Convention produced a comprehensive assessment of 
the state of the Mediterranean Sea (33) based on data collected since the last quality status 
report  in  2017.  Although  many  topics  could  not  be  assessed  due  to  uneven  data 
availability, the available indicator assessments show a mixed picture. 

- 

- 

In terms of pollution, notably contaminants and eutrophication, although there are 
no  clear  messages  applicable  to  the  whole  Mediterranean,  detailed  results  are 
available for specific assessment areas and indicators (34). Only 16% of monitored 
Mediterranean  beaches  have  achieved  GES  for  litter.  The  Aegean-Levantine  sub-
region is the most affected by acute pollution events, in particular oil spills, reflecting 
the  fact  that  it  is  one  of  the  busiest  Mediterranean  maritime  routes.  The  whole 
Mediterranean Sea seems to be in GES in terms of impulsive noise levels impacting 
selected  cetaceans,  but  not  for  continuous  noise,  particularly  in  the  Western 
Mediterranean and Aegean-Levantine Sea. 

In terms of biodiversity, the overexploitation of fish stocks has decreased over the 
past decade encouragingly, with action accelerating over the last two years, reaching 
its lowest level since 2003. This trend is consistent in all sub-regions (35). However, 
most commercial species are still overexploited, and fishing pressure is still double 
the level considered to be sustainable. Habitat destruction remains one of the most 
pervasive  threats  to  the  structure  and  functioning  of  Mediterranean  coastal 
ecosystems.  Down  to  depths  of  1 000 m,  the  most  extensive  damage  to  seabed 
habitats is caused by bottom fishing using trawls and dredges. Many populations of 
seabird species have reached GES, with some exceptions. Most cetaceans are still 
listed as significantly threatened on the IUCN Red List Assessment, though the status 
of  widespread  species  such  as  the  common  bottlenose  and  striped  dolphins  has 
improved since mid-2000. 

-  Climate change is one of the most critical challenges that the Mediterranean region 
faces.  Over  the  last  three  decades,  marine  heatwaves  have  caused  mass-mortality 
events across various marine species and critical losses for the seafood industry. The 
rise  in  seawater  temperature  is  accelerating  the  spread  of  non-indigenous  species. 
Hydrographic  changes  cause  Mediterranean  marine  habitats  to  be  increasingly 
endangered,  with  some  at  risk  of  complete  extinction.  The  central  and  eastern 
Mediterranean  areas  are  considered  more  vulnerable  to  climate  change  due  to 
increased pressure from invasive species, higher water temperatures and less ocean 
circulation, which leads to lower levels of dissolved oxygen (36).  

(32) https://op.europa.eu/en/publication-detail/-/publication/2e76afa1-5695-11ee-9220-01aa75ed71a1. 
(33) 2023 Mediterranean Quality Status Report, 23rd Meeting of the Contracting Parties to the Convention 
for the Protection of the Marine Environment and the Coastal Region of the Mediterranean and its 
Protocols, Portorož, Slovenia, 5-8 December 2023, UNEP/MED IG.26/Inf.10. 
(34)  For instance, the Adriatic Sea sub-region is in GES for nitrogen, phosphorous and chlorophyll-a and 
80% of sub-regions are in GES for metals, Polycyclic Aromatic Hydrocarbons (PAHs) and 
Polychlorinated Biphenyls (PCBs) in sediments. 
(35)  Communication from the Commission to the European Parliament and the Council, Sustainable 
fishing in the EU: state of play and orientations for 2025, Brussels, 7.6.2024, COM(2024) 235 final. 
(36)  As above. 

6 

 
 
 
•  North-East Atlantic Basin 

The  quality  status  report,  released  in  June  2023  by  OSPAR ( 37)  and  based  on  data 
spanning the 2009-2021 period, is the most authoritative assessment of the state of the 
whole North-East Atlantic Sea. Significant advances have been made to better understand 
and  limit  the  negative  impacts  of  human  activity.  Despite  some  improvements,  trends 
indicate that biodiversity is declining and habitats are being degraded across many parts 
of the OSPAR maritime area. 

-  Pollution from a wide range of hazardous substances, excessive nutrients (leading to 
eutrophication)  and  marine  litter  have  not  been  fully  addressed.  Reductions  have 
been recorded in discharges of hazardous substances from the oil and gas sector and 
of radioactive substances from the nuclear sector. Concentrations of many of the most 
serious  hazardous  substances  (e.g.  PAHs  and  PCBs  originating  from  run-offs, 
industrial discharges and old building sites, and certain insecticides) have decreased 
substantially since the 1980s and 1990s. However, most sub-regions are in a poor 
status  for  hazardous  substances  in  marine  species,  caused  mainly  by  mercury  and 
PCBs, while the situation is somewhat better for sediment pollution. There has been 
a significant reduction in the nutrients reaching the marine environment, particularly 
from  agricultural  sources,  wastewater  and  industrial  and  atmospheric  sources. 
However, pollution persists in river plumes and in some coastal areas. The results for 
marine litter are similarly mixed: the volume of marine litter remains high but it has 
fallen.  The  volume  of  litter  on  beaches  is  also  falling  but  seafloor  litter  remains 
widespread,  mainly  litter from  fisheries and plastic materials. Noise pollution  is a 
growing concern. 

-  Despite undeniable progress in reducing overfishing since 2003 (38), the impacts of 
fisheries and other human activities on biodiversity are still deeply concerning. All 
assessments  of  the  main  components  (marine  birds,  mammals,  fish,  benthic  and 
pelagic habitats) and food webs show declines in biodiversity, despite progress made 
in identifying and addressing pressures. In particular, the condition of marine birds 
has deteriorated since the last assessment in 2017. 

-  Climate change and ocean acidification are driving major changes that imperil much 
of the North-East Atlantic’s marine biodiversity. Due also to other ongoing forms of 
human pressures, overall, marine ecosystems are losing resilience to climate change. 

The conclusions of the Quality Status Report make two findings clear:  

1)  additional measures are needed to change the current trajectory;  
2)  the measures taken so far need to be implemented more effectively. 

(37) See https://oap.ospar.org/en/ospar-assessments/quality-status-reports/qsr-2023/. 
(38)  “In 2003, average fishing mortality in the North-East Atlantic was 53% above the FMSY target. The 
latest assessment shows that the mortality rate has progressively fallen to reach 42% below the FMSY in 
2022” Commission Communication on Sustainable fishing in the EU: state of play and orientations for 
2025, as above. 

7 

 
 
 
 
•  Black Sea Basin 

No regional assessment is available for the Black Sea but there is some data available, 
mainly  covering  the  2016-2021  period,  from  the  EU-funded  EMBLAS  project ( 39 ), 
supplemented by analyses carried out by the Commission’s Joint Research Centre. 

-  On  pollution,  observations  confirm  that  all  Black  Sea  areas  contain  marine  litter, 
mostly plastic and microplastic litter. The data indicate that Black Sea beaches are 
the most littered in Europe and have the highest rate of single use plastics (652 litter 
items per 100 m). The sea remains contaminated by heavy metals, PAHs and certain 
pesticides and the PFOS concentration exceeds the safe limit. Indeed a 2021 scientific 
survey  revealed  that  the  cumulative  pollution  of  the  Black  Sea  with  chemical 
contaminants was approximately 3 to 8 times higher compared to the Mediterranean 
Sea and 2 to 7 times higher than in the North-East Atlantic (40). Some coastal regions 
appear to be in GES for eutrophication, but most of the central eastern deep-water 
parts were not in GES in 2019 due to phytoplankton bloom and high concentrations 
of pollutants. 

-  On biodiversity, the biomass levels of several fish and shellfish species has clearly 
fallen between 1995 and 2021, some quite dramatically (e.g. whiting, picked dogfish, 
anchovy or the gastropod Rapana venosa). Coastal and shelf waters were assessed to 
be  in  GES  for  phytoplankton  biodiversity,  but  open  waters  were  not.  In  addition, 
environmental  conditions  deteriorated  between  2016  and  2019  in  the  ‘Zernov’s 
Phyllophora Field’ marine reserve, which is the Black Sea’s largest marine protected 
area located in Ukrainian waters. Recent surveys have also noted possible invasive 
species migrating into the Black Sea (41). 

-  On  climate  change,  scenarios  show  an  increase  in  water  temperature  and  other 
changes that will alter the transport and dispersion of nutrients and pollutants in the 
Black Sea (42) and increase pollutant accumulation in the eastern basin (43). 

The environmental effects of Russia’s war of aggression towards Ukraine have had far-
reaching and transboundary impacts on the Black Sea. These impacts stem from mines 
and other explosives, oil spills and emissions of toxic substances, pollutants, and plastics 
due to the destruction of ports and ships, as well as pollution carried by rivers into the 
sea. Although long-term monitoring is very difficult because of the ongoing hostilities, 
there is clear evidence that these damages have negative impacts on biodiversity, habitats 
and species including marine mammals and fish stocks.  

The  breach  of  the  Kakhovka  Dam  in  June  2023,  in  particular,  has  had  unprecedented 
environmental consequences for the South of Ukraine, extending to the larger Black Sea 
region. All chemical pollutants were at significantly higher concentrations at all sampling 
points  after the dam  destruction in  2023 compared to  2020. In addition,  the  2000-fold 

(39) Slobodnik, J., Arabidze, M., Mgeladze, M., Korshenko, A., Mikaelyan, A., Komorin, V., Minicheva, 
G., 2020, EMBLAS Final Scientific Report– Joint Black Sea Surveys 2016-2019. 
(40)  2021 scientific survey of the North-East Atlantic, Mediterranean and Black seas titled “The Cruise 
of Three European Seas carried out in the framework of the EU4EMBLAS project with JRC support.  
(41)  2021 scientific survey of the North-East Atlantic, Mediterranean and Black seas.  
(42) Miladinova, Svetla, et al., 2020, ‘Seasonal and Inter-Annual Variability of the Phytoplankton Dynamics 
in the Black Sea Inner Basin’ Oceans 1, No 4: 251-273. https://doi.org/10.3390/oceans1040018; Macias, 
D., et al., 2022, Water/marine zero pollution outlook: a forward-looking, model-based analysis of water 
pollution in the EU. Luxembourg. https://doi.org/10.2760/681817. 
(43) Miladinova, S., et. al., E. 2020 ‘Identifying distribution and accumulation patterns of floating marine 
debris in the Black Sea’, Marine Pollution Bulletin, 153, 110964, doi:10.1016/j.marpolbul.2020.110964; 
Macias, D., et al., 2022. as above. 

8 

 
 
increase in blue-green algae phytoplankton led to the death of 40% of one of the Black 
Sea  mussel  populations ( 44).  Although  recovery  is  already  happening,  the  long-term 
impacts  of  this  pollution  on  human  and  ecosystem  health  will  need  to  be  further 
investigated. 

3.  TACKLING THE TRIPLE PLANETARY CRISIS 

Since the marine waters in the European Union did not achieve good environmental status 
(GES) in 2020, Member States were expected to update their first MSFD programmes of 
measures to further tackle pressures and achieve GES as soon as possible. 

In  their  update,  the  17  Member  States  assessed  reported  2046  measures  covering  all 
marine regions, descriptors and pressures (45). Of these, only a third are new measures 
specifically  included  in  this  second  update,  the  vast  majority  merely  extending  the 
measures reported previously, with some modifications. Since GES was not achieved by 
2020, more new measures could have been expected. 

Almost  half  of  the  measures  reported  are  designed  to  achieve  or  maintain  GES 
specifically under the MSFD. This is a substantial increase since the first programmes of 
measures, where only a quarter of the measures were ‘MSFD-specific’ (46). The remaining 
measures  stem  from  requirements  under  other  pieces  of  EU  law,  RSCs,  international 
agreements or national legislation.  

In  the  second  programmes  of  measures,  almost  50%  of  the  measures  are  designed  to 
directly prevent further pressures, reduce existing pressures or restore species or habitats. 
Over 35% of the measures are designed to indirectly contribute to those objectives (e.g. 
through  governance  mechanisms,  financial  incentives  or  awareness  campaigns). 
Measures linked to knowledge improvement make up approximately 15% of the total. 

The measures reported cover all the different types of pressures relevant to the EU marine 
environment (47). Litter and contaminants are the most frequently tackled pressures, each 
the subject of almost 30% of the measures. Over 20% of the measures tackle disturbance 
and extraction of species and eutrophication. Over 10% tackle noise, seabed disturbance 

(44)  Consequences of the Kakhovka hydropower plant dike explosion for the Black Sea: new data – 
EMBLAS project 
(45) For an in-depth analysis of the information on the updated programmes of measures that has been 
electronically reported by the 17 Member States, see: European Commission, Joint Research Centre: 
Louropoulou, E., Alonso Aller, E., Cardoso, A.C., Carravieri, A., Druon, J., Magliozzi, C., Martini, E., 
Mendes, C., Palma, M., Piroddi, C., Ruiz-Orejón, L.F., Zupan, M. and Hanke, G., Programmes of 
Measures under the Marine Strategy Framework Directive to achieve or maintain Good Environmental 
Status, Publications Office of the European Union, Luxembourg, 2024, JRC139180. 
(46) Report from the Commission to the European Parliament and the Council  assessing Member States’ 
programmes of measures under the Marine Strategy Framework Directive, Brussels, 31.7.2018 COM(2018) 
562 final. 
(47) Measures also cover all the descriptors of Good Environmental Status of Annex I to the MSFD. Over 
30% of measures are related to biodiversity (Descriptor 1), 28% to seafloor integrity (Descriptor 6), 24% 
to contaminants (Descriptor 8) and 22% to marine litter (Descriptor 10). The descriptors least frequently 
associated  to  measures  are  hydrographical  conditions  (Descriptor  7  –  8%),  contaminants  in  seafood 
(Descriptor 9 – 9%), non-indigenous species (Descriptor 2) and underwater noise (Descriptor 11) at 10% 
each.  Biodiversity  descriptors  (1-4-6)  are  best  covered  because  any  measure  taken  to  reduce  a  certain 
category of pressure, for instance eutrophication or contaminants, will also have an impact on the state of 
marine biodiversity. 

9 

 
 
 
and  non-indigenous  species  and  less  than  10%  of  the  measures  tackle  other  forms  of 
energy, adverse effects on species and habitats and hydrographical changes (Figure 1). 

Figure 1. Share of measures in the second programmes of measures tackling pressures 
on marine ecosystems 

However, this statistical analysis does not give an insight into how effective the proposed 
measures  are.  Despite  many  measures  being  taken  to  tackle  chemical  and  nutrient 
contamination, Member States action still falls short of what is needed to substantially 
reduce pollution and ultimately to achieve good environmental status. 

3.1 TOWARDS ZERO POLLUTION IN THE SEAS AND OCEAN 

Reducing water pollution is a key dimension of the EU Green Deal and the zero pollution 
action plan. Pollution is one of the five main threats to biodiversity (48). 

Based on the data reported by the Member States under Article 8 of the MSFD in 2018 
(49),  80%  of  the  EU's  sea  area  failed  to  meet  GES  for  contamination  by  ubiquitous, 
persistent, bio-accumulative and toxic substances, such as mercury. 87% failed to achieve 
GES for eutrophication, 90% for litter and 97% for continuous underwater noise. 

Over  the  past  few  years,  the  Commission  has  tabled  several  proposals  to  tackle  water 
pollution,  most  recently  to  revise  the  Urban  Wastewater  Treatment  Directive,  the 
Industrial Emissions Directive and to update the list of water pollutants under the Water 
Framework  Directive.  The  adoption  in  2020  and  2022  of  threshold  values  under  the 
MSFD for litter (50) and noise (51) is also an important step towards better management 
of ocean pollution. 

(48)  Report from the Commission, First ‘zero pollution’ monitoring and outlook, ‘Pathways towards 
cleaner air, water and soil for Europe’, COM(2022) 674 final, Brussels, 8.12.2022. 
(49)  WISE Marine: https://water.europa.eu/marine. 
(50) EU Member States agree on threshold value to keep Europe’s beaches clean - European Commission 
(europa.eu). 
(51) Zero pollution and Biodiversity: First ever EU-wide limits for underwater noise - European 
Commission (europa.eu). 

10 

 
 
 
 
This  section  covers  the  four  major  categories  of  pollution  affecting  the  marine 
environment:  marine  litter  (Descriptor  10),  eutrophication  (Descriptor  5),  harmful 
contaminants (Descriptors 8 & 9) and underwater noise (Descriptor 11). 

Figure  2.  Adequacy  of  Member  States’  second  programmes  of  measures  to  tackle 
pollution 

On  average,  Member  States’  measures  only  partly  tackle  the  issues  needed  to  reduce 
pollution (Figure 2). While the measures put in place to reduce marine litter go in the right 
direction, the measures to tackle eutrophication, chemical contamination and underwater 
noise are still insufficient. 

Marine litter (Descriptor 10) 

Overall, the quality of the measures to tackle marine litter improved between the 
two cycles. 

An analysis confirms the positive trend seen over the past few years on action to tackle 
marine litter. 22% of all the measures reported by Member States are related to Descriptor 
10 – marine litter – and a quarter are additional to existing legal obligations. 

The  measures  cover  the  main  sources  of  litter  input,  starting  with  activities  related  to 
sewage  from  urban  areas  and  other  land-based  sources  (e.g.  industry  and  agriculture). 
Riverine input is also identified as one of the main sources of pollution. Measures also 
cover sea-based sources. Several measures directly tackle litter from fisheries (including 
ghost nets), including clean-up actions and actions to prevent further input (based on the 
requirements  of  the  Port  Reception  Facilities  Directive  and  the  Single  Use  Plastics 
Directive). Shipping, recreational activities and tourism are also major sources of litter, 
and aquaculture to  a lesser extent. Litter from maritime transport is mainly  tackled by 
initiatives related to the IMO, MARPOL and the Port Reception Facilities Directive. 

11 

 
 
 
Only  a  few  Member  States  have  identified  marine  pollution  hotspots,  despite  the 
Commission's  recommendation  to  do  so  in  its  2018  assessment  (52).  Gaps  remain  in 
tackling micro-litter, litter on the seafloor and in the water column and impacts on marine 
life. Although Mediterranean Member States have clear targets related to litter impacts 
on Caretta caretta turtles, none have yet reported measures to directly tackle the problem. 
Almost all Member States recognise the value of regional cooperation and the work done 
in the context of the RSCs. 

Good examples 

Some Member States have taken specific measures to tackle micro-litter, including developing 
containment systems, purification plants or treatment of stormwater and wastewater specifically 
targeting micro-litter and microplastics. 

Eutrophication and contaminants (Descriptors 5, 8 and 9) 

Overall,  there  has  been  progress  in  developing  measures  to  further  reduce  both 
organic and chemical pollution, but more action is needed. 

Action  to  combat  eutrophication  and  contamination  by  hazardous  substances  remains 
insufficient (53). Member States have included many measures related to Descriptor 8 – 
contaminants  (24%),  Descriptor  5  –  eutrophication  (18%)  and,  to  a  lesser  extent, 
Descriptor  9  –  contaminants  in  seafood  (9%).  They  often  link  these  measures  to  the 
updated RBMPs, though make a limited assessment of their effectiveness in achieving 
GES.  

There is less consistent action planned to tackle pollution from airborne emissions, despite 
a wealth of legislation on air quality and emissions, notably under EU law governing the 
energy, industry and transport sectors, the Ambient Air Quality and the National Emission 
Reduction Commitments Directives. However, Member States have included measures 
to further regulate contamination from shipping linked to implementation of MARPOL 
or IMO agreements (e.g. environmentally friendly anti-fouling, emission controls, cleaner 
ship concepts), with expected positive impacts, notably in offshore areas. 

Member States still find it challenging to tackle pollution from emerging substances (e.g. 
pharmaceuticals)  and  to  remedy  the  legacy  impacts  from  persistent  contaminants  (e.g. 
mercury).  However,  there  are  good  practices  to  tackle  contamination  from  sea-based 
sources (e.g. managing contaminants from wrecks, phasing out the use of lead in fishing 
gear, tracking and recovering lost containers) and eutrophication (e.g. by using recycled 
manure in biogas production). Finally, as EU rules on maximum levels of contaminants 
in foodstuffs were updated in 2023 to cover a broader range of heavy metals and persistent 
organic  substances  (54),  achieving  GES  for  seafood  contamination  is  likely  to  require 
additional measures in future. 

(52)  Commission staff working document accompanying the document Report from the Commission to 
the European Parliament and the Council assessing Member States’ programmes of measures under the 
Marine Strategy Framework Directive, Brussels, SWD(2018) 393 final, 31.7.2018, p33. 
(53)  On average, measures for Descriptors 5, 8 and 9 are considered to be moderately adequate. 
(54)  Commission Regulation (EU) 2023/915 of 25 April 2023 on maximum levels for certain 
contaminants in food and repealing Regulation (EC) No 1881/2006. 

12 

 
 
 
Good examples 

Healthy marine habitats can play a crucial role in reducing the adverse effects of eutrophication. 
Some Member States are increasingly using nature-based restoration measures for habitats 
such as blue mussel beds, seagrass beds and saltmarshes to tackle eutrophication.  

Underwater noise (Descriptor 11) 

Overall, Member States’ measures to reduce underwater noise have improved, but 
they are still focused on knowledge gathering rather than on reducing pressures. 

Due to the lack of legal frameworks covering underwater noise, the MSFD has generated 
many new measures to tackle this form of pressure but they are still insufficient to reach 
GES and the set targets (55), both in quantity (only 10% of all measures) and in quality. 

Compared to the first programmes, the measures give a better coverage of sources and 
types  of  pressure,  but  remain  mostly  focused  on  knowledge  gathering  rather  than  on 
having a direct impact on reducing the pressure. 

To improve their knowledge on underwater noise, Member States mainly base their action 
on regional level frameworks and on EU-funded projects. Only a few Member States have 
designed specific measures based on the outcomes of these projects, such as setting speed 
limits near sensitive areas or during sensitive times. The most targeted measures tackle 
offshore  and  coastal  infrastructure  construction,  either  by  limiting  noise  levels  or  by 
including underwater noise in environmental impact assessment studies. Setting threshold 
values for maximum levels of impulsive and continuous noise in October 2022 should 
support the design of more and better measures in the next cycle. 

Other forms of energy (e.g. electromagnetic, light and heat) are still not well addressed, 
except for a few ad hoc  measures looking into the potential effects of electromagnetic 
fields on vulnerable habitats or monitoring light pollution. 

Good example 

One Member State optimises shipping approach routes during the construction or maintenance 
of offshore wind farms or other offshore infrastructure to avoid high levels of continuous noise 
in vulnerable areas functioning as biodiversity hotspots. 

3.2 BRINGING MARINE NATURE BACK INTO OUR LIVES 

Europe’s seas host a wide and highly diverse range of coastal and marine ecosystems with 
a great variety of habitats and species (56). If in good condition, they provide our societies 
with vital services, including food, energy, clean air and climate change mitigation (57). 
Pressures that impact marine biodiversity and ecosystems weaken the planet's ability to 
function  healthily  and  to  provide  the  essential  services  we  rely  on  for  survival  and 

(55) On average, measures for Descriptor 11 are considered to have a moderate level of adequacy. 
(56) State of Europe’s seas – European Environment Agency (europa.eu). 
(57) Europe’s marine biodiversity remains under pressure – European Environment Agency (europa.eu). 

13 

 
 
 
 
prosperity. As demands on the ocean increase, ensuring the continued availability of these 
services becomes even more crucial. 

The  EU  has  stepped  up  its  commitment  to  protect  marine  biodiversity.  The  EU 
biodiversity strategy for 2030 (58) requires to legally and effectively protect 30% of our 
seas, a third of which under strict protection. Through its Mission “Restore our Ocean 
and Waters by 2030” (59), the EU is aiming to bring concrete solutions to the challenges 
faced by our seas and ocean today, by putting research and innovation into a new role, 
combined  with  new  forms  of  governance  and  collaboration,  as  well  as  by  engaging 
citizens. At global level, these commitments are echoed by the adoption of two historic 
agreements: the 2022 Global Biodiversity Framework at the Convention on Biological 
Diversity COP 15 (60) and the 2023 Treaty on the conservation and sustainable use of 
marine biological diversity of areas beyond national jurisdiction (BBNJ Treaty) (61). 
The 2023 adoption of the  marine  action  plan (62)  also  contributes  to  the work to  meet 
these  objectives  by  calling  on  Member  States  to  take  action  to  reconcile  fishing  with 
environmental  protection  objectives,  notably  by  improving  gear  selectivity,  tackling 
bycatch of sensitive species, protecting the seabed and action to support the transition and 
knowledge exchange. 
The threshold values set under the MSFD in 2023 for seabed loss and damage (63) are 
also an important step towards better management of ocean natural resources. 

Nonetheless,  GES  is  far  from  being  achieved  for  the  biodiversity  descriptors.  For 
example, only 3% of cetaceans (such as dolphins and porpoise), only 15% of whales and 
seabed habitats and just 29% of pelagic-feeding birds in European marine waters were 
assessed by Member States as being in GES at the start of the Directive’s second cycle of 
implementation. 

This section covers the measures taken to protect species, habitats and food webs against 
non-pollution  forms  of  pressure  such  as  disturbance,  extraction  and  non-indigenous 
species.  It  is  linked  to  Descriptors  1  (biodiversity),  2  (non-indigenous  species),  3 
(commercial  fish  and  shellfish),  4  (food  webs),  6  (seafloor  integrity)  and  7 
(hydrographical conditions). 

Overall, progress in designing and implementing effective MSFD measures to protect and 
restore  biodiversity  has  been  rather  limited  since  the  first  programmes  of  measures 
(Figure 3). However, the measures taken to protect the seafloor have improved, mainly 
by  better  tackling  mobile  bottom-contact  fishing,  and  progress  has  also  been  made  in 
tackling non-indigenous species and changes to hydrographical conditions. 

The lack of a comprehensive gap analysis has limited the Commission’s assessment of 
the  biodiversity  measures.  Strong  gap  analyses  give  a  better  understanding  of  how 
existing measures contribute to achieving GES and what additional measures are needed. 

(58) Communication from the Commission, EU Biodiversity Strategy for 2030 Bringing nature back into 
our lives, COM(2020) 380 final 
(59)  https://research-and-innovation.ec.europa.eu/funding/funding-opportunities/funding-programmes-
and-open-calls/horizon-europe/eu-missions-horizon-europe/restore-our-ocean-and-waters_en  
(60)Kunming-Montreal Global Biodiversity Framework (cbd.int). 
(61) Intergovernmental Conference on Marine Biodiversity of Areas Beyond National Jurisdiction | 
(un.org). 
(62)  Communication from the Commission, EU Action Plan: Protecting and restoring marine ecosystems 
for sustainable and resilient fisheries, COM(2023) 102 final 
(63) EU Green Week: first ever EU-wide criteria for seabed protection - European Commission 
(europa.eu) 

14 

 
 
Figure  3.  Adequacy  of  Member  States’  second  programmes  of  measures  to  tackle 
biodiversity issues 

General measures for biodiversity (Descriptors 1, 4 and 6) 

Overall, there has been only limited progress in the measures for biodiversity. 

Most if not all of the measures taken by Member States are likely to have an effect on the 
state of marine biodiversity, which is why the biodiversity descriptors are generally well 
covered by the programmes of measures (64). Measures to reduce pressures (65) will have 
direct positive effects on species and habitats and indirectly on the whole ecosystem and 
food webs. Additional measures can be taken specifically for the purpose of protecting 
and restoring biodiversity. 

The  most  common  measure  is  to  designate  marine  protected  areas  (MPAs),  either  to 
protect specific habitats  and species (often under the regime of the Birds and Habitats 
Directives)  or  to  restore  certain  ecosystem  functions  (e.g.  seafloor  integrity,  food  web 
health). The aim of MPAs is often to reduce levels of pollution, extraction or disturbance 
by regulating activities that have a negative impact on species and habitats. These can 
include  tourism  activities  (recreational  boating  and  water  sports),  fishing,  particularly 
with bottom-trawling gear and polluting activities either within or in the surrounding area. 
MPAs can have a significant impact on pressures, depending on their size, the degree of 
human activity restrictions and on whether effective management measures are in place. 

The  information  provided  by  Member  States  often  contain  scant  detail  on  the  type  of 
management measures and the size and the location of the MPAs, making it difficult to 
ascertain how they contribute to the targets of the EU biodiversity strategy. 

(64)  31% of all measures are linked to Descriptor 1 – biodiversity, which is the highest share among all 
descriptors; 28% are linked to Descriptor 6 – seafloor integrity, and 19% to Descriptor 4 – food webs. 
(65)  Such as those designed for the purpose of the MSFD pressure descriptors. 

15 

 
 
 
 
Good example 

Currently, MPAs cover only 12% of European waters; they range from ‘multi-use MPAs’, where 
most  human  activities  are  allowed  and  the  level  of  effective  protection  is  low,  to  ‘strictly 
protected’  MPAs  which  allow  very  few,  if  any,  human  activities.  Where  active  restoration  of 
habitats is planned such as reef reconstruction or the recovery of oyster beds, Member States 
also restrict or even ban human activities that are damaging to these habitats. 

Measures for species, including commercial species (Descriptors 1 and 3) 

Overall,  there  has  been  only  limited  progress  in  the  measures  planned  to  tackle 
species, including commercial fish and shellfish species. 

Species-specific  measures  tend  to  focus  on  fish,  marine  mammals  and  seabirds,  while 
measures  for  cephalopods  (e.g.  octopus  and  squids),  marine  reptiles  (e.g.  turtles)  and 
pelagic  species  (e.g.  plankton)  are  rarer.  The  activity  reported  by  Member  States  as 
causing most pressure on marine species, especially from incidental bycatch for seabirds 
and  mammals,  is  commercial  fishing.  Measures  to  reduce  bycatch  focus  on  adapting 
fishing gear, training fishers to improve recording and avoidance of bycatch incidents, 
and increased monitoring of fishing activities. These measures typically fall in the scope 
of the Technical Measures Regulation (66), which supports the objective of the MSFD in 
terms of species and habitats protection. Some Member States also regulate bycatch inside 
MPAs by making use of the scope under the common fisheries policy to propose joint 
recommendations with neighbouring countries for spatial fisheries measures (67). 

Measures for turtles are rare, except for a few direct measures involving the training of 
fishers to avoid bycatch and the risk of vessel collision. Measures for cephalopods are 
non-existent; they are commonly bundled together with fish species. 

Commercial and non-commercial fish and shellfish are covered by measures to reduce 
fishing  pressure.  Most  measures  are  linked  to  the  CFP  to  ensure  that  populations  are 
fished at levels that are sustainable over the long term. Some Member States also cover 
nationally managed local/in-shore stocks. To some extent, they cover recreational fishing, 
but not sufficiently. Half of the Member States have also reported measures to tackle the 
requirement for healthy age and size distribution of fish populations (68), for example by 
reducing the catch of juvenile fish or updating regulations on mesh sizes. Obstacles in the 
migratory  corridors  of  fish  are  also  reported  as  major  threats  to  the  health  of  fish 
populations. 

Good example 

One  country  has  taken  a  measure  to  reduce  blockages  to  fish  migratory  corridors  by  using 
acoustic monitoring, removing old barriers or re-opening migratory pathways and stimulating 
fish populations in estuarine/coastal areas. 

(66) The Technical Measures Regulation (EU) 2019/1241 on the conservation of fisheries resources and 
the protection of marine ecosystems through technical measures. 
(67) Common Fisheries Policy Regulation (EU) 1380/2013, Article 11 on ‘Conservation measures 
necessary for compliance with obligations under Union environmental legislation’. 
(68) As per criterion D3C3 of Commission Decision (EU) 2017/848. 

16 

 
 
 
Measures for habitats (Descriptors 1 and 6) 

Overall, some progress has been made on measures for seabed habitats, in particular 
by reducing the seabed harm caused by mobile bottom-contact fishing methods, but 
action on water column habitats remains overlooked. 

By nature, all forms of biological, physical, and substance input pressures have an impact 
on seabed habitats and seafloor integrity, whether directly or indirectly. In addition to all 
the measures taken under other descriptors, Member States have taken measures clearly 
focused on the physical  preservation of the seafloor, including reducing  pressure from 
human  activities  on  seabed  habitats,  designating  seabed-focused  MPAs  and  actively 
restoring  habitats  and  the  biological  communities  associated  with  them  (e.g.  restoring 
oyster reefs and Posidonia meadows and planting Zostera beds). 

Most Member States identified mobile bottom-contact fishing as the main threat to the 
health of seabed habitats. Some  have adopted measures to  reduce its harmful impacts, 
either covering large areas or specifically for vulnerable habitats.  

The Member States also regulate other activities causing physical pressure on the seabed, 
such  as  anchoring  in  the  Mediterranean,  which  is  a  particular  threat  to  Posidonia 
meadows, lost fishing gear and sand dredging. Despite growing pressure from offshore 
wind  energy  infrastructure,  including  cables,  only  a  few  Member  States  tackle  the 
pressure  caused  by  wind  energy  installation.  Measures  include  mapping  vulnerable 
seabed habitat  types, for example. The adoption  in  March 2023 of EU-wide threshold 
values  for  the  maximum  extent  of  adverse  effects  and  loss  on  seabed  habitats  should 
support the design of even more effective measures for seafloor integrity in the next cycle. 

Water column habitats are still largely overlooked under the biodiversity descriptors but 
they are covered by measures to reduce pollution levels in the water column. 

Good example 

Reducing  the  trawl-swept  area  in  national  waters  and  promoting  lower  impact  and  more 
selective gear for the whole fleet are examples of the measures taken by some Member States 
to help protect seabed habitats outside of MPAs.  

Measures for food webs (Descriptor 4) 

Overall, no noticeable progress has been made on measures for marine food webs; 
action on species and seabed integrity would drive improvements to food webs. 

The MSFD requires that marine food webs are healthy, meaning that all living organisms 
in  the  given  marine  environment  are  in  balance  and  capable  of  achieving  long-term 
abundance  and  reproductive  capacity.  Human  activities  can  affect  the  balance  of  this 
intricate relationship, for example by removing too many forage fish and making it more 
difficult for their predators to find food. 

There  are  very  few  examples  of  practical  direct  measures  taken  by  Member  States  to 
safeguard the health  of  marine food  webs. Most measures  linked to  food  webs aim to 
protect  biodiversity  in  general,  such  as  designating  or  expanding  MPAs,  or  species-
specific measures  such as preventing bycatch. While these measures are important  for 

17 

 
 
 
maintaining populations of certain species, and thus the local food web, they have only 
an indirect impact on the overall food web health. 

Good example 

Examples of measures taken by some Member States for food webs include restricting fishing 
of a certain trophic group (e.g. of all predatory or forage fish) or of certain commercial species 
that play a particularly important role in the food web, or reducing fishing levels overall. 

Measures to reduce other non-pollution pressures on biodiversity (Descriptors 2 and 7) 

Overall,  progress  has  been  made  in  identifying  suitable  measures  to  tackle  non-
indigenous  species.  However,  few  Member  States  have  made progress  in  tackling 
changes to hydrographical conditions. 

Most of the measures to reduce the threats to biodiversity stemming from non-indigenous 
species relate to  implementation  of the  IMO  Ballast Water Convention,  as  shipping  is 
widely recognised by Member States as the main introduction pathway. Aquaculture is 
also identified as a growing introduction pathway, and some Member States have taken 
early detection measures by monitoring aquaculture hotspots. Recreational boating and 
angling are also increasingly covered by preventive measures. 

Permanent changes of hydrographical conditions, such as water temperature or salinity, 
can  also  impact  marine  biodiversity  by  disturbing  water  column  habitats  and  the 
environmental conditions  in  which  marine  species live,  feed and reproduce.  The main 
direct measures taken by Member States to prevent some of these changes, in particular 
in coastal areas, are linked to the WFD RBMPs. They include, for instance, controlling 
the  freshwater  and  sediment  flow  from  rivers  into  the  sea.  Indirect  measures  include 
ensuring that strategic environmental assessments and environmental impact assessments 
cover  these  impacts  or  using  maritime  spatial  planning  to  better  plan  and  control 
cumulative effects potentially leading to alterations of hydrographical conditions. Climate 
change is also significantly affecting hydrographical conditions (see details below). 

Good example 

Innovative  measures  taken  by  certain  Member  States  include  developing  a  forward-looking 
vision to develop large-scale activities (e.g. offshore energy production sites and aquaculture). 
Based on these future scenarios, spatial planning of human activities at sea can be designed 
to manage future cumulative impacts and ensure they do not prevent the achievement of GES.  

3.3 TACKLING THE CLIMATE CRISIS 

2023 was the warmest year ever recorded in many parts of the northern hemisphere (69). 
As a result, most basins in the Atlantic Ocean have been warmer than average, especially 

(69)  State of the Global Climate 2023. 

18 

 
 
 
 
in  Europe ( 70).  The  European  Climate  Risk  Assessment  report  ( 71)  confirms  that  all 
European seas are heavily affected by climate risks and anthropogenic pressure. 

The latest Intergovernmental Panel on Climate Change report on the ocean and cryosphere 
in a changing climate (72) indicates that the ocean is warming, acidifying and suffering 
from deoxygenation. The growing trajectory of this ‘deadly trio’ will reduce the ocean’s 
ability to absorb carbon dioxide and preserve life on the planet. 

In  a  recent  ruling,  the  International  Tribunal  for  the  Law  of  the  Sea  under  the  UN 
Convention on the Law of the Sea clarified that ‘anthropogenic GHG emissions into the 
atmosphere constitute pollution of the marine environment within the meaning of Article 
1, paragraph 1, subparagraph 4 of the UN Convention’ (73). With this ruling, the Tribunal 
directly links countries’ efforts to reduce greenhouse gas emissions in the atmosphere (and 
thus fight climate change) with action to tackle pollution of the marine environment, in 
the UNCLOS context. This decision should also be read in the MSFD context, requiring 
Member States to tackle pollution of the marine environment. 

It is therefore necessary to act and take measures to support the ocean-climate nexus. In 
particular, the ocean can help mitigate climate change by: 

•  Preserving the capacity of the oceans to act as carbon sinks. Healthy coastal and 
marine ecosystems ensure the oceans maintain their capacity to store carbon. 
•  Reducing greenhouse gases emissions by developing ocean renewable energy and 

greening blue economy sectors. 

Addressing climate change through the MSFD 

Overall, although the MSFD does not directly tackle it, many Member States have 
taken climate adaptation measures, e.g. supporting coastal communities, and some 
have taken climate mitigation measures, e.g. restoring blue carbon ecosystems. 

To date, climate change is neither explicitly covered by an MSFD descriptor nor listed as 
a form of pressure. Climate change is however mentioned in the Directive and the holistic 
marine  strategies  provide  a  good  framework  to  monitor  climate  change  impacts  and 
explore climate change mitigation. This approach was confirmed by the assessment made 
for  the  previous  cycle,  where  Member  States  highlighted  that  the  impacts  caused  by 
climate change and ocean acidification are important transboundary issues tackled under 
MSFD monitoring programmes (74). 

As  climate  change  is  a  concern  for  all  marine  regions  and  a  growing  pressure  on  the 
marine environment, several Member States now consider it a frontline issue: 4% of all 
measures (84 measures from 15 Member States) are directly related to climate change. 

Most  climate-related  measures  concern  adaptation  or  resilience,  i.e.  reducing  climate 
change  impacts  or  supporting  communities  in  addressing  and  recovering  from  future 
deteriorations. One third is related to mitigation, i.e. reducing and preventing greenhouse 
gas emissions, including action to restore blue carbon ecosystems. 

Many  important  measures  stem  from  work  under  the  RSCs,  others  from  the  Member 
States’ national energy and climate plans or national climate adaptation strategies. 

(70)  The European heatwave of July 2023 in a longer-term context | Copernicus. 
(71)  European Climate Risk Assessment – European Environment Agency (europa.eu). 
(72)  AR6 Synthesis Report: Climate Change 2023 – IPCC. 
(73)  https://www.itlos.org/fileadmin/itlos/documents/press_releases_english/PR_350_EN.pdf. 
(74) Report on the implementation of the Marine Strategy Framework Directive (europa.eu). 

19 

 
 
 
Good example 

By quantifying the carbon sequestered by seagrass meadows and macroalgae forests, some 
Member States identify carbon hotspots in their waters and ensure that economic activities do 
not threaten them or, on the contrary, contribute to their restoration. 

4.  ENSURING SOCIO-ECONOMIC SOUNDNESS 

Overall, Member States  now have a greater  understanding of the socio-economic 
impacts of MSFD measures. Still,  fewer than half indicate the level of investment 
needed and very few look into the social acceptability of the measures proposed. 

Almost all Member States performed a cost-benefit and/or a cost-effectiveness analysis 
on their measures, and some followed up with a categorisation of the least cost-effective 
measures. Only a few explained how these analyses influenced the selection of measures, 
for instance by prioritising certain measures over others. A few Member States from the 
Baltic region made a quantitative comparison between the costs of their programmes of 
measures  and the benefits (achieved or potential) of improving the state of the marine 
environment. 

Fishing and shipping are the two activities/sectors reported as being most impacted by 
MSFD  measures.  Only  two  Member  States  also  looked  at  how  their  programmes  of 
measures  would  affect  social  issues  and  human  well-being.  One  Member  State 
investigated whether each individual new measure could be expected to have a positive, 
negative or no impact on local communities, traditions, cultural heritage, employment and 
health. 

The proposed MSFD measures covering the 2022-2027 period have been estimated at an 
average cost of EUR 724 per km2 of marine area per year. Based on this data, the cost of 
MSFD measures for all EU marine waters can be estimated at EUR 5.8 billion per year 
(75). Based on Member States’ reporting of the share of their measures that are specific to 
the  MSFD  (42%),  the  cost  of  MSFD-specific  measures  for  all  EU  marine  waters  is 
estimated at EUR 2.4 billion per year. 

Almost all Member States mobilise a mix of national and EU funds, with some Member 
States listing EU funds for 50-80% of their measures. EU funds most often mentioned are 
EMFF/EMFAF, LIFE and Horizon Europe. Over half of the Member States also mention 
mobilising private finance, either as costs to the private sector to follow the measures that 
are implemented (e.g. as a capital investment) or as funding provided by environmental 
foundations to implement the MSFD measures. 

5.  GOVERNANCE AND REGIONAL COOPERATION 

Designing a suitable programme under the MSFD requires not only identifying the right 
measures  to  help  achieve  GES  but  also  putting  in  place  a  governance  framework  to 
support their implementation. 

(75) Total km2 of marine waters of 22 EU Member States (7 958 556) * average cost of measures per km2 
(724) = EUR 5 764 104 242.96. Calculations are included in EUR. See more detailed calculations in the 
SWD accompanying this communication. 

20 

 
 
 
 
The  Commission  assessed  four  main  aspects  of  the  Member  States’  governance 
mechanisms:  involving  the  public,  coordinating  across  related  policy  fields,  regional 
cooperation and likelihood of implementation. 

to  support 
Member  States  have  put  governance  mechanisms 
implementation  of  the  programme  of  measures  but  coordination  with  other 
authorities and with neighbouring Member States is not always sufficient. Since the 
first  programmes  of  measures,  more  Member  States  have  expressed  a  clear 
commitment to the full implementation of their programmes of measures. 

in  place 

The  obstacles  identified  by  Member  States  include  financing  and  issues  related  to 
implementation at national level, reported by just a few Member States. Member States 
did  not  report  any  obstacles  to  implementation  for  almost  half  of  their  measures 
(48%) (76). 

Involving the public 

Overall, processes for involving the public seem adequate but the extent to which 
they use feedback to amend the programmes of measures is much less clear. 

Only  two  Member  States  did  not  mention  conducting  public  consultations  on  their 
programmes  of  measures.  Of  the  other  15,  a  quarter  reported  only  very  limited 
information  on  how  they  take  on  board  the  input  from  the  public  in  selecting  and 
designing the measures. The level of engagement was higher where the information about 
the consultation was provided using both traditional and social media.  

Feedback  could  be  provided  through different  means  including  direct  contact  with  the 
public  through  workshops,  seminars  and  stakeholder  meetings  in  addition  to  online 
consultations.  Only  four  Member  States  reported  setting  aside  time  to  handle  public 
feedback  using  a  comprehensive  methodology  and  amending  their  programmes  where 
appropriate. 

Cooperation with other authorities, policies and Member States 

Overall,  all  countries  cooperate  across  policy  areas  and  with  other  authorities, 
although  it  is  not  always  clear  what  the  outcome  of  this  cooperation  is.  Some 
countries  cooperate  more  closely  with  WFD  and  MSP  authorities,  including  by 
taking a joint approach to the design of measures. Regional cooperation plays an 
important role in the development of Member States’s programmes of measures in 
some regions, but the level of regional coherence of the measures remains moderate. 

All Member States make very clear links between their MSFD programmes of measures 
and the measures taken under other pieces of EU law, in particular the Habitats Directive, 
the Water Framework Directive and the common fisheries policy. 

This  is  in  line  with  the  finding  that  58%  of  the  measures  included  in  these  second 
programmes of measures are derived from other legal instruments (77). Most are linked to 
pollution-related frameworks (e.g. the WFD, the urban wastewater treatment directive, 
the  waste,  chemicals  and  agricultural  law,  the  Minamata  Convention  on  mercury), 

(76) See European Commission, Joint Research Centre: Louropoulou, E., et al., Programmes of Measures 
under the Marine Strategy Framework Directive to achieve or maintain Good Environmental Status, as 
above. 
(77)  For a more detailed analysis, see Figure 2 in SWD(2025) 1. 

21 

 
 
 
 
biodiversity-related  frameworks  (such  as  the  Birds  and  Habitats  Directives,  the  EU 
biodiversity strategy, the Convention on Biological Diversity) and fisheries and maritime-
related policies (e.g. maritime spatial planning, the common fisheries policy, International 
Maritime  Organization,  etc.).  Most  Member  States  also  refer  to  the  objectives  of  the 
biodiversity strategy, but rarely to the 30% and 10% targets set in the strategy. There are 
even fewer references to the zero pollution action plan, although the measures adopted 
under the MSFD to fight pollution are fully aligned with its objectives. 

Coordination with authorities in charge of implementing the Water Framework Directive 
and  the  maritime  spatial  planning  processes  are  most  often  mentioned  in  the  MSFD 
reports; less so in the WFD RBMPs. Only a few Member States elaborated on how they 
govern and coordinate between different policies and the outcomes of this coordination. 
For instance, one Member State explained that the authorities responsible for the MSFD 
and those responsible for WFD had drawn up a catalogue of measures common to the 
objectives of both laws  and that they update the catalogue in line with the MSFD and 
WFD implementation cycles (see also WFD report) (78). 

Regional coordination, in particular through the RSCs, is cited frequently throughout the 
programmes  of measures  and mentioned by all  17 Member States. They also describe 
coordination  mechanisms  with  neighbouring  countries  within  the  RSCs  and  make 
frequent references to action plans (e.g. the OSPAR regional action plan for marine litter 
or  the  Baltic  Sea  action  plan),  joint  initiatives  or  projects  in  the  individual  descriptor 
sections. Some Member States complemented this with further  contacts at subregional 
level,  for  instance  holding  trilateral  meetings  to  identify  common  issues related  to  the 
management of MPAs, marine litter and underwater noise in the Bay of Biscay. 

Despite  intense  and  time-consuming  coordination  within  the  different  regions,  it  is 
unsatisfactory  to  see  that,  on  average,  there  is  only  a  moderate  degree  of  regional 
coherence of the programmes of measures. Coherence is  particularly  poor  in  action to 
tackle contaminants in seafood (D9), hydrographical conditions (D7) and food webs (D4) 
in all three regions. Confirming the positive results achieved over this period, coherence 
is highest (moderate to high) in all three regions on marine litter (D10). 

Good example 

Support from the RSCs in developing the measures can play an important role. In the Baltic 
Sea, HELCOM’s Sufficiency of Measures tool (79), used by most Baltic Member States, has led 
not  only  to  a  higher  level  of  regional  coherence  but  also  to  a  higher  level  of  quality  of  the 
measures put forward by the individual Member States. 

Member States’ likelihood of implementing their programmes of measures 

Looking at a number of criteria (including how the Member State takes account of socio-
economic impacts, whether it has identified sources of financing, the level of coordination 
with key EU policies and the level of detail of implementation mechanisms) it is possible 

(78)  Report from the Commission to the Council and the European Parliament on the implementation of 
the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Third river basin 
management plans Second flood risk managment plans, COM(2025) 2 
(79)  https://helcom.fi/baltic-sea-action-
plan/som/#:~:text=The%20aim%20of%20the%20sufficiency,GES)%20in%20the%20Baltic%20Sea. 

22 

 
 
 
to group Member States according to the likelihood of implementing their programmes 
of measures (80) (Table 1). 

Table 1. Likelihood of implementation of Member States’ second programmes of 
measures 

Likelihood of 
implementation 

Member States 

Justification 

Highly likely or 
likely 

EE, LV, SE, PT, FI, 
FR, LT, ES, PL, IE, 
SI, DE and BE 

Moderately likely 

NL, RO and CY 

Not likely 

IT 

the 

impacts  of 

These  Member  States  made  a  sound  socio-
their 
economic  analysis  of 
identified 
programmes  of  measures,  clearly 
sources  of  funding  and  appear  to  have  actively 
coordinated  across different  authorities  involved 
in  implementing  the  measures.  Importantly,  it  is 
clear  how,  where  and  when  the  new  measures 
they proposed will be implemented.  

These Member States made a partial analysis of 
the  socio-economic  benefits  of  their  measures 
and investigated social issues to a limited extent. 
They listed sources of funding but did not allocate 
specific 
specific  measures. 
to 
Coordination  with  authorities  appears  more 
limited  or  superficial  and  it  is  also  less  clear 
where,  how  and  when  new  measures  will  be 
implemented. 

amounts 

This Member State provided little information on 
sources of funding and reported only a superficial 
socio-economic analysis  of  its  measures.  There 
is no sign of coordination between the MSFD and 
other EU  laws  or  it  has  not  been  reported.  It  is 
also  not  clear  where,  when  and  how  new 
measures will be implemented. 

The  Directive  also  enables  Member  States,  in  well-defined  circumstances,  to  apply 
exceptions  to  achieving  GES  (Article 14).  These  circumstances  include  the  fact  that 
achieving  such  goals  is  related  to  action  or  inaction  beyond  their  responsibility,  force 
majeure events, or the fact that natural conditions do not enable them to achieve a timely 
improvement in the status of their marine waters. 

As  shown  in  Figure  4,  12  of  the  17  Member  States  reported  exceptions  for  all  these 
possible reasons, except force majeure. Contaminants and eutrophication are the topics 
for which most Member States requested an exception, citing natural conditions that do 
not enable the timely improvement in the status of marine waters. Underwater noise is 
the only topic for which no exception was requested, and few exceptions were requested 
for food webs, hydrographical conditions and seafood contaminants, all topics that are 
currently not very well developed under the MSFD. 

(80) A more detailed explanation of the methodology used for this assessment is provided in the SWD 
accompanying this report. 

23 

 
 
Figure  4.  Exceptions  to  the  non-achievement  of  GES  as  reported  under  the  second 
programmes of measures 

6.  CONCLUSIONS AND OUTLOOK 

Member  States  have  done  an  impressive  work  in  identifying  and  tackling  the  highly 
complex and diverse nature of marine pressures  needed to  achieve  GES.  The share of 
measures  specifically  designed  for  the  MSFD  –  and  not  adopted  under  other 
frameworks – has increased from 25% to 42%, showing that the MSFD is a key driver 
of new measures to protect the marine environment and to use it sustainably. 

Despite this, further work is required to harmonise the development of measures as there 
are clear disparities across descriptors and Member States. On average across all 17 
Member  States,  only  measures  for  marine  litter  and  non-indigenous  species  are 
considered  to  tackle  to  some  extent  the  issues  needed  to  remedy  the  problems ( 81). 
Measures to tackle other forms of pollution, biodiversity loss and climate change are still 
considered insufficient, although progress has been made in some areas such as seabed 
protection and alterations to hydrographical conditions. 

Many measures stem from other legislative frameworks, such as EU law governing 
water,  nitrates  and  chemicals,  the  common  fisheries  policy  or  the  Birds  and  Habitats 
Directives. These frameworks do not have the same scope, however, and the MSFD sets 
out requirements for additional forms of environmental pressures (for instance, marine 
pollution in offshore areas, e.g. from fossil fuel production). This shows the need for 
more work to cover these gaps when designing MSFD measures.  

(81) Detailed explanations on the methodology and scoring of the adequacy assessment are included in 
SWD(2025) 1. 

24 

 
 
 
 
In  contrast,  Member  States  have  taken  better  measures  to  tackle  pressures  or 
impacts that are less well covered by other policies and legislation, with the exception 
of  underwater  noise  and  food  webs.  In  the  absence  of  a  ‘safety  net’  of  targeted  long-
standing legislation regulating the issue at EU level, overall Member States have been 
more  innovative  in  identifying  measures  for  non-indigenous  species,  hydrographical 
conditions,  seafloor  integrity  and  marine  litter.  They  still  use  existing  frameworks  but 
achieving GES for these topics requires Member States to think collectively about new 
approaches to tackle these problems. 

Measures  on  marine  litter  are  a  good  illustration  of  how  the  MSFD  can  make  a 
difference while working in synergy with other legislative frameworks. As a starting 
point, several Member States have been able to assess how far they are from achieving 
the GES objective, quantified through the recently agreed threshold value (82). Based on 
this,  they  designed  suitable  measures  to  close  the  gap,  including  references  to  other 
frameworks.  Not  only  are  the  measures  for  marine  litter  of  better  quality  than  the 
measures  for  other  topics,  but  they  are  also  more  regionally  coherent.  By  contrast, 
measures  on  underwater  noise  still  fall  short  of  expectations.  It  shows  that  success 
depends on many factors, including high public awareness and a solid data and knowledge 
basis, both of which are still lacking to some extent for underwater noise. 

For the main part, the measures are moderately coherent within a marine region. The 
degree of coherence is higher where tools have been developed to support the assessment 
of how far Member States are from GES and the measures needed to close the gap, for 
example through the work of HELCOM in the Baltic Sea. Of the seven Member States 
considered to have a good quality programme of measures, five share waters in the Baltic 
Sea region and have worked together in the framework of HELCOM. 

In  general,  the  approach  to  taking  measures  under  the  MSFD  still  requires  work  and 
effort.  In  particular,  it  remains  difficult  to  gauge  by  how  much  and  by  when  the 
measures will reduce the impact on the marine environment and help achieve GES. 
This is partly due to the lack of clearly quantified GES, and partly to a lack of suitable 
tools  and  methodologies,  including  modelling,  to  better  assess  the  action  needed  to 
achieve GES. Recent  developments  in  this  field  are encouraging  and should  continue. 
These issues will also be analysed further in the upcoming MSFD evaluation. 

7.  RECOMMENDATIONS 

Country-specific  recommendations  are  provided  in  the  staff  working  document 
accompanying this report (83). The following recommendations are applicable to all EU 
Member States: 

1.  Member  States  should  increase  the  level  of  ambition  and  accelerate  action  to 

achieve the objectives of the Directive. This involves: 

a.  developing  more  robust  programmes  of  measures  based  on  a  clearer 
assessment of the gap to be bridged to reach good environmental status; 
b.  designing quantitative measures that bridge the gap between the current status 
and good environmental status, as quantified by  the threshold values set at 

(82)  https://publications.jrc.ec.europa.eu/repository/handle/JRC121707 
(83)  SWD(2025) 1 

25 

 
 
EU, regional and subregional level and integrated into Member States’ marine 
strategies (84); 

c.  ensuring  that  measures  taken  under  other  legislation  and  policies  have  the 
right  ambition  level  to  contribute  to  the  achievement  of  GES,  or 
complementing them to cover issues that are needed for GES but are not part 
of existing frameworks. 

2.  Member States should identify and put in place, as appropriate, additional measures 
to  reduce  persistent  environmental  challenges  (pressure)  that  prevent  the 
achievement of good environmental status. 

a.  On pollution, this involves: 

i.  stepping up action to reduce underwater noise pollution, including by 
tackling the main sources of continuous noise – such as shipping – and 
by setting up low-noise areas for marine species; 

ii.  stepping  up  action  to  reduce  nutrient  pollution  to  achieve  the 

objectives of the MSFD, WFD and the Nitrates Directive; 

iii.  reducing  chemical  pollution  from  sea-based  sources,  in  particular 
hydrocarbon extraction, and from novel substances, including PFAS, 
pharmaceuticals or microplastics; 

iv.  continuing action to reduce the impact of litter on marine life, while 

reducing the inputs at source. 

b.  On biodiversity, this involves: 

i.  completing  the  network  of  coherent,  representative,  effectively 
managed MPAs to reach the 2030 target set in the biodiversity strategy 
to  protect  30%  of  waters,  including  10%  strictly,  in  line  with  the 
ambition set in the marine action plan and the obligations under the 
Kunming-Montreal Global Biodiversity Framework; 

ii.  stepping up action to reduce the bycatch of sensitive species, starting 
with the priority species as recommended in the marine action plan; 

iii.  implementing  without  delay  the  obligations  under  the  Nature 
Restoration  Regulation  as  critical  contributions  to  achieving  GES 
under the MSFD;  

iv.  tackling  the  risks  to  marine  ecosystems  linked  to  the  projected 
expansion of offshore renewable energy production, together with the 
cumulative  impacts  of  existing  activities  at  sea,  through  forward-
looking ecosystem-based maritime spatial planning. 

c.  Regarding climate change, all Member States should seek to factor climate 

change in the design and selection of their measures and in particular: 

i.  prioritise measures that  help limit/reduce greenhouse gas  emissions, 

including by restoring blue carbon ecosystems; 

ii.  ensure  that  other  measures  or  groups  of  measures  do  not  increase 

greenhouse gas emissions; 

iii.  take  measures  to  strengthen  the  adaptive  capacity  of  coastal 
communities to climate change, e.g. by restoring coastal ecosystems. 

(84)  Communication from the Commission, Commission Notice on the threshold values set under the 
Marine Strategy Framework Directive 2008/56/EC and Commission Decision (EU) 2017/848 
(C/2024/2078), 11.3.2024. 

26 

 
 
3.  Member  States  should  increase  investment  and  provide  sufficient  financing  to 
implement  the  programme  of  measures  to  reach  the  MSFD  objectives.  This 
involves in particular: 

a.  developing a strategic outlook for investments to achieve good environmental 
status,  avoiding  a  piecemeal  approach  to  funding  individual  measures  and 
reducing inefficiencies across different policy areas; 

b.  clearly identifying the source of financing needed to implement all measures; 
c.  making  use  of  existing  financial  instruments  and  tools  that  support  the 
development of measures for marine protection and sustainable use, including 
through  research  and  innovation,  such  as  the  Cohesion,  Recovery  and 
Resilience Facility, regional funds, EMFAF, LIFE and Horizon Europe in its 
different clusters (e.g. Missions and Partnerships), among others. 

4.  Member  States  should  put  in  place  governance  mechanisms  that  support  the 
design  and  implementation  of  ambitious,  coherent,  coordinated,  fair  and 
effective programmes of measures. This involves: 

a.  tackling  decisively  the  obstacles  to  implementing  the  measures,  such  as 

insufficient financing; 

b.  improving  coordination  across  authorities  to  ensure  that  MSFD  measures 
dependent on other policies are fully implemented by the authorities dealing 
with  implementation  of  these  policies,  notably  in  relation  to  fisheries, 
agriculture and energy; 

c.  involving  the  public  and  stakeholders  at  the  planning  stage,  taking  their 
contributions  into  account  in  the  design  of  measures  and  ensuring  social 
acceptability of the measures proposed, adopting accompanying measures to 
limit potential negative impacts if necessary; 

d.  increasing early coordination of programmes of measures with neighbouring 
Member  States  to  ensure  coherence,  synergies  and  the  complementarity  of 
measures in the region and planning joint action where necessary; 

e.  operationalising  the  spatial  aspects  of  MSFD  programmes  of  measures 
through maritime spatial plans to ensure that the spatial protection measures 
and  spatial  pressure  reduction  measures  planned  are  fully  taken  up  in  the 
MSP. 

5.  Lastly,  Member  States  should  provide  more  up-to-date  and  complete  electronic 
reporting in order to give greater transparency to the public on the measures proposed 
and on how they are expected to support progress towards GES and the targets. This 
will also enable comparability across Member States and marine regions. 

27