COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on European fisheries and aquaculture statistics and repealing Regulations (EC) No 1921/2006, (EC) No 762/2008, (EC) No 216/2009, (EC) No 217/2009 and (EC) No 218/2009
Date: 2025-07-30
Institutions: European Commission, Eurostat
Subjects: EU statistics, aquaculture, catch of fish, data collection, disclosure of information, fishing area, fishing fleet, fishing statistics, resources of the sea, statistical method

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.7.2025  SWD(2025) 232 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL    on European fisheries and aquaculture statistics and repealing Regulations (EC) No 1921/2006, (EC) No 762/2008, (EC) No 216/2009, (EC) No 217/2009 and (EC) No 218/2009                                          {COM(2025) 435 final} - {SEC(2025) 224 final} - {SWD(2025) 233 final}  
 
 
Table of contents 

1. 

2. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ................................... 3 

PROBLEM DEFINITION ....................................................................................... 14 

2.1.  What is/are the problems?............................................................................. 14 
2.2.  What are the problem drivers? ...................................................................... 23 
2.3.  How will the problem evolve? ...................................................................... 24 

3.  WHY SHOULD THE EU ACT? ............................................................................. 25 

3.1.  Legal basis .................................................................................................... 25 
3.2.  Subsidiarity: Necessity of EU action ............................................................ 25 
3.3.  Subsidiarity: Added value of EU action ....................................................... 25 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................... 27 

4.1.  General objectives ........................................................................................ 27 
4.2.  Specific objectives ........................................................................................ 27 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ......................................... 32 

5.1.  What is the baseline from which options are assessed? ................................ 32 
5.2.  Description of the policy options .................................................................. 34 
5.2.1. 

Option 1: Baseline scenario – continuation of the current policy ......................... 34 

5.2.2. 

Option 2: Discontinuation of EFS ......................................................................... 34 

5.2.3. 

Option 3: New streamlined legal framework for EFS ........................................... 34 

5.2.4. 
level administrative sources .................................................................................................. 35 

Option 4: New legal basis for aquaculture and compilation of other EFS from EU 

5.3.  Options discarded at an early stage ............................................................... 36 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................... 37 

6.1.  Option 1: Baseline scenario – continuation of the current policy ................. 38 
6.2.  Option 2: Discontinuation of EFS ................................................................ 41 
6.3.  Option 3: New streamlined legal framework for EFS .................................. 44 
6.4.  Option 4: New legal basis for aquaculture and compilation of other EFS from 
EU level administrative sources ................................................................... 48 

7.  HOW DO THE OPTIONS COMPARE? ................................................................ 50 

8. 

PREFERRED OPTION ........................................................................................... 51 

8.1.  REFIT (simplification and improved efficiency) ......................................... 53 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED + EVALUATED? ............ 54 

ANNEX 1: PROCEDURAL INFORMATION ............................................................... 58 

ANNEX 2: STAKEHOLDER CONSULTATION .......................................................... 60 

ANNEX 3: WHO IS AFFECTED AND HOW? .............................................................. 73 

ANNEX 4: ANALYTICAL METHODS ......................................................................... 76 

1 

 
 
Glossary 

Term or acronym 

Meaning or definition 

ACDR 

CFP 

CWP 

DCF 

DG 

DGAS 

DG MARE 

EC 

EEA 

EFS 

EFTA 

Aggregated Catch Data Reporting 

Common Fisheries Policy 

Coordinating Working Party on Fishery Statistics 

Data Collection Framework 

Directorate-General 

Directors’ Group on Agricultural Statistics 

Directorate-General for Maritime Affairs and Fisheries 

European Communities 

European Economic Area 

European Fishery Statistics 

European Free Trade Association 

EMODnet 

European Marine Observation and Data Network 

ESP 

ESS 

EU 

European Statistical Programme 

European Statistical System 

European Union 

EUMOFA 

European Market Observatory for Fisheries and Aquaculture Products 

FAO 

ICES 

ISG 

JRC 

NGO 

NSI 

OECD 

REFIT 

RFMO 

SAIO 

SMEs 

WTO 

Food and Agriculture Organization of the United Nations 

International Council for the Exploration of the Sea 

Inter-Service Steering Group 

Joint Research Centre 

Non-governmental organisation 

National statistical institute 

Organisation for Economic Co-operation and Development 

Regulatory fitness and performance programme 

Regional fisheries management organisation 

Statistics on Agricultural Input and Output 

Small- and medium-sized enterprises 

World Trade Organization 

2 

 
 
 
 
 
 
 
1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

Eurostat and the European Statistical System 

Eurostat, the statistical  office of the European Union (EU), ensures  the production of high-
quality,  comparable  European  statistics1  according  to  established  rules  and  statistical 
principles, notably those laid down in the European statistics Code of Practice2 and in the legal 
framework for European statistics known as the “Statistical Law”3. These rules and principles 
aim  to  ensure,  among  others,  the  independence,  impartiality,  objectivity  and  reliability  of 
European statistics, and through those objectives public trust in the statistics. The main uses of 
European statistics are to serve EU policy design, implementation and monitoring, and their 
main users are EU Institutions. 

The European Statistical System (ESS) is the partnership between Eurostat and the national 
statistical institutes (NSIs), as well as other national authorities which are responsible for the 
development, production and dissemination of European statistics in each EU Member State. 
This partnership also includes the European Economic Area (EEA) and European Free Trade 
Association (EFTA) countries, i.e. Iceland, Liechtenstein, Norway and Switzerland. The ESS 
functions  as  a  network  in  which  Eurostat's  role  is  to  lead  the  way  in  the  harmonisation  of 
statistics  in  close  cooperation  with  national  statistical  authorities,  which  collect  data  and 
compile  statistics  for  national  and  EU  purposes.  In  order  to  fulfil  this  role,  Eurostat  issues 
statistical  regulations  and  methodological  guides,  organises  expert  groups,  and  assesses  the 
quality of statistics and countries’ legislative compliance. In accordance with the EU principles 
of subsidiarity and proportionality, each ESS member develops a statistical system suitable to 
their  individual  institutional  context,  while  still  following  the  common  rules.  The  ESS  also 
coordinates  its  work  with  candidate  countries  and,  at  EU  level,  with  other  European 
Commission services as well as with international organisations such as the Organisation for 
Economic  Co-operation  and  Development  (OECD),  an 
intergovernmental  economic 
organisation, and United Nations bodies such as the Food and Agriculture Organization (FAO), 
an agency tasked to defeat hunger and improve nutrition and food security. 

Eurostat’s  activities  are  further  influenced  by  overarching  policies  such  as  the  EU’s  Better 
Regulation agenda4, which promotes open and transparent EU decision-making and evidence-
based  decisions,  and  European  Commission  President  Ursula  von  der  Leyen’s  six  political 

1  Statistics  in  the  ESS  context  are  defined  according  to  Article  3(1)  of  Regulation  (EC)  No  223/2009  as 
“quantitative and qualitative, aggregated and representative information characterising a collective phenomenon 
in a considered population”. 

2  European statistics Code of Practice, revised version endorsed by the European Statistical System Committee 

on 16 November 2017 

3 Regulation (EC) No 223/2009 of the European Parliament and of the Council of 11 March 2009 on European 
statistics and repealing Regulation (EC, Euratom) No 1101/2008 of the European Parliament and of the Council 
on  the  transmission  of  data  subject  to  statistical  confidentiality  to  the  Statistical  Office  of  the  European 
Communities,  Council  Regulation  (EC)  No 322/97  on  Community  Statistics,  and  Council  Decision 
89/382/EEC, Euratom establishing a Committee on the Statistical Programmes of the European Communities, 
OJ L 87, 31.3.2009, p. 164–173 

4 Better regulation: why and how 

3 

 
 
 
 
 
 
priorities, among them “A European Green Deal” and “An economy that works for people”5. 
Implementing, monitoring and assessing these priorities requires impartial and objective data 
– that is, official statistics. 

European Fisheries and the Common Fisheries Policy 

The EU’s Common Fisheries Policy (CFP)6, a major common EU policy next to the Common 
Agricultural Policy, regulates the fisheries sector in the EU by creating a framework that gives 
direction to the fisheries sector, lays out the rules for managing the EU fishing fleet and strives 
to ensure the long-term economic, environmental and social sustainability of European fishing. 
The CFP was last updated in 2014 and currently rests on four pillars: 

1)  fisheries management to balance fish stock sustainability with maintaining livelihoods 

for EU fishers, including setting rules and regulations such as annual quotas; 

2)  international  policy  to  synchronise  EU  practices  with  practices  and  requirements  of 
international organisations and regional fisheries management organisations (RFMOs), 
as one in five EU fishing vessels fish outside of Union waters; 

3)  market and trade policy to ensure that the fisheries sector complies with and fosters the 
common  market  policy  of  the  EU  and  enables  equal  access  to  all  Union  waters  to 
vessels from all Member States; and 

4)  funding to support the previous three pillars.   

The fisheries authorities of EU Member States collect data related to fisheries control covering 
the entire production and distribution chain (e.g. catch, landing, transport and first sales, as well 
as data relating to fishing effort, vessel characteristics, fishing licences etc.) under the Control 
Regulation and reporting obligations stemming from specific regulations and in particular from 
RFMO  recommendations  and  international  agreements7.  The  main  data  sources  include 
logbooks, landing declarations, transport documents, sales notes, inspection reports, and vessel 
monitoring  system  records.  Based  on  this  information,  Member  States  must  transmit 
aggregated  catch  data  and  fishing  effort  data  to  the  European  Commission’s  Directorate-
General for Maritime Affairs and Fisheries (DG MARE) on a monthly basis for species subject 

5 The European Commission’s priorities 

6 Regulation (EU) No 1380/2013 of the European Parliament and of the Council of 11 December 2013 on the 
Common Fisheries Policy, amending Council Regulations (EC) No 1954/2003 and (EC) No 1224/2009 and 
repealing Council Regulations (EC) No 2371/2002 and (EC) No 639/2004 and Council Decision 
2004/585/EC, OJ L 354, 28.12.2013, p. 22–61 

7 Council Regulation (EC) No 1224/2009 of 20 November 2009 establishing a Community control system for 
ensuring compliance with the rules of the  common fisheries policy, amending Regulations (EC) No 847/96, 
(EC)  No 2371/2002,  (EC)  No 811/2004,  (EC)  No 768/2005,  (EC)  No 2115/2005,  (EC)  No 2166/2005,  (EC) 
No 388/2006,  (EC)  No 509/2007,  (EC)  No 676/2007,  (EC)  No 1098/2007,  (EC)  No 1300/2008,  (EC) 
No 1342/2008 and repealing Regulations (EEC) No 2847/93, (EC) No 1627/94 and (EC) No 1966/2006, OJ L 
343, 22.12.2009, p. 1–50   

Commission Implementing Regulation (EU) No 404/2011 of 8 April 2011 laying down detailed rules for the 
implementation  of  Council  Regulation  (EC)  No 1224/2009  establishing  a  Community  control  system  for 
ensuring compliance with the rules of the Common Fisheries Policy, OJ L 112, 30.4.2011, p. 1–153 

4 

 
 
 
 
 
 
 
 
 
to  quotas  and  on  a  quarterly  basis  for  all  other  species.  Aggregated  data  is  stored  in  the 
Aggregated Catch Data Reporting (ACDR) database, a Commission repository which is not 
publicly accessible. In addition, DG MARE manages data collection under the Data Collection 
Framework (DCF)8, with the aim of providing scientific advice for the CFP. Under the DCF, 
Member States collect biological, environmental, technical, economic and social data to help 
assess the state of exploited marine biological resources, the level and impact of fishing, and 
the  socio-economic  performance  of  the  fisheries  and  aquaculture  sector.  Some  assessments 
used for policy-making are performed by the Scientific, Technical and Economic Committee 
for  Fisheries  with  technical  assistance  by  the  Commission‘s  Joint  Research  Centre  (JRC), 
whereas  others  are  performed  by  the  International  Council  for  the  Exploration  of  the  Sea 
(ICES),  the  world’s  oldest  intergovernmental  science  organisation.  The  data  collection  is 
coordinated between Member States, end users and the Commission in regional coordination 
groups organised by sea basin, or by fisheries sector (e.g. long-distance or tuna fisheries). A 
dedicated group coordinates the socioeconomic data collection. 

The EU regulates the fisheries sector because it is inherently international. Fish move on their 
own,  often  in  international  waters,  and  when  exploited  sustainably,  are  a renewable  natural 
resource providing important nutrition for millions of people, as well as economic opportunities 
for fishers and coastal communities. Fish also play key roles in marine ecosystems. However, 
they are vulnerable to a collective action problem, as each individual fishing actor has a rational 
self-interest to fish as much as possible, with no initial possibility of excluding any actor from 
doing so. Mismanaged fisheries could lead to a rapid depletion of fish stocks, which indeed has 
happened  in  many  cases  in  the  past.  For  example,  scientists  of  the  JRC  estimate  that  the 
Mediterranean Sea lost 34% of its total fish population between 1950 and 20119. To prevent 
this collective action problem harming fisheries, the economy, the environment and society at 
large, international fisheries governance is therefore necessary (see also below). 

EU-27 fishery production had a volume of 5.7 million tonnes live weight in 2018 and consisted 
to about 4/5 of catches of wild fish, and to about 1/5 of aquaculture production10. Globally, 
China accounted for about 35% of total fisheries production in 2018, followed by Indonesia 
with 13%, India with 6.1%, Vietnam with 3.6% and the EU-27 in fifth place with about 3%11. 
The production value of EU fisheries and aquaculture was estimated at 10.2 billion € in 2018 
(6.5 billion € for landings and 3.7 billion € for aquaculture production), or 0.08% of the EU-27 
GDP of 13.5 trillion € in that year.  

8 Regulation (EU) 2017/1004 of the European Parliament and of the Council of 17 May 2017 on the establishment 
of a Union framework for the collection, management and use of data in the fisheries sector and support for 
scientific advice regarding the common fisheries policy and repealing Council Regulation (EC) No 199/2008, 
OJ L 157, 20.6.2017, p. 1–21 

9 Saving our heritage, our future: The worrying state of Mediterranean fish stocks 

10 Agriculture, forestry and fishery statistics, 2020 edition, Eurostat 

11 The state of world fisheries and aquaculture, 2020, FAO 

5 

 
 
 
 
 
 
 
 
 
 
 
Figure 1: EU Fisheries infographic, 2020. Source: Eurostat12. 

In contrast, CFP support via the European Maritime and Fisheries Fund  to the EU fisheries 
sector amounted to 6.4 billion € for the 2014-2020 programming period, or 0.6% of the EU 
budget for that period. Almost 80% of that amount is used to promote sustainable fisheries, 
around 10% is for control and enforcement, and about 9% is for Control Regulation and DCF 
data collection (EFS production costs are in addition to this cost, see below). 163.000 people, 
or 0.08% of all EU workers, were employed in the primary fisheries industry in the EU-27 in 
2018, with Spain, Italy, Greece, France and Portugal making up about three quarters of that 
employment. There were a bit more than 76.000 fishing vessels in the EU-27 in 2018, with the 

12 Eurostat Statistics Explained - Fishery statistics 

6 

 
 
 
 
 
 
 
highest numbers in Greece (almost 20% of the EU total), Italy (16%) and Spain (almost 12%), 
yet the largest gross tonnages were registered in Spain (about 25%), France (about 13%) and 
Italy (11%). The vast majority of EU fishing vessels is less than 10 metres long, but the larger 
vessels catch three quarters of the fish. Most companies in the fisheries and aquaculture sectors 
are small. In the fishing sector, 90% of companies operate only one vessel (see Figure 2), and 
it  is  estimated  that  90-95%  of  these  companies  employ  a  maximum  of  10  people.  In  the 
aquaculture  sector,  it  is  estimated  that  92%  of  the  enterprises  employ  a  maximum  of  ten 
people13.   

Figure 2. Vessel distribution by company size in 2018. Source: Scientific, Technical and 
Economic Committee for Fisheries 14. Note: Data for Germany are missing.  

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

Enterprises with one vessel

Enterprises with 2 to 5 vessels

Enterprises with more than 5 vessels

The  EU  imports  more  than  five  times  more  fish  by  value  than  it  exports15.  Despite  this 
comparatively  low  economic  impact,  fisheries  are  politically  important,  and  significant  for 
some coastal regions. 

European Fishery Statistics 

European Fishery Statistics (EFS) are official Eurostat statistics on the production, volume and 
value of fisheries products caught from the sea or cultivated in aquaculture facilities in the EU, 
Norway and Iceland (Liechtenstein and Switzerland are landlocked and do not report either sea 
fishery  or  aquaculture  data  to  Eurostat).  They  are  originally  intended  to  contribute  to  the 

13 Scientific, Technical and Economic Committee for Fisheries: The EU aquaculture sector – Economic report 

2020. Publications Office of the European Union, Luxembourg. 2021. 

14  Scientific, Technical and Economic Committee for Fisheries: The 2020 Annual Economic Report on the EU 

Fishing Fleet. Publications Office of the European Union, Luxembourg. 2021. 

15 Facts and Figures on the Common Fisheries Policy 2020 

7 

 
 
 
 
  
 
 
 
 
 
development, implementation and monitoring of the CFP, as well as to support EU trade policy, 
economic  analysis,  and  environmental  policy  with  the  aims  of  long-term  environmental, 
economic and social sustainability of European fisheries. 

Eurostat has produced EFS since the inception of the European Economic Community in the 
1950s. Currently, they are based on five statistical regulations16 covering catches17, landings18 
and aquaculture19 data, which are binding for EEA countries. The regulations lay down, among 
others,  the  fishing  areas  covered20,  the  statistical  variables,  data  and  metadata,  transmission 
deadlines and statistical quality criteria. In addition, Eurostat compiles fishing fleet statistics 
directly from the EU fishing fleet register managed by DG MARE under separate regulations 
for the purpose of proper registration of all vessels allowed to exploit EU fisheries resources21 

16 Regulation (EC) No 1921/2006 of the European Parliament and of the Council of 18 December 2006 on the 
submission  of  statistical  data  on  landings  of  fishery  products  in  Member  States  and  repealing  Council 
Regulation (EEC) No 1382/91, OJ L 403, 30.12.2006, p. 1–8 

Regulation (EC) No 762/2008 of the European Parliament and of the Council of 9 July 2008 on the submission 
by Member States of statistics on  aquaculture and repealing Council Regulation (EC) No 788/96, OJ L 218, 
13.8.2008, p. 1–13 

Regulation  (EC)  No  216/2009  of  the  European  Parliament  and  of  the  Council  of  11  March  2009  on  the 
submission of nominal catch statistics by Member States fishing in certain areas other than those of the North 
Atlantic (recast), OJ L 87, 31.3.2009, p. 1–41 

Regulation  (EC)  No  217/2009  of  the  European  Parliament  and  of  the  Council  of  11  March  2009  on  the 
submission of catch and activity statistics by Member States fishing in the north-west Atlantic (recast), OJ L 
87, 31.3.2009, p. 42–69 

Regulation  (EC)  No  218/2009  of  the  European  Parliament  and  of  the  Council  of  11  March  2009  on  the 
submission of nominal catch statistics by Member States fishing in the north-east Atlantic (recast), OJ L 87, 
31.3.2009, p. 70–108 

17 Fish catches cover fish, molluscs, crustaceans and other aquatic animals, residues and aquatic plants that are 
taken for all purposes, by all types and class of vessel, gear and fishermen, operated in all marine areas: high-
sea fishing areas, offshore, inshore or brackish water areas. The production from aquaculture and catches in 
fresh water are excluded. EFS data on fish catches are recorded in tonnes live weight. Landlocked EU countries 
without a marine fishing fleet are not included (Czech Republic, Luxembourg, Hungary, Austria and Slovakia). 

18 EFS landings statistics relate to fisheries products (product weight and value) landed in a country by vessels of 
the  country  or  vessels  from  other  EU/EEA  countries  (excluding  landings  by  non-EU/EEA  vessels),  and  to 
fisheries products landed by the country’s vessels in non-EU ports and then imported into the EU (excluding 
non-imported  fisheries  products).  Landlocked  EU  countries  without  a  marine  fishing  fleet  are  not  included 
(Czech Republic, Luxembourg, Hungary, Austria and Slovakia). 

19 Aquaculture is the farming of aquatic organisms under controlled conditions. It includes the cultivation of fish 
and fish eggs, the production of juveniles, capture-based inputs, and production for human consumption e.g. of 
fish, mussels and crustaceans. 

20 The EFS catch regulations currently cover seven FAO fishing areas near the EU: 21 – Northwest Atlantic, 27 – 
Northeast Atlantic, 34 – East-Central Atlantic, 37 – Mediterranean and Black Sea, 41 – Southwest Atlantic, 47 
– Southeast Atlantic, and 51 – West Indian Ocean.  

21 Commission Implementing Regulation (EU) 2017/218 of 6 February 2017 on the Union fishing fleet register, 

OJ L 34, 9.2.2017, p. 9–17 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
(Iceland  and  Norway  submit  their  fleet  data  directly  to  Eurostat).  Most  catch  and  landings 
statistics are now  produced from  administrative sources22 developed  under  the CFP such as 
logbooks, landing declarations and sales notes, but national authorities also carry out statistical 
surveys,  especially  when  administrative  sources  do  not  cover  the  complete  sector.  In  the 
aquaculture sector, surveys and, most often, censuses are used to cover the largely fragmented 
sector and the detailed data requirements. 

Eurostat processes, validates and finalises the data originally collected and first treated by EU 
Member  States  and  then  publishes  them  on  the  European  statistics  database  on  Eurostat’s 
website free of  charge.  The data is  further  published in  statistical  books, feeds  diverse web 
applications, and is sent to the EU Institutions needing them and to various organisations (see 
also below). For example, EFS aquaculture statistics are relevant as the basis for other data 
collections23,  in  particular  for  freshwater  aquaculture,  where  no  other  EU-level  dataset  is 
collected and published. They are also relevant for sustainable food production, especially in 
the context of the European Green Deal, whose “Farm to Fork” strategy24 includes the share of 
organic aquaculture production in the EU as an indicator. 

A  recent  evaluation  of  EFS25,  conducted  in  2018-2019,  included  an  online  survey  on  the 
purposes data users access EFS for.  The most-mentioned purposes were (multiple mentions 
possible): CFP design, implementation and monitoring on national, EU or international level 
(62%),  research  (28%),  commercial  purposes,  for  example  market  intelligence  (25%), 
environmental policy purposes (22%), and other policy purposes (13%). However, fewer than 
half  of  the  users  who  identified  the  CFP  purpose  represented  national  authorities  with 
responsibility  for  development  of  fisheries  policy,  with  the  majority  being  either  research 
institutes supplying data for the CFP, or individuals using the data for independent research or 
analysis  not  necessarily  directly  related  to  official  CFP  purposes.  As  another  data  point, 
downloads of Eurostat fisheries datasets (catches by fishing area, landings of fishery products, 
aquaculture production by species and fishing fleet) from 2013 to 2018 and page views for the 
same time period have tripled from 8.565 to 27.64726, likely reflecting an increasing general 
interest in EFS data. 

22 Administrative data are data collected for other than primarily statistical purposes. In the case of fisheries, they 

are used e.g. for the management of the CFP and in some cases reused and treated to compile EFS. 

23  Commission  Implementing  Decision  (EU)  2019/909  of  18  February  2019  establishing  the  list  of  mandatory 
research  surveys  and  thresholds  for  the  purposes  of  the  multiannual  Union  programme for  the  collection  and 
management of data in the fisheries and aquaculture sectors, OJ L 145, 4.6.2019, p. 21–26 

24 Farm to Fork strategy 

25 Commission Staff Working Document Evaluation of the European Fishery Statistics, SWD(2019) 425 

26 Source: Eurostat own calculations. Data available on request. 

9 

 
 
 
 
 
 
 
 
 
 
The  estimated  total  cost  of  producing  EFS  is  about  5.6  million  €  per  year27  for  the  27  EU 
Member States and the European Commission, of which approximately 5% are incurred by the 
European Commission. The  costs are higher for Mediterranean countries that have large small-
scale fishing fleets whose fishing data is not recorded automatically for the CFP (this is because 
EU  fishing  vessels  below  12  metres  are  not  obliged  by  the  Control  Regulation  to  have 
electronic recording systems on board, so data is mainly recorded based on paper logbooks and 
must be fed into the electronic database). These costs refer to direct and indirect costs for data 
producers (NSIs and other national authorities), but do not include costs for data providers as 
a separate statistical data collection is only organised exceptionally for catch and landings data, 
and filling in the aquaculture questionnaire only takes a few hours per year (see below). 

EFS costs thus represent only 0.05% of the annual EU fisheries and aquaculture production 
value. This is very low if compared, for example, to the cost of the decennial agricultural census 
alone,  which  represents  approximately  0.6%  of  the  production  value  of  the  far  larger  EU 
agricultural sector. The reason for this low cost is the wide reuse of available administrative 
data as source data for catch, landings and fleet statistics. These “raw data” are not specifically 
collected for EFS, but have to be collected by Member States under the Control Regulation for 
catches and landings, and under the fleet regulation for fishing fleet data. Additional costs for 
EFS  over  the  CFP  catch  and  landings  data  collection  mostly  arise  from  collecting  data  for 
vessels under the CFP’s recording thresholds, specific database queries, and the EFS validation 
procedure and quality  reports.  For  aquaculture statistics, most  EU Member States carry out 
joint collections for statistical and DCF purposes, which reduces costs. For example, the 2017 
report from the Commission to the European Parliament and the Council on the submission by 
Member States of statistics on aquaculture28 indicated that operators usually spend only around 
three hours to fill in the joint questionnaire per year. Aquaculture data costs related specifically 
to EFS mostly arise from adapting the questionnaires to the EFS requirements, the production 
of certain aggregates, and the EFS validation procedure and quality reports. 

EU and global fishery data and governance environment 

EFS  are  required  by  several  EU  Institutions  and  international  organisations  and  exist  in  a 
complex  environment  of  regional,  national,  international,  supranational  and  global  fisheries 
data flows, organisations, responsibilities and governance agreements. 

Within Eurostat and the EU, statistics related to fisheries are collected in many places:  

27 These cost estimates are provided by the countries in the statistical cost data collections carried out by the ESS 
Resource  Directors’  Group  for  the  reference  years  2015/2016  and  2020.  The  Member  States’  cost  for 
aquaculture statistics is 2.1 million €, for landing statistics 1.8 million €, and 1.5 million € for catch statistics. 
The  estimated  cost  for  Eurostat  is  0.3  million  €.  The  evaluation  and  subsequently  the  inception  impact 
assessment erroneously quoted as the total cost of EFS the national costs of only catch statistics and the Eurostat 
costs.   

28 Report from the Commission to the European Parliament and the Council on the implementation of Regulation 
(EC) No 762/2008 of the European Parliament and of the Council of 9 July 2008 on the submission by Member 
States of statistics on aquaculture and repealing Council Regulation (EC) 788/96, COM(2017) 747 

10 

 
 
 
 
 
 
 
•  statistics  on  fish  processing  are  included  in  the  statistics  on  the  production  of 

manufactured goods; 

•  statistics  on  the  businesses  working  with  fisheries  and  aquaculture  are  found  in 
Structural  Business  Statistics,  which  focus  on  describing  the  structure,  conduct  and 
performance of businesses; 

•  statistics on the international trade in fisheries products are included in  international 

trade statistics; 

•  statistics on the employment in fishing, aquaculture and related service activities are 

covered in labour force statistics; 

•  statistics on the organic production of aquaculture products are collected under organic 
farming statistics; and the European Food Price Monitoring Tool contains information 
about fish and seafood prices and their annual rates of change. 

Eurostat also provides EFS to the European Market Observatory for Fisheries and Aquaculture 
Products  (EUMOFA), a  service established by DG MARE to  provide  weekly,  monthly  and 
yearly  market  information  to  the  fisheries  sector  to  enable  better  production  planning  and 
increased production29. EUMOFA uses various EFS data and collects specific additional data 
from auctions and markets in EU Member States.  

Internationally, FAO compiles national catch and aquaculture statistics on a global scale, for 
which data are collected directly from countries. In the EU’s case, FAO uses Eurostat data as 
much  as  possible.  The  OECD  also  compiles  and  disseminates  statistics  on  landings  and 
aquaculture production for its members, drawing mainly from annual questionnaires, but also 
from EFS and other data. ICES uses DCF data and receives catch data from its 20 members, 
most of which are EU members for whom Eurostat provides most of the statistics. 

Regional fisheries management organisations were established following the adoption of the 
United  Nations  Convention  on  the  Law  of  the  Sea  in  1982,  which  called  on  participating 
countries  to  cooperate  at  global,  regional  and  sub-regional  level  to  manage  and  conserve 
fisheries on the high seas. They assess the status and commercial value of certain fish stocks 
they are responsible for, set catch limits or conduct inspections. Through the CFP, the EU has 
the mandate on fisheries management in EU waters, and the EU is a member of 17 RFMOs or 
other regional fisheries bodies. The reporting obligations of the EU towards RFMOs are mostly 
covered through the data collected under the DCF, and DG MARE reports fisheries activity 
aggregates to RFMOs on behalf of the EU.  

FAO’s  Coordinating  Working  Party  on  Fishery  Statistics  (CWP)  provides  a  mechanism  to 
coordinate the fishery statistical programmes conducted by regional fishery bodies and other 
intergovernmental organisations. It has served as the most important international and inter-
organisational  forum  for  agreeing  common  definitions,  classifications  and  standards  for  the 
collection of fishery statistics since 1960. The group has 19 members, such as RFMOs, ICES, 
OECD, and FAO. Eurostat participates in the CWP on behalf of the European Commission in 
close cooperation with DG MARE and EU Member States. 

29 https://www.eumofa.eu/  

11 

 
 
 
 
 
 
Issues with European Fishery Statistics 

The current EFS catch regulations recast older regulations adopted in the 1990s. The landings 
regulation repealed an older regulation in order to establish a common legal framework for data 
production based on principles of impartiality and reliability, ensure a better data transmission 
frequency and improve the data submission system. The aquaculture regulation also repealed 
an older regulation and aimed to organise the provision of statistics supporting the development 
and  management  of  the  aquaculture  sector  in  the  EU  within  the  CFP,  as  the  sector’s 
contribution to total EU fisheries production had increased over the years. All five regulations 
were adopted between 2006 and 2009, and it was  expected that most source data would be 
collected by statistical sample surveys. 

However, the fisheries data landscape has changed since then, following subsequent reforms 
of the CFP with the most recent one taking effect from 2014 on, the DCF recast in 2017 to 
provide scientific data, recent EU initiatives such as the European Green Deal with its focus on 
data  for  implementation  and  monitoring,  and  technological,  economic  and  environmental 
changes in the fisheries sector. Consequently, fisheries statistics needs and requirements have 
changed too. The wealth of CFP administrative data now used as the main source for EFS was 
not foreseen when adopting the current regulations, and EFS are therefore ill-adapted to this 
data flow, generally inflexible and do not offer easy ways to include or accommodate new data 
needs, sources or methods. 

Thus, there have been mounting indications from within the European Commission and from 
data  users  that  the  EFS  regulations  do  not  fully  meet  user  needs  anymore  and  place 
comparatively high administrative burdens and costs on data respondents and data producers. 
Moreover,  since  2007,  the  European  Court  of  Auditors  has  released  three  audit  reports30 
highlighting redundancies and inconsistencies between the data collected and disseminated by 
Eurostat and DG MARE, as well as inherent problems within EFS. 

For these reasons, the Commission started a project to streamline and simplify EFS in order to 
analyse  and  then  improve  this  situation.  The  project  is  part  of  the  European  Commission’s 
Better  Regulation  Agenda’s  programme  on  Regulatory  Fitness  and  Performance  (REFIT) 
because  it  aims  to  improve  the  performance  of  the  underlying  legislation  while  reducing 
burdens and costs.  

The first step of the project was the EFS evaluation. It focused on the EFS regulations and the 
current CFP period starting in 2014 and covered all then 28 EU Member States, Norway and 
Iceland.  Related  information  and  fisheries  data  collections  managed  by  other  parts  of  the 
European Commission than Eurostat, mainly under the responsibility of DG MARE, were not 
subject to the evaluation, but were taken into account as contextual factors. The same applied 

30 Special report No 7/2007 on the control, inspection and sanction systems relating to the rules on conservation 

of Community fisheries resources together with the Commission's replies, OJ C 317, 28.12.2007, p. 1–33 

Special report No 10/2014 – The effectiveness of European Fisheries Fund support for aquaculture 

Special report No 8/2017 – EU fisheries controls: more efforts needed 

12 

 
 
 
 
 
 
 
to European socio-economic statistics on the fisheries sector such as production, trade, business 
and employment statistics, and to organic production statistics. 

The evaluation found that EFS are an important and independent source of information for a 
wide range of users, but that their added value to manage the CFP is decreasing; in comparison, 
the  Control  Regulation  and  the  DCF  better  meet  fisheries  policy  management  and  analysis 
needs. The evaluation also found, among other issues, that EFS only partially cover EU catches, 
that  landings  of  fishery  products  are  not  precisely  and  comprehensively  defined,  and  that 
aquaculture statistics remain to a large extent confidential due to very detailed breakdowns of 
multiple statistical dimensions potentially allowing the identification of individual enterprises. 
Moreover, as EFS are part of a complex system of fisheries data in the EU and globally as 
described above, the evaluation found overlaps and discrepancies in parallel data flows, instead 
of  them  complementing  and  supporting  each  other.  The  evaluation  thus  confirmed  the 
European Court of Auditors’ findings. 

Eurostat therefore deemed it appropriate to conduct an impact assessment as the next step of 
the project to streamline and simplify EFS. Given the issues found by the evaluation, the impact 
assessment is to present objectives for improvement and systematically analyse and compare 
possible options to achieve them, as well as to analyse and compare the impacts of the options. 

Scope of the impact assessment report 

The scope of this report is accordingly the five regulations governing EFS, as these are under 
Eurostat’s full control to change. Related EU and other policies such as the CFP as well as the 
wider fisheries governance environment are taken into account as important context. However, 
as Eurostat’s influence on these is limited to cooperation agreements and/or being one of many 
members  of  groups  such  as  the  CWP,  the  related  policies  and  governance  venues  are  only 
included in the scope insofar as Eurostat can possibly influence them. 

To  understand  this  limitation  of  scope  and  of  the  project  to  streamline  and  simplify  EFS 
altogether, it is important to understand the difference between European statistics and other 
types of data, such as administrative data or big data. Statistics can be based on these and other 
types of data, but they go through more validation and verification according to established, 
public  principles,  standardised  definitions  and  so  on  in  order  to  create  an  as  accurate  and 
reliable picture of reality as possible. Statistical authorities also take care to be independent in 
their work to  prevent  undue influence  either via  low quality  data (hence  the validations) or 
irregular processes. Statistics are often the basis for political decisions and scientific research, 
so it matters that they are as objective and independent as possible. 

For these reasons, it is important and established institutional policy that European statistics 
are regulated by independent legal acts, and therefore EFS need to have a legal basis separate 
from  the  Control  Regulation  and  the  DCF.  While  this  impact  assessment  report  is 
accompanying  the  modernisation  of  the  EFS  legal  basis,  the  Control  Regulation  and  the 
multiannual programmes under the DCF are currently also being reformed by DG MARE in 
close  cooperation  with  Eurostat  (before  entering  their  respective  legislative  procedures)  in 
order to make the data optimally reusable for fishery statistics. However, Control Regulation 

13 

 
 
 
 
and DCF data fundamentally serve different purposes – e.g. mandatory control, monitoring and 
research – than statistics, so it is justifiable from this angle that each domain maintains its own 
legal basis, optimally tailored to its own characteristics and needs. 

The  Commission  proposal  to  revise  the  Control  Regulation  was  tabled  in  2018,  and  it  is 
currently  (September  2021)  entering  the  trilogue  phase  of  negotiations  in  the  European 
Parliament  and  the  Council  of  the  European  Union31.  This  revision  aims  at  improving  the 
collection of fisheries activity data. Reporting obligations are also not only established via the 
Control Regulation, but by other regulations as well, in particular one transposing international 
agreements  into  EU  law.  As  regards  the  revision  of  data  requirements  under  the  DCF,  the 
multiannual  programme  was  adopted  on  27  April  202132  after  thorough  stakeholder 
consultation,  including  Eurostat.  The  data  collected  for  aquaculture  under  this  programme 
concerns mainly socioeconomic variables; DCF thresholds below which EU Member States do 
not have to collect the data are based on Eurostat data on the weight and value of aquaculture 
production. 

Eurostat and DG MARE are cooperating intensively to align their data collection parameters 
such  as  definitions  and  classifications  in  order  to  facilitate  the  work  of  data  collectors  and 
contribute  to  coherent  data  sets.  All  Member  States  have  welcomed  this  work.  Many  EU 
countries choose to use Control Regulation data for EFS because they deem the data quality 
adequate,  and  according  to  the  European  statistics  Code  of  Practice,  already  existing  data 
sources should be used to decrease the burden on respondents. alternatively, Member States 
could  also  choose  to  use  for  example  surveys,  which  they  are  free  to  do  following  the  EU 
principle of subsidiarity. The importance of Control Regulation data as an EFS data source is 
thus not a de jure obligation, but a de facto choice. Or put another way, source data, whatever 
the source, are a prerequisite for statistics, but not statistics themselves, and this report focuses 
on statistics.  

2.  PROBLEM DEFINITION 

2.1.  What is/are the problems? 

The  evaluation  of  EFS,  the  three  European  Court  of  Auditors  reports  on  aspects  of  the  EU 
fisheries data system and consultations with expert groups such as the Eurostat Working Group 
on Fishery Statistics and other stakeholders have resulted in concordant lists of problems, but 
also strengths of EFS. 

As to the strengths of EFS, the evaluation found that the statistics are in general an important 
and  independent  source  of  fisheries  information  for  a  wide  range  of  users  in  fisheries 
management, market monitoring and research and media. The main user groups of EFS are 

31 Legislative train schedule – revision of the Fisheries control system  

32  Commission  Delegated  Decision  (EU)  2021/1167  of  27 April  2021  establishing  the  multiannual  Union 
programme for the collection and management of biological, environmental, technical and socioeconomic data 
in the fisheries and aquaculture sectors from 2022, OJ L 253, 16.7.2021, p. 51–90 

14 

 
 
 
 
 
 
 
national authorities, non-governmental organisations (NGOs), national fisheries organisations, 
international organisations and research institutions. The most common uses have been linked 
to  fisheries  policies  either  at  national,  EU  or  international  level.  Research  and  commercial 
purposes were the second and third most common uses, followed by environmental policy and 
other policies. EFS thus appear to provide relevant statistics to monitor and evaluate European 
fisheries policy and to inform policy making in a wider context. 

Moreover,  stakeholders  see  the  quality  and  independence  of  the  data  as  high,  and  the  EFS 
datasets  are  generally  internally  coherent.  This  means  that  the  five  legal  acts  framing  EFS 
complement and do not contradict, overlap or duplicate each other. The internal coherence has 
improved in recent years because Eurostat coordinates closely with Member States in the ESS 
to guide and support countries and share best practices for the statistical process. EFS are also 
complementary to and not overlapping with or duplicating other European statistics such as 
trade,  labour  or  organic  farming  statistics.  In  addition,  data  users  consider  EFS  to  be  more 
accurate, reliable and complete than comparable collections, and they are seen as adding EU 
value  because  they  offer  long,  independent,  comparable,  consistent,  validated  and  publicly 
available  data  time  series,  which  individual  countries  acting  on  their  own  could  not  easily 
compile.  Respondents  to  the  online  survey  in  the  EFS  evaluation  concurred  and  named  as 
further benefits of the data a general European overview among countries and sectors which 
allows comparative analysis and benchmarking, and support for stakeholders’ advisory with 
official  facts  and  data  for  modelling.  The  respondents  also  had  general  confidence  in  the 
statistics and appreciated the easy and free access, the added value in data quality verification 
and compliance monitoring, the timeliness and reliability of the data, and Eurostat as a one-
stop shop for data instead of having to access up to 27 NSI pages with various language or 
technical  barriers.  These  benefits  were  also  confirmed  by  the  case  studies  and  stakeholder 
interviews undertaken for the evaluation. As stated, the statistics are also in high demand on 
Eurostat’s  online  database,  more  than  comparable  data  collections  in  other  domains,  which 
indicates that the EFS target of reaching the general public is attained. The EFS regulations are 
crucial for this availability and quality of fishery statistics by stipulating, among others, lists of 
variables  to  be  provided,  main  definitions,  reporting  and  quality  control  procedures,  and 
deadlines, with legal force. 

Lastly, the evaluation also considered statistical quality as an additional, overarching criterion 
with  metrics  like  accuracy  and  reliability,  timeliness  and  punctuality,  coherence  and 
accessibility  as  well  as  process  control,  cost-efficiency  and  other  factors.  It  found  that  EFS 
have high quality standards valued by data users, and are also in general published in a timely, 
punctual,  accessible  and  clear  fashion.  The  regulatory  compliance  monitoring  system  of 
Eurostat and the reaction speed of countries to compliance issues are also rated as good.  As 
stated previously, the cost and additional administrative burden of producing EFS is very low 
(about 0.05% of the annual EU fisheries and aquaculture production value) in comparison to 
their  possible  benefits  because  they  are  mostly  produced  from  administrative  data  already 
collected for CFP purposes.  

However, this means there are few opportunities to reduce EFS costs and burdens further, either 
in  absolute  or  relative  terms.  For  example,  the  questionnaires  sent  to  aquaculture  facilities 

15 

 
 
 
 
create  a  burden  on  respondents,  but  it  is  estimated  (in  the  national  metadata  reports  for 
aquaculture statistics sent to Eurostat) that it takes approximately only three hours to complete 
the  joint  questionnaire  for  EFS  and  DCF  data  collection.  Given  the  size  of  the  aquaculture 
sector and the nature of the data collection, the total EU-wide cost of the time spent to fill in 
the  questionnaire  is  thus  estimated  as  less  than  200.000 €,  i.e.  small  if  compared  to  the 
economic value of the sector of around 3.7 billion € in 2018. In order to reduce the burden, 
countries have made the questionnaires more user-friendly and offered possibilities to report 
the  data  online,  but  any  such  efforts  only  have  a  very  small  financial  effect  as  long  as  the 
statistics are being collected. 

In  all,  EFS  can thus  be  seen as relevant  to  the needs of professional  users such as research 
institutions, national and international fisheries organisations and data redistributors (such as 
FAO,  OECD  and  ICES)  who  use  EFS  as  a  reference  or  a  validation  source  for  their  own 
statistics, and for purposes like market monitoring and analysis in the frame of EUMOFA. And 
while DG MARE fulfils EU reporting obligations towards RFMOs, some of the organisations 
use  EFS  for  validation  and  country  disaggregation  purposes.  In  this  manner,  EFS  fulfil 
stakeholders’ needs and provide timely and official information that is comparable across EU 
Member States. 

However,  despite  these  strengths  and  as  referred  to  above,  the  evaluation  also  showed  the 
statistics’ decreasing added value with regard to the purpose of supporting CFP policy-making 
and management, and diagnosed several other problems of EFS. In detail, these are: 

•  Sinking relevance: Subsequent and continuing reforms of the CFP have changed the 
policy’s data needs and data availabilities, to which EFS have structurally been unable 
to  react  adequately.  EFS  were  originally  supposed  to  support  CFP  development, 
monitoring and implementation. But data collection under the Control Regulation and 
the  DCF,  adopted  after  the  current  EFS  regulations  had  been,  now  generates  more 
detailed, disaggregated, frequent and timely catch and landings data than EFS, so DG 
MARE uses those data more frequently than statistics. For example, the ACDR dataset 
provides  monthly  figures  to  measure  catches  against  the  total  allowable  catches, 
whereas EFS only provide annual figures. EFS can also not easily meet the data needs 
resulting  from  the  new  CFP  landing  obligation,  which  mandates  that  all  catches  of 
certain marine species must be landed instead of being partly discarded. This is because 
the “unwanted catch” may not be used for human consumption, but EFS only focus on 
catches  and  landings  for  human  consumption.  In  general,  advising  and  reporting  on 
progress  in  achieving  CFP  and  European  Green  Deal  objectives  requires  biological, 
economic, social, and environmental data beyond the data available in the EFS. 

EFS are also in principle relevant for aquaculture to define thresholds for the DCF, as 
a reference for European Maritime and Fisheries Fund actions, and as an information 
source  for  DG  MARE  on  fisheries  in  Norway  and  Iceland,  especially  regarding 
structural information, but the current EFS do not deliver the needed data, nor deliver 
them early enough. For example, the dataset on the structure of the aquaculture sector 
is currently collected, but not published due to persistent quality problems. Moreover, 

16 

 
 
 
 
 
FAO has indicated that it would be interested in using EFS aquaculture statistics if they 
were published earlier and had fewer confidential values, and OECD has expressed a 
preference to use EFS instead of collecting fisheries data from EU Member States if 
they would fit their specific needs better. 

More generally, the current EFS regulations were designed with the expectation that 
the statistics would be collected mainly by sample surveys, and for minor species by 
expert  estimates.  The  availability  of  detailed  CFP  administrative  fisheries  data  has 
upended  this  expectation,  so  the  EFS  regulations  are  not  well-tailored  to  the 
predominant mode of EU fisheries data collection anymore. The aggregation level of 
EFS is generally considered as too high for almost all dimensions (species, geographical 
units  and  time),  and  some  users  would  prefer  them  to  be  more  timely,  even  if  that 
implies a trade-off with quality and reliability – the earlier data is collected, the more 
one has to work with preliminary, not yet fully verified data. Users also ask for better 
data on by-catches, landings outside of the EU, catches in more than the seven FAO 
fishing regions currently included, and sometimes for easier usability of Eurostat’s on-
line  database.  For  these  reasons,  users  currently  seek  the  data  they  need  from  other 
sources,  even  if  they  are  aware  of  the  differences  e.g.  in  quality  between  official 
statistics and other types of data. For example, fisheries data users at national level often 
use national fisheries statistics or mixtures of e.g. national, DCF and FAO data due to 
them having more detail or a broader scope. 

Some of these data, for example those of FAO, are either based on EFS via transmission 
by Eurostat or structured by the requirements of the EFS regulations, possibly without 
users’ knowledge. This means that the relevance of EFS is higher than some users are 
aware of and than e.g. the number of direct downloads from Eurostat’s online database 
suggests  (a  “Brussels  effect”33  for  fisheries  data).  Nevertheless,  improvements  in 
coverage, aggregation levels and dissemination aspects would increase the relevance of 
EFS, and EFS should be adapted to the changed information ecosystem in which they 
now  operate  by  redetermining  the  desired  relevance  level  and  importance  of  fishery 
statistics (see also “fisheries data landscape” point below).    

•  The EFS legislation is inflexible and data needs go unfulfilled: As stated in section 
1,  the  EFS  regulations  are  either  recasts  or  moderate  updates  of  older  regulations 
originating  in  the  1990s.  They  were  aligned  with  the  treaty  of  Lisbon  in  2013  by 

33 The Brussels effect can be defined as a process of unilateral regulatory globalisation caused by the European 
Union  de  facto,  but  not  necessarily  de  jure,  externalising  its  laws  outside  its  borders  through  market 
mechanisms.  This  is  because  the  combination  of  market  size,  market  importance  and  relatively  stringent 
standards and regulatory capacity of the EU can have the effect that firms trading internationally find that it is 
not economically, legally or technically practical to maintain lower standards in non-EU markets, and instead 
adopt standards set by the EU uniformly throughout their business. See e.g. Bradford, Anu (2020): The Brussels 
Effect. How the European Union Rules the World. Oxford University Press. 

17 

 
 
 
 
 
 
 
 
 
Regulation  (EU) No 1350/2013  in  order to  increase their flexibility  somewhat34, but 
much more legislative flexibility would be beneficial to enable quicker reactions to new 
or changing data needs, for example to more easily change lists of fish species to be 
collected, or to react to political developments, e.g. those following the EU exit of the 
major fisheries stakeholder of the United Kingdom, where important fishing waters lie. 

As  also  stated  previously,  EFS  currently  only  partially  cover  catches  by  EU  fishing 
vessels,  landings of fishery products  are not  precisely  and comprehensively  defined, 
emerging data needs e.g. on molluscs and seaweeds are not fulfilled or not fulfilled in 
a timely enough fashion, the aquaculture economic value at first sale is ill-defined and 
often estimated which can lead to large fluctuations between years and countries, and 
fisheries effort data is not well-developed and seems not to be used much. Solving these 
problems is not possible only via delegated and implementing acts because that would 
necessitate a wider restructuring of the EFS regulations. Moreover, the regulations are 
at the moment not open enough for technological and statistical innovation, for example 
with regard to new data collection methods.  

•  Too  much  confidential  data:  Some  of  the  data  collected  for  EFS  are  very  detailed, 
leading them to be confidential and hence not publishable. This issue concerns half the 
countries and is particularly acute in aquaculture, where 13% of values are confidential. 
The detailed data needs of the EFS aquaculture regulation necessitate large samples, in 
many cases censuses, and long and complex questionnaires which place administrative 
burdens and costs on data producers and respondents and then result in confidential and 
publicly unusable data for about half of EU countries, and correspondingly a lack of 
EFS  aggregates  for  aquaculture.  The  confidentiality  is  necessary  because  detailed 
public breakdowns could allow the identification of individual companies’ production 
or even of individual stocks they grow. This is because the EU aquaculture sector is 
highly  specialised  and  dominated  by  only  few  companies  in  many  countries,  and 
because  the  current  Eurostat  statistical  confidentiality  rules  make  aggregates 
confidential even if only a small part of them originally was and even if the confidential 
information  is  of little economic importance in  order  to  prevent the identification of 
other individual cells by subtraction. So far, Eurostat and the EU Member States have 
only  made  little  progress  in  agreeing  on  new  rules  to  make  more  EU  aquaculture 
statistics aggregates available while preserving data confidentiality. 

A  similar  problem  is  growing  in  landings  statistics  where  four  Member  States  have 
lately flagged a part of the data as confidential, yet at the same time, some EFS users 
request even more detailed statistics which would exacerbate the confidentiality issue. 
Therefore, this problem should be resolved with a coherent and standardised solution 
that balances confidentiality protection with data access.  

34 Regulation (EU) No 1350/2013 of the European Parliament and of the Council of 11 December 2013 amending 

certain legislative acts in the field of agricultural and fishery statistics, OJ L 351, 21.12.2013, p. 1–14 

18 

 
 
 
 
 
 
 
 
 
•  Quality problems of EFS source data: As explained, EFS base data today come largely 
from  administrative  data  sources  such  as  data  collected  under  control  requirements 
(about two thirds) or statistical collections (about three tenths), so their accuracy and 
reliability  depend  in  large  part  on  the  quality  of  this  third-party  source.  But  data 
collected under control requirements sometimes contain inaccuracies and mistakes such 
as wrongly reported or unreported species, particularly for smaller vessels without an 
electronic recording and reporting system, the fishing areas used are partly unaligned 
with those used for EFS, and there can be different deadlines. As the European Court 
of Auditors found, this is in part because EU fisheries control is not effective enough: 
some  Member  States  are  not  rigorously  following  up  on  missing,  incomparable  or 
erroneous data or do not apply strong penalties. However, these source data problems 
are hard to resolve by legislative measures under Eurostat remit. 

In general, third-party data sources can present multiple problems for statistical bodies: 
technical  problems  such  as  creating  interfaces  to  access  administrative  databases, 
organisational  problems  such  as  establishing  durable,  if  possible  contractual 
relationships  with  the  holders  or  managers  of  such  data  sources,  and  substantive 
problems if, for example, those sources change their classifications and definitions in 
justified response to their use cases changing. 

These problems have also been confirmed within the EU Institutions by a 2017 audit of 
the European Commission’s internal audit service on “other statistics”35, i.e. statistical 
activities of the institutions and bodies of the EU which are coordinated and steered by 
Eurostat  to  ensure  data  quality  and  consistency,  with  a  mandate  stemming  from  the 
“Statistical Law”. The audit found that there are many issues with the independence, 
robustness,  sustainability,  reliability  and  quality  of  these  data  and  the  process  of 
disclosing, managing and producing them, and some relevant data are not even declared 
as “other statistics” yet. As statistical  services in the EU and around the world  keep 
facing budget cuts while the need for official statistics keeps growing, the services turn 
more and more towards already existing third-party data sources such as administrative 
data, which is also recommended by the European Statistics Code of Practice. Solutions 
for the problems encountered with these sources would therefore benefit not only EFS, 
but other statistical data collections too. 

•  Gaps,  overlaps  and  discrepancies  in  the  EU  and  global  system  of  fisheries  data: 
Ideally,  the  parallel  fisheries  data  flows  within  and  outside  of  the  EU  should 
complement and support each other, especially if they mostly originate from the same 
source  data,  as  e.g.  data  collected  under  control  requirements  and  EFS  data  do.  But 
instead,  there  are  still  significant  differences  between  EFS  and  data  collected  under 
control requirements in Mediterranean countries even though the difference is small in 
the EU-wide aggregate and has decreased over time due to stakeholders’ efforts. This 

35 Report from the Commission to the European Parliament and to the Council – Annual report to the Discharge 

Authority on internal audits carried out in 2017, COM/2018/661 

19 

 
 
 
 
 
 
  
 
is partly due to the large number of small vessels in these fleets, and the fact that these 
small  vessels  can  benefit  from  derogations  to  some  of  the  Control  Regulation  and 
therefore need to be covered by surveys. In 2016, EFS showed 2.9% higher total catches 
than ACDR data, with most of the difference stemming from Greek (+34%) and Italian 
(+42%) data. The evaluation of EFS also found that there are discrepancies of more 
than 100 tonnes in 15% of records between Eurostat, FAO and ACDR data in 2016. 
The  main  reasons  for  the  differences  are  different  methods  in  catches  estimation 
(weighted landings and sales notes in EFS versus logbooks and landings in the control 
framework), different  species reporting and  classifications,  differences in  population 
and coverage, different organisations submitting the data and different deadlines and 
revisions. For example, ACDR includes data for 2289 species, the DCF for 2014, EFS 
for  1273,  and  FAO  “only”  for  847.  The  Commission  is  currently  tackling  these 
differences bilaterally with the concerned countries36. 

This lack of harmonisation and coherence makes the data less comparable than it could 
be  and  is  a  source  of  additional  burden  on  fisheries  data  producers.  This  is  because 
while data is originally mostly collected through a single process, the need to recollect, 
reprocess and submit it in different formats with different definitions, classifications, 
aggregations and validations and at different times for different organisations imposes 
time and resource costs and a potential for errors that could be reduced through greater 
harmonisation between EFS, Control Regulation, DCF and international organisations’ 
data requirements. For example, both Member States and Eurostat report certain data 
to OECD, sometimes resulting in discrepancies. These could be eliminated or reduced 
by having single transmissions according to the principle “collect once, use multiple 
times”. This has already been implemented with FAO catch data which are now only 
collected from Eurostat and no longer from EU Member States, at least for those FAO 
fishing regions covered by the EFS regulations. 

Within  Eurostat,  the  other  European  statistics  linked  to  fisheries  are  statistics  on 
international  trade,  production  of  fisheries  products,  businesses  and  labour  force 
working in the sector, and organic aquaculture statistics. The level of detail of these 
data is not always compatible with EFS. For example, trade and processing statistics 
are  not  broken  down  by  catches  and  aquaculture.  As  stated  above,  these  statistical 
domains complement each other, but they do not offer an optimal set-up for analysing 
e.g. “blue growth”37 potential in detail. This could also be improved. 

As stated, the costs of producing EFS are low in absolute terms and compared to the 
production value of the fisheries sector, but they are high compared to an ideal state 

36 The source for the numbers in this paragraph are Eurostat and DG MARE own calculations. Data available on 

request. 

37 Blue growth is the European Commission’s long term strategy to support sustainable growth in the marine and 
maritime sectors as a whole, as seas and oceans are seen as drivers for the European economy and to have great 
potential for innovation and growth. See https://ec.europa.eu/maritimeaffairs/policy/blue_growth_en  

20 

 
 
 
 
 
 
 
 
 
without double reporting and  discrepancies. National  statistical  authorities  are under 
severe budget pressure and therefore constantly seeking to reduce costs, for example 
by asking the Commission to modernise European statistics data collections in order to 
enable savings. From their perspective, the costs of EFS are therefore higher than they 
could be. 

Finally,  these  inconsistencies  in  EU,  Member  State  and  international  organisations’ 
fishery data sets are confusing and difficult to explain to data users and thus pose risks 
to the credibility and reputation of the EU. 

•  The place of EFS in the EU and global fisheries data landscape is unclear: This is in 
part a consequence of the other problems. Each of the EU and international fisheries 
data  sets,  whether  statistical,  scientific  or  administrative,  has  a  certain  purpose  and 
should be relevant for that purpose. Not all data have to or can be relevant for every 
purpose; for example, scientific data can be more relevant for stock assessments than 
EFS data, even though e.g. EFS time series on catches can serve as important contextual 
information  for the setting  of fishing  quotas. However, as described  above, EFS  are 
currently  not  used  much  for  their  intended  purpose  of  serving  the  CFP.  Given  the 
changes  in  the  EU  and  global  fisheries  data  landscape  following  CFP  reforms  and 
international organisations’ evolving data needs, the overall role and purpose of EFS 
within it should  therefore  be redefined so they can be optimally  produced and used. 
EFS  should  also  be  flexible  enough  to  be  able  to  react  to  further  changes  in  the 
landscape, as new policies, new technologies  and other developments may make the 
most suitable data sources for a task change over time. For example, research on fishing 
effort in an area was previously based on statistical data with a low spatial resolution 
and a long time lag. Today, it can be conducted based on vessel monitoring systems 
and with electronic logbook data in close to real time, so fishing effort statistics play 
less of a role and could conceivably be flexibly de-emphasised or even taken out in a 
new EFS setup. 

EFS are official statistics which means their production follows certain principles such 
as objectivity, impartiality and reliability. They are therefore in principle well-tailored 
to provide validated and reliable data on unit or aggregated level which show major 
trends  and  serve  as  an  official  one-stop  reference  and  comparability  benchmark  for 
other data collections. Official statistics should also in general be the main evidence at 
the  heart  of  evidence-based  policy-making  because  they  are  more  independent, 
validated and trusted, i.e. of higher quality, than other sources of data. The better the 
data,  the  better  decisions  are  likely  to  be.  Improvements  to  EFS  that  resolved  the 
problems described above would strengthen these characteristics and enhance the EU’s 
reputation through better policy design and delivery. 

On the other hand, official EFS cannot and should not serve short-term administrative 
needs, policy enforcement needs or scientific biological needs, to take some examples. 
The validation processes of official statistics take time, and they are thus unsuited for 

21 

 
 
 
 
 
  
 
 
very quick outputs. Enforcement has political and economic consequences which puts 
data used for enforcement under political pressure, an incompatible state of affairs for 
official statistics which need to be independent. Lastly, statistics cannot cover complex 
and changing biological phenomena with enough detail and speed. Data users should 
be supported in discerning which source is optimal for which need and in which context. 

EFS should thus respond to  the changed  fisheries  data landscape by redefining their 
own  place  within  it,  but  also  by  helping  to  clarify  the  roles  and  purposes  of  other 
fisheries  data  collections,  not  least  to  reduce  the  gaps,  overlaps  and  discrepancies 
between them, as described above. A well-organised EU and international fisheries data 
landscape  would  allow  each  data  collection  to  be  used  as  optimally  as  possible  and 
improve comparability. Eurostat as the statistical office of the EU is well placed to play 
a  leading  role  here  due  to  its  long  experience  with  data  collection,  validation  and 
transmission and its cooperation with services both within and outside of the European 
Commission. As noted, the Commission is represented by Eurostat (in co-operation by 
DG  MARE)  in  the  CWP,  which  has  developed  common  procedures  to  streamline 
processes,  provided  technical  advice,  and  published  methodological  and  reference 
documents.  Some  non-statistical  fisheries  data  sources  seek  to  align  with  CWP 
definitions and recommendations, but not all do, in particular when these definitions 
differ  from  FAO’s  generic  ones.  This  could  be  improved  in  a  concerted  effort.  For 
example,  an  opportunity  could  be  used  to  further  harmonise  EFS  with  the  currently 
ongoing  update  of  the  Control  Regulation  aiming  to  improve  data  quality  and 
availability, as well as with the revision of the DCF’s multiannual programmes, where 
Eurostat’s suggestions on coverage and exemptions have already been taken on board. 

Harmonisation  is  especially  beneficial  in  this  field  where  clear  responsibilities, 
accountabilities,  procedures  and  definitions  are  necessary  to  solve  the  inherent 
collective action problem of fisheries. An analysis of existing agreements of Eurostat 
with various international organisations shows that some are outdated, incomplete or 
allocate  responsibilities  unclearly.  Eurostat  recently  signed  an  administrative 
arrangement with FAO to improve data exchange based on domain-specific technical 
arrangements  specifying  contents  and  conditions  of  data  sharing,  but  this  is  only  a 
beginning. EFS are used as inputs by ICES (catches), OECD (fishing fleet, in principle 
landings  but  for  EFS  incompleteness),  FAO  (catches,  fishing  fleet,  in  principle 
aquaculture but for confidentiality and timeliness) and RFMOs (catches). DG MARE 
represents and provides data to six tuna RFMOs and nine non-tuna RFMOs38.  

Lastly, the objectives and purposes of EFS are currently not clearly stated in one legal 
document,  but  sometimes  only  mentioned  implicitly,  spread  across  several  policy 
documents  and  regulations,  or  inferred  from  wider  legislation  relating  to  Eurostat’s 
mandate and the European fisheries sector. A clear, single definition could serve as a 

38 The six tuna RFMOs are ICCAT, IOTC, WCPFC, IATTC, AIDCP and CCSBT, and the nine non-tuna RFMOs 
are  CCAMLR,  CCBSP,  NEAFC,  NAFO,  NASCO,  SEAFO,  SIOFA,  SPRFMO  and  GFCM.  See 
https://ec.europa.eu/fisheries/cfp/international/rfmo_en 

22 

 
 
 
 
 
polestar  that  EFS  could  be  oriented  towards  and  that  could  be  used  to  resolve 
uncertainties as to what EFS are for. 

As to the coronavirus crisis, it has had little effect on the EU fisheries sector as an important 
part of EU food production, and most fishery data work can be done remotely, particularly if 
data collection is digital as with fishing vessel electronic recording and reporting systems. The 
problems outlined in this section are also unlikely to be affected by the crisis because they are 
general  issues  irrespective  of  possible  short-term  data  collection  problems;  if  anything,  the 
coronavirus crisis will contribute to a further push to digitise and harmonise data collection, 
which EFS should take advantage of. But not every possible crisis is likely to leave the sector 
mostly unscathed, so EFS should be set up in a way that allows them to react flexibly to rapidly 
changing data needs or availabilities and other important external developments. 

2.2.  What are the problem drivers? 

The problems described above are mainly driven by the following factors or developments: 

•  The EU and global fisheries sector keeps changing e.g. due to 

o  The  climate  crisis,  which  has  effects,  among  others,  on  fish  stocks  and 
marine ecosystems, which can have effects, among others, on the fishing 
areas frequented, the most important species fished or the gear used 

o  Persistent  overfishing  and  other  sustainability  challenges  which  have 

effects, among others, on fish stocks and marine ecosystems 

o  Socioeconomic  developments,  such  as  more  expensive  fuel  for  fishing 
vessels, the shrinking number of European fishers, the difficulty to attract 
newcomers to the sector and changing customer tastes and sensibilities such 
as a higher demand for sustainably caught fish, which have effects on the 
fisheries sector’s behaviour 

o  Technological developments, such as more effective means to track shoals 

or innovations in aquaculture feed and rearing 

o  Political developments such as Brexit, which could affect EU access to the 

important fishing waters around Great Britain. 

These changes are outside of Eurostat’s power to influence because they are based 
on  large-scale  environmental,  social,  economic  and  political  forces,  but  through 
their effect on the fisheries sector, they determine which fishery statistics become 
available, relevant, important, and needed. 

•  Partly in response to these changes in the fisheries sector, but also to proactively 
shape fisheries and due to political pressures, the EU keeps regularly changing the 
CFP  in  order  to  safeguard  the  sector’s  economic,  environmental  and  social 
sustainability. This important regulatory and financial environment in turn shapes 
the  fisheries  sector’s  behaviour  and  incentives,  which  again  has  effects  on  data 
relevance  and  needs.  As  described  above,  the  CFP  also  heavily  influences  basic 

23 

 
 
 
 
 
 
 
 
 
data availability for Eurostat as well as the EU and global fisheries data landscape 
through large administrative data collections such as the ACDR database. Eurostat 
is part of the European Commission and cooperates with DG MARE on the data 
side of the CFP, but has little input into the main drivers shaping each reform. 

•  Other EU policies such as the European Green Deal and other organisations’ actions 
to  regulate the fisheries  sector and/or to  collect,  treat  or redistribute fishery data 
further contribute to a dynamic EU and global fisheries and fisheries data landscape. 

•  Lastly, the EFS legislation being inflexible is both a problem of EFS – in that it is 
an issue with negative effects that can and should be solved to improve EFS – and 
a problem driver – in that this inflexibility contributes to other problems such as the 
sinking relevance of EFS, gaps, overlaps and discrepancies with other fisheries data 
collections, and an unclear place of EFS in the fisheries data landscape. As long as 
it remains unaddressed, this issue will drive EFS further losing relevance. 

2.3.  How will the problem evolve? 

In the last decade, the information needs for the CFP have grown a lot, changing the framework 
in which EFS operate and their role in the fisheries data ecosystem. The reporting obligations 
of  the  reformed  Control  Regulation  have  made  a  wealth  of  administrative  information 
available, not only e.g. for monitoring quota uptakes, but also as a building block of many other 
datasets,  including  EFS  on  catches  and  landings.  However,  the  EFS  regulations  were  not 
specifically designed to use mainly administrative data as source data, but sample survey data. 
This  original  premise  had  a  strong  impact  on  the  EFS  regulations,  for  example  as  regards 
available aggregation levels. DG MARE and other users have consequently been using CFP 
and other data to fulfil their data needs because EFS cannot match the wealth of information 
offered. 

During  the  last  decade,  DG  MARE  also  recast  the  DCF  which  collects  not  only  marine 
biological data  for scientific purposes, but  also  data for  other policy needs. For fisheries, it 
entails  variables  not  collected  by  EFS  or  other  European  statistics  in  detail,  such  as 
socioeconomic data. Thus, the relevance of EFS has declined both in the European Commission 
and among external users as compared to their goal of supporting CFP policy development, 
implementation and monitoring. 

Without changes to EFS and considering the problems and problem drivers outlined above, 
EFS would likely decline further in relevance  for global fisheries stakeholders and for CFP 
purposes, as fisheries data users would more and more use other data sources that fulfilled their 
needs better, responded more flexibly to evolving requirements, and fit better into the global 
fisheries data landscape. EFS would thus slide towards obsolescence, and fishery stakeholders 
would  progressively  be  deprived  of  a  high-quality,  relevant  and  reliable  data  source,  with 
consequent negative impacts on EU and global fisheries policy. As stated above, the better the 
data, the better decisions are likely to be. The converse is also true. 

24 

 
 
 
 
 
 
 
3.  WHY SHOULD THE EU ACT? 

3.1.  Legal basis 

Article  338  of  the  Treaty  on  the  Functioning  of  the  European  Union39  outlines  the  EU 
competence  to  adopt  measures  for  the  production  of  statistics  where  necessary  for  the 
performance of the activities of the Union. In order to allow an accurate and independent follow 
up of the CFP, an exclusive competence of the Union as regards the conservation of marine 
biological  resources  (Article  3  of  the  Treaty),  high  quality,  comparable  and  harmonised 
statistics across the EU and internationally are needed. This is because common policies in and 
of themselves require such data to allocate resources fairly, efficiently and effectively and help 
make the best possible decisions across Member States. 

3.2. 

Subsidiarity: Necessity of EU action 

Fisheries are a natural, renewable and movable resource for food and other uses seen as part of 
humanity’s common heritage. In the EU, they are governed by a common policy, the CFP, with 
common rules adopted at EU level and applied in all Member States. The objectives of the CFP 
are to ensure the environmental, economic and social sustainability of fisheries and aquaculture 
and  to  provide  a  source  of  healthy  food  for  EU  citizens.  Without  a  common  policy  at 
supranational level to ensure a fair and level playing field, a collective action problem would 
ensue where each individual fisheries actor would have a rational self-interest to fish as much 
as possible, with no initial possibility of excluding any actor from doing so, as it is impossible 
to monitor the entirety of the wide seas even today. As referred to above, many fish stocks have 
historically been depleted or put into a precarious state in the absence of strong common rules. 

As an exclusive competence of the EU, the CFP is inherently subject to EU action. Producing 
EFS  can  be  better  achieved  at  EU  level  because  only  the  Commission  can  coordinate  the 
necessary harmonisation of the statistical information at Community level to serve the needs 
of the CFP managed at the EU level, and those of other EU policies requiring fisheries statistics. 

3.3. 

Subsidiarity: Added value of EU action 

EU action in fisheries statistics, i.e. collecting, harmonising and publishing fisheries data based 
on  common  regulations,  facilitates  the  collection  of  data  at  the  same  level  of  detail  in  all 
Member  States.  It  imposes  the  application  of  common  standards,  definitions  and 
methodologies  which,  in  addition  to  producing  comparable  results  at  the  service  of 
management  and  analysis  needs  for  the  CFP  and  other  EU  policies,  improve  efficiency, 
timeliness, reliability and harmonisation, or in short, increase data quality. A common fisheries 
policy must inherently be based on comparable, harmonised and high-quality data which can 
only be ensured by action at EU level. 

The regulations framing EFS are crucial for the availability and quality of the statistics. They 
stipulate the lists of variables to be provided, main definitions to be used, the reporting system, 

39 Consolidated version of the Treaty on the Functioning of the European Union, OJ C 326, 26.10.2012, p. 47–

390 

25 

 
 
 
 
 
 
submission  and assessment  procedures, deadlines and geographic coverage.  In addition,  the 
regulations  ensure  quality  control  mechanisms  and  the  availability  of  metadata.  For  these 
reasons, national EFS providers and institutional stakeholders such as Commission services, 
FAO or ICES have stressed the importance of a legal basis for EFS. 

The  added  value  generated  by  the  obligation  to  comply  with  the  EFS  acts  stems  from  the 
complete chain starting from user needs, definitions and requirements, continuing with the co-
ordinated compilation  and transmission of statistics and  with the shared quality  criteria and 
validation framework, and finishing with the monitoring ensuring compliance with the legal 
frame.  This  complete  process  ensures  the  availability  of  EFS  covering  the  EU  and  EFTA 
countries to the wide user community. The availability of long, comparable time series of EFS 
in  a  consolidated  publicly  available,  free  of  charge  database  accompanied  by  harmonised 
metadata could not be achieved by individual actions of countries, yet is advantageous to track 
trends and monitor and evaluate policies. The use of separate national sources, even if they 
were harmonised – which they would have little incentive to be without a common rationale 
and coordinating body  –, would  be much more cumbersome and hindered by technical  and 
linguistic barriers.  

EFS also create added value when compared to other types of fisheries data; institutional users 
consider the independence of official statistical information to be fundamental. Policies cannot 
be  evaluated  and  analysed  credibly  without  independent,  objective  data  sources  such  as 
European statistics. Moreover, the economic playing field is levelled by reducing information 
discrepancy between larger and smaller actors, leading to healthier competition. 

The ESS with Eurostat as the coordinating body and guardian of statistical principles ensures 
the application of the European Statistics Code of Practice, the harmonisation of definitions 
and  statistics,  the  maintenance  of  updated  statistical  laws,  and  alignment  with  international 
statistical  standards  such  as  those  of  the  CWP.  These  statistical  principles  are  enforced  by 
Eurostat validation and quality reporting and highly valued by national and international users 
because they meet their needs. They are also taken as an example by other institutions working 
with  fisheries  data,  and  due  to  the  complex  web  of  EFS  data  transmissions  to  international 
organisations  mentioned  above,  users  of  e.g.  FAO  fisheries  data  based  on  EFS  also  benefit 
from European statistical principles, sometimes without being aware of it. Similarly, national 
aquaculture data, which some users prefer over EFS aquaculture data, have often been collected 
under the rules of the EFS aquaculture regulation. This wide relevance of EFS beyond the data 
in Eurostat’s online database has been confirmed by case studies and interviews conducted for 
the evaluation. 

In short, the EU added value of EFS lies in the consistency, quality and internal coherence of 
the statistics, as well as their accessibility and clarity. EFS provide an EU-wide framework for 
data collection and supply of fisheries and aquaculture statistics using concepts and definitions 
that are harmonised across all Member States. This could not be achieved by Member States 
acting in isolation, but only by a common and coordinated approach in the ESS. 

26 

 
 
 
 
4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1.  General objectives 

The  general  objectives  of  EFS  are  currently  outlined  in  Article  2  of  the  “Statistical  Law”, 
Regulation (EC) No 223/2009, which lists the statistical principles governing the development, 
production and dissemination of European statistics; intermittently and implicitly in the five 
EFS  regulations;  and  in  objective  8.4.  of  the  European  Statistical  Programme  (ESP;  the 
framework in which all statistical activities of Eurostat are embedded), which states as the goals 
of EFS to process and publish independent, accurate, timely and comparable fisheries statistics 
at EU level to support the development and monitoring of the CFP, the management of EU 
fishery resources and of the fishing and aquaculture sectors and markets, and meeting the EU’s 
international obligations to provide fishery statistics to international organisations and RFMOs. 
These  aims  are  also  tied  to  the  six  main  priorities  of  the  von  der  Leyen  Commission,  in 
particular “A European Green Deal” and “An economy that works for people”. 

In order to optimally fulfil these objectives, the project aims to streamline and simplify EFS by 
improving the system of collecting, producing and disseminating European fishery statistics so 
that they can better and more flexibly meet user needs, while at the same time reducing burdens 
and costs on data respondents and producers, eliminating gaps, overlaps and discrepancies with 
other fisheries data collections, and finding the appropriate place for EFS in the global fisheries 
data landscape. 

4.2. 

Specific objectives 

•  Increase the relevance of EFS. For example, the EFS regulations should be aligned 
with the latest CWP concepts and classifications. EFS catch data usually do not include 
discards  or  other  catch  that  is  not  landed  because  they  are  mostly  calculated  from 
landings  using  different  conversion  factors  by  species  and  presentation  (e.g.  gutted 
mackerel or plaice fillet) as “nominal catches”, which makes them less usable for the 
CFP landing obligation. This could be changed. And EFS aquaculture data should be 
improved to contain fewer confidential values and more timely data publication. 

The attainment of this objective could be measured by an increase in the number of data 
downloads from Eurostat’s database and by making an inventory of new data needs to 
check  when  they  have  been  answered.  These  metrics  would  point  to  an  increased 
interest in EFS, suggesting a higher relevance ceteris paribus, and show EFS answering 
to evolving data requirements. 

•  Meet EFS user needs better and more flexibly. As stated, the current legal framework 
of EFS is successful in producing quality statistics, but user needs have changed and 
continue to change, and the evolution in the nature and availability of alternative data 
sources merits reexamining and updating the legal acts to ensure that they are flexibly 
addressing those user needs that cannot or should not be met by other data sources. For 
example, users have requested that EFS should cover more FAO fishing areas than the 
current seven. In order to make better use of delegated and implementing acts that offer 

27 

 
 
 
 
 
 
the  possibility  for  comparatively  rapid  changes  e.g.  in  variable  lists  or  allowed 
methodological  approaches,  the  regulations  could  be  reconstructed  in  a  modular  or 
framework fashion. In order to resolve definitional issues and reduce complexity, the 
rules that are currently spread across five regulations, but also across parts of the control 
framework  and  the  DCF,  could  be  consolidated  into  a  single  legal  act.  Legislative 
flexibility is also needed to take account of innovations and emerging phenomena in 
the aquaculture sector, where e.g. more seaweed and algae data and better definitions 
of “first sale” and “juveniles” could improve the economic picture. 

Lastly, while EFS provide high-quality statistics overall, there are some weaknesses in 
the level of quality of data collection at Member State level that should be addressed to 
further  improve  the  overall  quality  of  the  statistics.  The  evaluation  found  different 
levels of quality checks undertaken and different data collection processes at national 
level.  Additional  training  and  support  for  Member  States  as  well  as  clearer  quality 
guidelines  in  legislation  would  improve  the  quality  of  EFS  overall  in  future  years, 
particularly with respect to the design, implementation and quality assurance of the data 
collection. 

This objective could be measured by indicators such as the share of FAO fishing areas 
covered by catch statistics and the shares of EFS users rating their quality, timeliness 
and  comparability  as  good  or  very  good,  in  order  to  create  an  external  quantitative 
assessment in addition to the internal, more process-focused quality assessment. 

•  Resolve the EFS confidentiality issues. In order to reduce the high share of confidential 
data in EFS aquaculture and increasingly in EFS catch statistics and thus to increase 
their  usefulness,  fewer  breakdowns  for  less  important  aquaculture  and  catch  species 
should be requested, and Eurostat should also adopt more advanced rules of protecting 
confidentiality while ensuring as much data access as possible. 

This objective could be measured by counting the number of confidential data cells and 
the number of published EU aggregates in aquaculture statistics. 

•  Solve  the  quality  problems  of  EFS  source  data.  Eurostat  should  better  clarify  and 
codify the responsibilities and rules for the access, use, amendment and maintenance of 
administrative  data  sources  with  the  holders  of  those  data  sources,  for  example  as 
regards  interfaces,  validation,  quality  and  adherence  e.g.  to  the  European  Statistics 
Code of Practice. These cooperations should be tailored to the respective relationships 
which  can  differ  for  example  with  regard  to  the  frequency  and  importance  of  data 
extraction or whether public or private entities are holding the data. The instruments 
used  to  formalise  the  cooperations  could  accordingly  range  from  Memoranda  of 
Understanding to legislative powers such as those already included in the “Statistical 
Law” or those recently included in Regulation (EU) 2019/2152 on European business 

28 

 
 
 
 
 
 
statistics  (Article  5)40.    These  instruments  would  help  resolve  issues,  minimise 
transaction  costs,  stabilise  the  relationships  and  also  serve  as  a  model  for  similar 
relations  in  other  domains  of  statistics.  In  the  future,  statistical  offices  and 
administrative  data  holders  should  cooperate  from  the  beginning  in  order  to  set  up 
administrative data collections from the ground up so that more synergies are achieved, 
for example by aligning definitions from the start and periodically realigning them, as 
different  implementations  and  uses  will  over  time  inevitably  lead  to  discrepancies. 
These  actions  would  help  overcome  otherwise  systemic  difficulties  for  statistical 
offices to access, influence and validate administrative data sources. 

Measuring  this  objective  would  be  more  challenging  than  for  other  objectives,  but  
could  be  achieved,  for  example,  by  checking  whether  the  quality  assessment  of 
administrative source data is better aligned with statistical quality criteria. 

•  Reduce gaps, overlaps and discrepancies in the EU and global system of fisheries 
data. Persistent large overlaps and discrepancies as evidenced  in the EFS evaluation 
incur a reputational risk and confuse statisticians, policy-makers, media and the public. 
The principle of “collect once, reuse multiple times”  should be followed as much as 
possible  to  reduce  burdens  and  costs  and  increase  clarity.  For  this,  data  definitions, 
reporting  requirements,  handbooks  etc.  should  be  aligned  between  Eurostat,  DG 
MARE, international organisations and RFMOs as much as possible, and data flows 
should  be  optimised  towards  single  data  collection  points  and/or  standardised 
information  exchange  platforms.  For  example,  ideally  none  of  the  data  collected  by 
Eurostat  should  also  be  collected  from  EU  Member  States  by  international 
organisations. At a minimum, the EFS evaluation showed that optimally, only Eurostat 
should deliver EFS to FAO and OECD on behalf of EU and EFTA countries. Eurostat 
should  therefore  intensify  its  harmonisation  efforts  which  have  so  far  yielded  some 
successes, e.g. OECD sourcing aquaculture data only from FAO instead of also from 
EU Member States, but still need to tackle important areas of gaps and overlaps such 
as between EFS and DG MARE’s fisheries data collections. Eurostat would be well-
placed to take on a central coordinating role in this task by continuously engaging and 
consulting with Member States and international organisations, as it is already doing 
so. Revisiting the legal framework for EFS would also help in addressing these issues. 

Measuring the attainment of this objective would be relatively straightforward by, for 
example, assessing the number of administrative sources used replacing survey data, 
and  finding  a  reduction  in  the  number  of  data  flows  from  countries  to  the  EU  and 
international organisations. 

•  Clarify the place of EFS in the EU and global fisheries data landscape. As described 
in section 2, the objectives of EFS are currently spread across several policy documents 
and legal acts and not entirely clearly stated, the statistics are not used much for the 
purpose of serving the CFP, and the EU and international fisheries data landscape has 

40 Regulation (EU) 2019/2152 of the European Parliament and of the Council of 27 November 2019 on European 
business statistics, repealing 10 legal acts in the field of business statistics, OJ L 327, 17.12.2019, p. 1–35  

29 

 
 
 
 
 
changed a lot since the adoption of the EFS regulations. The objectives of EFS should 
therefore be redefined and stated in a clear and concise manner in a single document, 
preferably with legal force, and Eurostat should support further efforts to reorder the 
EU  and  international  fisheries  data  landscape  for  the  benefit  of  data  users  and 
producers. Areas of contradiction, overlap, duplication or complementarity as well as 
stakeholders’  relevant  experiences  and  perceptions  should  be  identified  and  then 
improved  in  cooperation  between  Eurostat,  other  Commission  Directorates-General 
and Services, and international organisations. 

In addition, given the continued precarious state of many marine basins and fish stocks 
particularly in the Mediterranean, an argument could be made that the current EU and 
global fisheries data landscape is not contributing enough to the environmental, social 
and economic sustainability of fisheries, and should be reordered accordingly. 

This objective could be assessed as attained if there were a single reference document 
stating the objectives of EFS and if the wider fisheries data landscape were discussed 
in  the  Directors’  Group  on  Agricultural  Statistics  (DGAS),  within  the  EU  and  in 
international venues such as the CWP. 

These objectives are interlinked in a number of ways. For example, meeting EFS user needs 
better and more flexibly would also increase EFS’ relevance and help resolve confidentiality 
issues. Clarifying the place of EFS in the fisheries data landscape would go a long way towards 
reducing gaps, overlaps and discrepancies and give impulses for how best to meet user needs. 
And mproving EFS source data would contribute to reducing gaps and discrepancies as well as 
to increasing the relevance of EFS. Figure 3 illustrates the full relation of the problem drivers 
to  the interconnected  problems, the objectives and the options  (see sections 5  and 6) of the 
modernisation  of  EFS.  Solid  lines  indicate  full  influences,  dotted  lines  partial  influences. 
Except for the inflexibility of EFS, most problem drivers cannot be directly tackled because 
they are either not under the control of Eurostat or, as e.g. in the case of regular CFP reforms,  
a necessary reaction of the European Commission to changes in the fisheries sector. As the EU 
wants to keep regulating the sector, it needs to adapt its relevant legislation to changes in the 
sector.

30 

 
 
 
 
Figure 3: Problem drivers, problems, objectives and options of streamlining and simplifying EFS. Source: Eurostat. 

31 

 
 
 
 
 
5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1.  What is the baseline from which options are assessed? 

As  described  above,  Eurostat  produces  EFS  based  on  five  statistical  regulations  covering 
catches,  landings  and  aquaculture,  which  are  binding  for  EEA  countries.  These  regulations 
have no end date and could therefore continue applying indefinitely. EU Member States fulfil 
their EFS obligations for catches and landings mostly by reusing administrative data collected 
for  the  implementation  of  the  CFP,  which  they  supplement  with  further  data  e.g.  on  small 
fishing  vessels  which  are  not  covered  by  the  administrative  data,  but  required  by  EFS. 
Aquaculture statistics, on the other hand, are mostly collected using surveys and censuses. In 
addition,  Eurostat  produces  EU  fishing  fleet  statistics  directly  from  the  EU  fleet  register 
maintained by DG MARE without receiving data from Member States itself, and Eurostat also 
delivers fishery statistics to various international organisations such as OECD and FAO. 

Hence, the baseline or status quo option would mean that the EU Member States and Eurostat 
would  continue  producing  EFS  under  the  current  legal  framework  of  five  regulations,  and 
Eurostat  would streamline  and simplify  the  framework as far as possible through delegated 
acts. Such adaptations could simplify and align some definitions, the lists of species and fishing 
regions, and in the case of Regulation (EC) No 218/2009 also the permitted data aggregation 
level, yet they would by design only affect non-essential elements of the legislation, i.e. be far 
from a significant overhaul.  

The groups mainly affected by EFS are data providers, i.e. fishers, aquaculture producers and 
others providing source fisheries data, and data producers, i.e. national statistical institutes and 
other  national  authorities  collecting  and  treating  fisheries  statistics.  Data  users  such  as  EU 
bodies, redistributors or scientists are also affected by the statistics as they use them for their 
work, but they do not have to do work themselves to create them. Very small enterprises, so-
called “micro-SMEs” with fewer than 10 employees cannot practically be excluded from EFS 
data collection because most EU fishing vessels have crews smaller than that. 

Producing EFS only costs about 5.6 million € annually for the entire EU, about 0.05% of the 
annual value of EU fisheries and aquaculture production. Whatever the option chosen, it can 
be expected that further digitalisation, the consolidation of the fisheries sector into fewer, but 
bigger  operators,  more  efficient  practices  at  statistical  authorities  and  similar  developments 
will  over  time  reduce  the  costs  of  data  collection  and  production.  Any  change  to  EFS  has 
therefore only a small potential to reduce costs either in absolute or relative terms, but as stated, 
the  costs  are  high  compared  to  an  ideal  state,  which  national  statistical  authorities  seek. 
However, several not directly monetary benefits such as more and better harmonised fisheries 
data,  which  could  be  used  to  improve  the  design,  implementation  and  monitoring  of  EU 
fisheries  and  related  policies,  are  sought  with  some  options,  as  analysed  below.  In  general, 
high-quality  official  statistics  are  a  comparatively  cheap  public  service  that  indirectly  more 
than  pays  for  itself  by  providing  an  important  part  of  the  necessary  objective  evidence  for 
evidence-based policies. 

32 

 
 
 
 
The main benefits of EFS, as evidenced by the evaluation and the previous  sections, can be 
summarised as follows: 

•  offering a one-stop shop overview of the European fishing and aquaculture sector which 
allows comparison, benchmarking, and analysis of long  time series for national,  EU 
and international policy making and research, and thus creates a high EU added value; 
•  supporting users with fisheries facts and figures to level the playing field and enable 
informed commercial and market decision making with reliable statistics and trends; 
•  providing all users free of charge with official, reliable, high quality fishery statistics 
that are subject to high levels of data quality verification, and are understood by users 
to be of high quality. 

These benefits are hard to quantify in a meaningful way, but are broad-ranging and consistently 
mentioned by stakeholders. EFS are highly regarded among all types of users, especially for 
their comprehensively validated quality and reliability, and are used as a reference source for 
many users and as a validation tool by many important international organisations. 

However, the problems of EFS as documented above affect assessment criteria such as those 
used for the evaluation:  

•  EFS have less relevance than they could have. 
•  EFS show effectiveness, but could be even more effective. 
•  EFS are produced with efficiency, but it could be improved. 
•  EFS show internal coherence, but their external coherence could be improved. 

If the status quo of EFS continued without solving these problems, the cost-benefit ratio of EFS 
would  likely  shrink,  as  they  would  fulfil  evolving  requirements  for  the  CFP  and  other  EU 
policies less and less. The costs and administrative burden would remain about the same as 
now,  with  small  improvements  due  to  some  streamlining  of  definitions  and  updating  of 
classifications via delegated acts. On the other hand, data providers, data producers, Member 
States and users have a good understanding of the current policy and legal framework of EFS, 
so  the  data  collection  and  validation  systems  would  continue  working  and  producing  high-
quality and comparable European fishery statistics, even if new needs were not fully satisfied. 
A more detailed impact analysis for this baseline option can be found in section 6.1. 

The  six  assessment  criteria  indicated  above  can  be  mapped  to  the  objectives  described  in 
section 4 as follows: 

•  Increase the relevance of EFS maps to the criterion of relevance. 
•  Meet EFS user needs better and more flexibly includes the criteria of effectiveness 

and efficiency. 

•  Resolve EFS confidentiality issues maps to effectiveness. 
•  Solve the quality problems of EFS source data includes effectiveness, efficiency and 

statistical quality. 

33 

 
 
 
 
 
 
•  Reduce gaps, overlaps and discrepancies in the EU and global system of fisheries 
data  maps  to  the  criteria  of  efficiency,  coherence,  EU  added  value  and  statistical 
quality. 

•  Clarify  the  place  of  EFS  in  the  EU  and  global  fisheries  data  landscape  includes 

efficiency, coherence and EU added value. 

Going forward, these objectives will be used for the impact assessment in section 6. In addition, 
the opinions of the EFS stakeholders on each option are noted. 

5.2.  Description of the policy options 

5.2.1.  Option 1: Baseline scenario – continuation of the current policy 

See section 5.1. 

5.2.2.  Option 2: Discontinuation of EFS 

All EFS regulations would be repealed. EU fishery statistics would from then on be derived 
from EU level administrative data to the extent possible, similar to the current approach for 
fishing fleet statistics, which Eurostat derives directly from the EU fleet register administered 
by DG MARE and then publishes without asking Member States for data separately or having 
a  separate  legal  basis  for  fleet  statistics.  However,  these  administrative  data  would  not  be 
supplemented  by  requirements  specific  to  EFS  anymore,  and  they  would  not  be  treated 
statistically (validation, quality reports, metadata provision etc.) anymore. EU Member States 
would continue collecting the fishery statistics they need for their national and international 
purposes, but not send them to Eurostat anymore. 

5.2.3.  Option 3: New streamlined legal framework for EFS 

A new, single streamlined framework regulation for EFS covering catches, landings, fishing 
fleet and aquaculture statistics would be introduced, and the current five regulations on catches, 
landings and aquaculture would be repealed. This would be in line with the REFIT programme 
and satisfy the von der Leyen Commission’s “one in, one out” principle for new legislative 
proposals by reducing the burden of EU legislation. 

The structure of the new EFS framework regulation would likely resemble that of other recent 
Eurostat framework regulations: a basic act fixing common statistical building blocks such as 
scope, definitions, coverage (e.g. of FAO fishing areas and fish species), allowed data sources 
(e.g.  administrative  data,  surveys  and  novel  data  sources  such  as  Big  Data)  and  quality 
assurance  procedures,  as  well  as  the  names  of  the  topics  and  detailed  topics  to  be  covered. 
These topics (for example catch, aquaculture and fleet data), their variables and further domain-
specific  requirements  such  as  statistical  observation  units,  precision  requirements,  specific 
deadlines and exemptions would be described in implementing acts, which are not adopted by 
the European Parliament and the Council of the European Union, but in the comitology process 
by  the  European  Commission  and  the  responsible  comitology  committee,  in  this  case  the 
European  Statistical  System  Committee.  Delegated  acts  would  cover  amendments  to  non-

34 

 
 
 
 
 
essential elements of the basic act, and those could be adopted by the Commission alone after 
consultation  with  Member  State  experts  and  the  possibility  of  a  European  Parliament  and 
Council veto. Such a structure would make the statistics more comparable and ensure that the 
most burden-relevant elements would be under the full control of the EU legislator, increase 
coherence across the different implementing acts, allow flexibility to address domain-specific 
differences,  and  enable  comparatively  rapid  changes  without  having  to  change  the  entire 
framework in a long legislative process with an uncertain outcome (on average, it takes more 
than 18 months for a Commission proposal to become law). In order to give the EU legislator 
a  full  picture  of  all  intended  changes,  it  would  be  advisable  to  have  draft  implementing 
regulations ready at the time when the basic act is adopted. 

EU Member States would adapt their national systems to the new framework regulation and 
then  collect  EFS  data  according  to  its  requirements  before  sending  them  to  Eurostat  for 
compilation,  validation  and  dissemination.  Redetermining  the  place  of  EFS  in  the  EU  and 
international fisheries data architecture through this option could also mean that Eurostat would 
become the single contact point for FAO and OECD in the ESS, instead of both Eurostat and 
the Member States sending data to these organisations, as they currently do to some extent. 

Eurostat, EU Member States and DG MARE could agree for Eurostat to directly access the 
ACDR system for data production and validation, a right in principle given by the “Statistical 
Law” but in this case not yet exercised in practice, among other reasons due to the discrepancies 
between Control Regulation and EFS data. Similar to Eurostat access to the EU fleet register, 
this  could  further  simplify  data  flows  in  particular  for  catches,  improve  timeliness  and 
coverage,  and  reduce  transaction  costs  and  burdens  for  Member  States,  since  they  could 
simultaneously ensure the quality of ACDR data and fishery statistics, as the validation would 
already take place at the administrative data level. 

5.2.4.  Option 4: New legal basis for aquaculture and compilation of other EFS 

from EU level administrative sources 

A new legal basis for aquaculture would be developed to resolve the issues with the current 
legislation; the legal basis for catch and landing statistics would be discontinued, and European 
catch and landing statistics would from then on be derived from EU level administrative data 
to  the  extent  possible.  The  discontinuation  of  the  catches  and  landings  regulations  and 
modernisation  of  the  aquaculture  statistics  regulation  would  be  in  line  with  the  REFIT 
programme and satisfy the von der Leyen Commission’s “one in, one out” principle for new 
legislative proposals by reducing the burden of EU legislation. 

This option would be a combination of option 3 for aquaculture statistics and option 2 for catch 
and landings statistics with their respective benefits and drawbacks, and with less cross-domain 
harmonisation than would be possible in option 3. 

EU  Member  States  would  accordingly  adapt  their  national  systems  to  the  new  aquaculture 
regulation  and  collect  data  according  to  its  requirements  before  sending  it  to  Eurostat  for 
compilation, validation and dissemination, whereas they would continue collecting the catch 
and  landings  data  they  need  for  their  national  purposes,  international  obligations  and  non-

35 

 
 
 
 
Eurostat EU  requirements. This  is  because  the legal  obligations  to  provide fisheries data to 
various international organisations would have to be met by EU Member States and potentially 
DG MARE only instead of also by Eurostat. 

5.3.  Options discarded at an early stage 

Option  4  was  originally  planned  to  include  the  integration  of  aquaculture  statistics  into  the 
proposal for a new framework regulation on statistics on agricultural input and output (SAIO) 
that  the  Commission  recently  adopted41.  The  reason  was  that  some  organisations  are  of  the 
view that aquaculture production has more similarities with animal agricultural production than 
with wild fisheries, for example controlled rearing, feeding and monitoring conditions. This is 
why e.g. FAO considers aquaculture to be a part of agriculture. However, more organisations 
group  aquaculture  in  the  same  policy  area  as  wild  fisheries,  and  funding  instruments  are 
accordingly tied to the fisheries policy area. EFS stakeholders also felt that aquaculture should 
be grouped with wild fisheries. In addition, SAIO is already advanced and would have been 
slowed  down  by  a  year  or  more  while  waiting  for  the  development  of  a  new  aquaculture 
regulation, which would have been risky particularly in light of the new Common Agricultural 
Policy reform and the European Green Deal, which require modernised agricultural statistics 
soon. Therefore, Eurostat decided to discard this option in the end. 

Other possible options would have lain between options 3 and 4, i.e. with various combinations 
of modernised and possibly integrated legal bases for catches, landings and/or aquaculture and 
discontinuations of some data collections. For example, it would in principle be possible to 
update  the  catch  and  landings  regulations,  yet  not  integrate  them,  and  not  to  update  the 
aquaculture regulation. Or to update and integrate the catch and aquaculture regulations and 
discontinue the landings regulation. But ultimately, modernising the EFS regulations without 
integrating  them  would  forgo  obvious  opportunities  to  harmonise  common  elements  and 
increase  efficiencies,  for  little  apparent  reason.  For  example,  modernising  either  catches  or 
landings statistics, but not the other would not make much sense as both depend on the same 
data sources, require each other to  provide a fuller context, and nominal catches are in  fact 
calculated from landings using a conversion factor. For these reasons, all possible “in between” 
options were crystallised in options 3 and 4, which both make the most sense prima facie and 
together incorporate the main benefits and drawbacks of full (option 3) or partial (option 4) 
modernisation, as well as those of partial discontinuation (in option 4).  

It  is  also  not  possible  to  amend  just  some  parts  of  the  EFS  regulations  to  create  additional 
options  between  the  baseline/status  quo  option  1  and  options  3  and  4.  This  is  because  the 
regulations are internally an integral whole where the articles build on each other, so significant 
changes to one part would necessitate changes in all other parts as well. Moreover, the ordinary 
legislative procedure is controlled by the European Parliament and the Council of the European 
Union  which  are  essentially  free  to  substantially  add  to,  change,  or  remove  from  European 
Commission proposals, so there would be no guarantee an intended partial change would not 

41 Proposal for a Regulation of the European Parliament and of the Council on statistics on agricultural input and 
output and repealing Regulations (EC) No 1165/2008, (EC) No 543/2009, (EC) No 1185/2009 and Council 
Directive 96/16/EC 

36 

 
 
 
 
 
result in a more complete overhaul similar to options 3 or 4. The Commission can amend parts 
of the current EFS legislation by itself with delegated acts, but these are only allowed to change 
non-essential elements. So if a lengthy and complicated ordinary legislative procedure were 
undertaken to modernise EFS, it should be worth the effort by proposing substantial changes 
to the regulations, as the workload during the procedure would be similar either way. These 
are additional reasons for the crystallisation of possible options into options 3 and 4. 

As  a  possible  technical  or  practical  option,  data  coordination  centres  were  considered.  As 
explained, data compiled under the Control Regulation are currently first provided to different 
national institutions which treat  them  to  meet  the statistical  requirements of EFS, FAO  and 
OECD and scientific requirements under the DCF. Differences between the data transmissions 
occur,  among  other  reasons,  because  of  different  definitions,  aggregations,  deadlines  and 
quality checks. It is however conceivable that the data could first be treated within one central 
node either at national level (option A: national data coordinator) or at EU level (option B: EU 
data coordinator), which would then transmit the data to all concerned inter- and supranational 
organisations. This could reduce the burden on Member States which would then not need to 
separately provide data to FAO, OECD and RFMOs, but would likely increase the costs at EU 
level. Both option A and option B assume that Eurostat would be responsible for the provision 
of statistics to FAO and OECD. This would be possible because the data definitions are similar, 
but effort would have to be expended to fully align them. 

However, such centres would not obviously fall under the purview of EFS because they would 
be neither data nor data respondents or data producers, and their operation would in any case 
depend on better data harmonisation through one of options 1, 3 or 4, so they would not be an 
option on their own, but a part of different options. Therefore, Eurostat decided to limit the 
scope of this impact assessment report to changes to the EFS regulations proper, whose remit 
is comparably well defined, and which are under the control of Eurostat. 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

The impacts of statistical regulations are more difficult to identify and quantify than those of 
many other EU initiatives. They mostly  apply  directly  only  to  data  providers, i.e. usually a 
narrow group that is  usually not  overall significantly affected by responding  to  a survey or 
census, and to data producers, i.e. a small group of organisations such as national statistical 
authorities whose job it is to create statistics efficiently, even if the creation of some statistics 
can be relatively burdensome. The direct impacts are here the resources needed to fulfil the 
legislative  requirements  of  EFS,  such  as  management  and  time/inputs  required  by  data 
providers,  data  producers,  and  Eurostat.  The  legal  acts  are  regulations  and  as  such  directly 
applicable  in  Member  States,  and  the  resulting  activities  triggered  by  their  implementation, 
such  as  collection,  processing  and  validation  of  statistics  by  the  countries  and  Eurostat, 
constitute  impacts  which  have  a  resource  cost.  The  resulting  statistical  data  do  not  have  an 
impact on the world by themselves, only indirectly through their use e.g. for policy-making, 
research or media. Such indirect impacts are hard to measure because it is often difficult to 

37 

 
 
 
 
 
know, for example, who uses statistics for which purposes, how large a part statistics play in 
the taking of certain decisions, and which effects those decisions have in the short and long 
run. Trying to assess such indirect impacts to the second or third degree would be too expansive 
and beyond the scope of this report, which is why it is not attempted here.  

But  in  general,  it  is  reasonable  to  assume  that  the  provision  of  comparable,  high-quality 
European  statistics  can  lead  to  outcomes  such  as  better  development,  implementation  and 
monitoring  of  the  CFP,  improved  market  monitoring,  and  better  assessments  of  economic 
impacts  on  fisheries  and  aquaculture.  Fishery  statistics  are  also  considered  to  contribute  to 
higher-level impacts such as supporting the sustainable exploitation of aquatic resources and 
better evidence-based decision-making overall. But as these outcomes are indirect, they cannot 
be readily quantified. In addition (as stated in section 1) the direct costs of producing EFS are 
very low (5.6 million € per year for the whole EU), so any change would only have a modest 
financial impact. 

For the reasons described, the direct economic, social, environmental and fundamental rights 
impacts of the production of official statistics are low, and as stated, “micro-SMEs” with fewer 
than 10 employees cannot practically be excluded from EFS data collection (because most EU 
fishing vessels have crews smaller than that). The impacts on these areas and on SMEs are 
therefore not separately analysed below, except for the burden and costs for data providers and 
producers. Nevertheless, in order to have a proxy for indirect impacts of statistical regulations 
on other groups, the analysis notes the effect of each option on the statistical quality, i.e. the 
independence,  comparability,  availability  of  long  time  series  on  EU  and  country  level,  and 
accessibility in a public database of EFS. The reason for this is that these criteria are relatively 
tangible and that better statistics, i.e. produced through a better quality assurance process, can 
lead to better indirect impacts because they provide a better picture of reality to base decisions 
and policies on. 

However,  mainly  “measuring  the  measurable”  risks  that  potentially  important  impacts  go 
undetected, and inferring that better statistics result in better decisions rests on the potentially 
wrong assumption that statistics and other data are used consistently and faithfully in decision-
making. Regardless of the quality of EFS, policymakers could weight other factors higher in 
their decisions in an unsystematic fashion, for example if public attention and pressure were 
suddenly  drawn  to  a  fisheries  sustainability  crisis.  The  analysis  below  tries  to  note  such 
uncertainties and potentially significant second order impacts where possible, but a complete 
assessment of every conceivable consequence of changing or not changing EFS is impossible 
(see also Annex 4). 

As EFS are statistical regulations that are directly applicable in EU Member States, no special 
support or implementation plan is needed whose impacts would need to be analysed. 

6.1.  Option 1: Baseline scenario – continuation of the current policy 

Continuing with the status quo of EFS would not solve the main problems detailed above of 
unfulfilled  data  needs,  non-harmonised  definitions,  double  reporting,  inflexibility  and  an 

38 

 
 
 
 
unclear place of EFS in the international fisheries data landscape. The cost-benefit ratio of EFS 
would  likely  shrink,  as  they  would  fulfil  evolving  requirements  for  the  CFP  and  other  EU 
policies less and less. The costs and administrative burden would remain about the same as 
now,  with  small  improvements  due  to  some  streamlining  of  definitions  and  updating  of 
classifications via delegated acts. But these delegated acts could not address the main problems 
as they can only change non-essential elements of the regulations, and changing for example 
the structure of the  EFS regulations so that they could  react  to  new developments  and data 
needs more flexibly would be a major change.  

On the other hand, data providers, Member States and users have a good understanding of the 
current  policy  and  legal  framework  of  EFS  that  has  grown  over  years.  The  data  collection, 
validation and treatment systems are in place and do not need to be changed, but  would be 
maintained. And the long, useful time series of fishery statistics would also continue unbroken 
under option 1, as would high-quality and comparable statistics on catches, landings, fishing 
fleet compositions and aquaculture at EU level in general.  

Data  producers  would  continue  collecting  and  submitting  catch,  landings  and  aquaculture 
statistics  to  Eurostat,  DG  MARE  and  other  organisations  requesting  fisheries  data,  while 
continuing to send fishing fleet data to DG MARE only (Iceland and Norway send theirs to 
Eurostat because they are not EU members). 

Correspondingly,  Eurostat  would  continue  compiling,  validating  and  disseminating  catch, 
landings and aquaculture statistics while taking fishing fleet data for EU Member States from 
the  EU  fleet  register  and  for  Iceland  and  Norway  directly  from  them,  compiling  and 
disseminating the statistics. Eurostat would also continue submitting fishery statistics to OECD 
and FAO to the extent possible due to slightly different data collections. 

Users  would  likely  continue  relying  on  EFS  for  comparable  statistics  on  catches,  landings, 
aquaculture and the fishing fleet at EU level, but among the other problems detailed above, 
their new and emerging needs would not be fully reflected.  

Overall, the possible changes within this status quo option would mean that: 

•  The  relevance  of  EFS  would  on  the  one  hand  slightly  increase  due  to  the  possible 
improvements done by delegated acts, but on the other hand continue to decrease over 
time as the CFP and fishery data needs evolved without an adequate response by EFS. 

•  Meeting EFS user needs better and more flexibly would be slightly more possible 
due to the improvements done by delegated acts and because the strengths of the current 
legal  framework  would  be  maintained,  i.e.  high-quality,  reliable  and  comparable 
official  statistics that are accessible to  the public. However, most weaknesses of the 
current  legal  framework  would  remain  unresolved,  such  as  a  high  amount  of 
confidential  data  in  aquaculture,  mostly  unmet  needs,  several  inconsistencies  and 
discrepancies, double reporting and inflexibility. 

39 

 
 
 
 
EFS would remain efficient due to the low cost of producing them. As Member States 
need to  collect  the data  underpinning EFS for other purposes as well, the additional 
administrative  burden  related  to  the  production  of  EFS  would  also  remain  limited. 
Improved  IT  tools  and  more  use  of  administrative  data  could  help  increase  the 
efficiency  further.  However,  there  would  be  no  large  efficiency  gains,  for  example 
through systematic harmonisation and elimination of double reporting, and developing 
new delegated acts would incur a small cost. It is also doubtful whether the current legal 
framework of EFS with its five regulations and overlapping reporting requirements is 
still in line with the REFIT programme, which aims to keep EU law simple, remove 
unnecessary  burdens  and  adapt  existing  legislation  without  compromising  on  policy 
objectives. 

•  The EFS confidentiality issues would not be resolved under this option because the 
improvements possible under this option could not change either the fragmentation of 
the  aquaculture  sector  leading  to  easily  identifiable  data  points,  the  Eurostat 
confidentiality  procedures,  or  the  general  structure  of  the  aquaculture  regulation 
mandating very detailed data. 

•  Solving the quality problems of EFS source data: While the statistical quality of EFS 
themselves  would  remain  high  as  the  statistics  would  continue  to  conform  with  the 
principles of impartiality, reliability, relevance, cost-effectiveness, confidentiality and 
transparency, they would not be able to be modernised and aligned well to current and 
future CFP reforms nor be able to exert much of an influence on EFS source data due 
to a lack of formalised cooperation, common database access and validation rules etc. 

•  Reducing gaps, overlaps and discrepancies in the EU and global system of fisheries 
data:  The  coherence  of  EFS  would  remain  as  it  is,  i.e.  high  internally,  but  hard  to 
maintain, and leaving overlaps and discrepancies with other fisheries data collections 
untouched, even if based on the same source data. However, EFS would still add EU 
value as the objectives of EFS can only be achieved on the basis of a common legal 
framework, such as the one currently in place, because only the EU can coordinate the 
necessary harmonisation between Member States.  

•  Clarifying the place of EFS in the EU and global fisheries data landscape. A lack 
of systematic harmonisation and a thorough revamping of the EFS regulations would 
mean that there would be little space to rethink the place of EFS, and little room for 
manoeuvre. 

•  The EFS stakeholders consulted for the evaluation are interested in streamlining the 
data collection and presentation of the statistics, but they are generally not interested in 
only  amending  the  existing  EFS  legislation  as  this  would  not  deliver  some  of  the 
changes that they desire, such as the inclusion of more fishing areas. The respondents 
to the public consultation of the impact assessment considered the impacts of this option 
on all stakeholder groups to be rather neutral, which is expected for the baseline. 

40 

 
 
 
 
This option is also technically feasible as it would mainly be a continuation of the current EFS 
system,  and likely  politically feasible  as  it  would only  introduce small  changes through the 
adoption  of  delegated  acts  which  would  be  unlikely  to  face  strong  opposition  –  unless  the 
European Parliament or the Council wanted more reform and vetoed the delegated acts, which 
is possible. 

In sum, option 1 would mostly be a continuation of the current system with all its benefits and 
drawbacks, with some small improvements through the adoption of delegated acts. Their scope 
would however be limited as delegated acts cannot change essential elements of regulations.  

6.2.  Option 2: Discontinuation of EFS 

Option 2 would mean repealing the five EFS regulations, and Eurostat would stop producing 
EFS. This would be a technically relatively straightforward administrative procedure including 
repealing  the  regulations  themselves  and  amending  any  EU  or  other  legislation  referencing 
them. It could lead to some public opposition from data providers and users, but they would 
have little power to stop the procedure. 

Discontinuing  the  EFS  regulations  and  only  creating  European  fishery  statistics  from  such 
administrative data as are available, while Member States would continue collecting the data 
they  need  for  national,  EU  and  international  purposes,  would  have  several  mostly  negative 
impacts: 

•  Relevance: Repealing EFS would lead to a loss of some important statistics which are 
usually not sourced from administrative data, such as most aquaculture statistics. Users 
and redistributors of EFS such as OECD and EUMOFA would have to shift their data 
sourcing either to the DG MARE data networks or to national sources, which would be 
more time consuming and cumbersome for them and reduce the availability and quality 
of data. This is because of technical and language barriers and because these alternative 
sources are perceived as being of lower statistical quality, as they use less structured 
quality assurance frameworks than the one implemented by Eurostat. 

•  Meet EFS user needs better and more flexibly: Repealing EFS would mean a loss of 
the legal structure that standardises the approach to producing fishery statistics across 
the EU resulting in reasonably complete, comparable, independent and validated high-
quality  catch, landings, fleet  and aquaculture statistics with  long time series that are 
publicly available to all users. As evidenced in the evaluation, this harmonised system 
represents  a  higher  added  value  than  the  sum  of  each  participant’s  individual 
contribution  because  it  establishes  a  trustworthy  and  comparable  framework. 
Moreover,  a  lack  of  a  regular,  legally  regulated  statistical  data  collection  and 
independent  EU-level  statistical  data  could  lead  to  data  only  being  collected  in  an 
unsystematic  fashion  to  respond  to  short-term  policy  needs,  which  would  result  in 
quality, comparability and predictability issues. 

41 

 
 
 
 
 
 
 
 
 
While  EU  Member  States  would  still  collect  Control  Regulation  and  DCF  data  in  a 
standardised  way  based  on  EU  legislation  under  this  option,  they  would  not  collect 
fishery statistics in a standardised way based on the EFS legislation anymore. If this 
legislation fell away, countries would thus still have CFP administrative data but not a 
harmonised approach to make statistics out of them anymore. 

As for efficiency, repealing EFS would mean that there would be no more costs and 
burdens explicitly for EFS such as producing data according to EFS requirements and 
transmitting it to Eurostat, and compiling, validating and disseminating it in Eurostat. 
However, Member States would have to produce “EFS-like” fishery statistics beyond 
the  data  available  in  administrative  sources  anyway  for  national  purposes  such  as 
national accounts, EU purposes such as DG MARE data requests, and requirements of 
international organisations such as FAO. Therefore, the actual savings could be low or 
even negative both at Eurostat where officials currently tasked with EFS would likely 
still be tasked with creating and publishing such fisheries statistics as are possible to be 
made from administrative sources (yet without as much influence on these sources as 
under other options with a legislative basis), and in Member States, as the current single 
EU-wide EFS system would be discontinued and up to 27 new national systems would 
have to be built up first. These systems would also differ between countries, increasing 
aggregation and comparison costs, and the EU would have little influence over them 
because they would be based on national laws. As these data would then exist in any 
case, Member States and the EU would have forgone an opportunity to harmonise them 
and  obtain  the  benefits  of  an  EU-wide  comparable  system.  Moreover,  without  a 
common  EU  source,  the  burden  and  cost  of  finding  the  statistics  necessary  for 
calculating  EU  aggregates  would  be  shifted  from  one  organisation  to  many  users, 
leading  to  a  large  duplication  of  work.  In  short,  there  would  be  a  loss  of  efficiency 
because  Eurostat  legislation  and  the  ESS  offer  harmonisation,  comparability  and 
standardised procedures. 

Repealing  EFS  would  also  result  in  lower  data  quality  as  the  co-ordination, 
harmonisation and quality assurance provided by the EFS regulations would not be in 
place anymore.   

•  Resolve EFS confidentiality issues: As the detailed EFS breakdowns and the Eurostat 
approach to confidentiality would fall away, it would be up to individual countries to 
deal  with  any  confidentiality  issues.  These  could  even  be  exacerbated  as  producers 
which would be anonymous in  EU aggregates  could  become identifiable  in  national 
aggregates. 

•  Solve the quality problems of EFS source data: Without EFS legislation, national 
fishery  statistics  could  not  be  well  aligned  to  current  and  future  CFP  reforms  and 
systems nor be able to exert much of an influence on the source data due to a lack of 
same-level formalised cooperation, common database access and validation rules etc. 

42 

 
 
 
 
 
 
 
 
 
•  Reduce gaps, overlaps and discrepancies in the EU and global system of fisheries 
data:  Without  common  regulations  imposing  e.g.  common  definitions  and  quality 
assurance procedures, the “EFS-like” fishery statistics in EU Member States and the 
statistics created at Eurostat from such administrative sources as there are would have 
less internal coherence than they have now, and even less external coherence because 
every data producer would work on their own without EU-level coordination. 

•  Clarify the place of EFS in the EU and global fisheries data landscape: Repealing 
EFS would incur a reputational risk for the EU, as non-EFS data made available to users 
such as  from EUMOFA and FAO  could  differ across sources, leading  to confusion, 
uncertainty and a loss of trust. The convenient EFS one-stop shop for users of high-
quality fishery statistics would be lost, and users would find it harder to  access data 
with characteristics such as long, consistent time series from 1950 on elsewhere; for 
example, DCF data only go back to 2003 at the earliest, and  EFS are easily publicly 
accessible for data users, but other sources not always. Moreover, the value of EFS as 
independent, high-quality and comparable baseline statistics used to support CFP and 
EU policies work would also be lost, and e.g. fisheries market monitoring would be 
negatively affected. Without EFS, Eurostat would also likely not contribute anymore to 
the development of international fisheries statistics standards in the CWP. This would 
be  a  loss  of  expertise  for  the  CWP,  and  for  Eurostat  a  lost  opportunity  to  develop 
international fishery statistical standards further. 

It would also be hard to explain why one of the main common policies of the EU was 
no  longer  supported  by  independent  EU  statistics  and  invite  questions  for  Eurostat, 
which is responsible for decisions on statistical methods, standards and procedures to 
be used for European statistics, in accordance with the “Statistical Law”. Moreover, the 
Commission Decision on Eurostat42 provides that the Director-General of Eurostat act 
in an independent manner when carrying out statistical tasks and should neither seek 
nor  take  instructions  from  Union  institutions  or  bodies,  from  any  government  of  a 
Member State, or from any other institution, body, office or entity.  

In  addition,  those  commitments  of  sending  EU  fisheries  data  to  international 
organisations which Eurostat is currently fulfilling with EFS would have to be fulfilled 
with  different  quality  data,  which  could  in  some  cases  be  difficult  and  incur  new 
burdens  and  costs.  Repealing  EFS  would  also  go  against  Eurostat’s  mission,  as 
expressed in the ESP, that includes providing fishery statistics for the development and 
monitoring  of  the  CFP.  The  “costs  of  non-Europe”  would  therefore  be  severe. 
Moreover,  statistical  institutes  should  in  principle  add  value  to  data  based  on  their 
expertise  instead  of  just  redistributing  administrative  data,  lest  their  contribution  is 
devalued. 

42 2012/504/EU: Commission Decision of 17 September 2012 on Eurostat, OJ L 251, 18.9.2012, p. 49–52 

43 

 
 
 
 
 
 
 
 
 
 
•  EFS stakeholders disliked this option the most according to the evaluation because it 
would  not  solve  their  problems.  The  respondents  to  the  public  consultation  of  the 
impact  assessment  considered  the  impacts  on  data  providers  and  producers  of  this 
option as positive due to a smaller burden, but as negative or very negative on various 
user groups, as the availability of statistics would drastically decrease. 

6.3.  Option 3: New streamlined legal framework for EFS 

This  option  means  that  the  current  five  EFS  regulations  would  be  replaced  by  one  new 
framework regulation for catch, landings, aquaculture and fleet statistics that would address 
the  problems  described  in  section  2  with  new  legislative  provisions  and  data  collection 
requirements  in  order  to  simplify  the  system  and  streamline  and  update  definitions, 
classifications  and  deadlines.  For  example,  the  geographical  coverage  of  EFS  catches  and 
landings could be extended as requested by users. Aquaculture statistics would be reworked to 
reduce  the  amount  of  confidential  data  and  improve  timeliness.  Legal  and  organisational 
arrangements  would  be  made  for  better  Eurostat  access  to  and  use  of  administrative  data 
sources  such  as  the  ACDR  database,  e.g.  by  pre-validating  data  already  on  that  level.  In 
addition,  mechanisms  for  allowing  more  flexibility  to  accommodate  new  needs  could  be 
integrated into the new legal architecture. This improvement of the legal framework would be 
in line with the Commission’s REFIT programme.  

The option is technically relatively straightforward, and the responsible unit in Eurostat tasked 
with  creating  the  new  framework  regulation  has  recent  experience  in  writing  framework 
regulations  to  modernise  agricultural  statistics  (Integrated  Farm  Statistics,  adopted  as 
Regulation (EU) 2018/109143, and SAIO) and in accompanying them through the legislative 
process. Other Eurostat units have similar recent experience. Although there could be initial 
costs of adaptation to a new legal framework for the Member States due to various reasons, 
they have expressed support for modernising the legal basis for EFS. In the medium to long 
term, the new legal basis could lead to savings, e.g. by increasing the use of administrative data 
and estimating and aggregating data for species of minor economic importance. 

In  addition,  NSIs,  DG  MARE  and  the  JRC  within  the  Commission,  and  international 
organisations such as FAO and OECD, should be involved in the EFS modernisation process, 
respectively  via  established  venues  such  as  the  ESS,  annual  hearings  between  Commission 
services,  and  the  CWP.  This  is  important  to  ensure  that  their  needs  are  addressed,  to  align 
definitions, data flows and deadlines, and to reorganise the EU and international fisheries data 
architecture so that user needs are met with a lower burden due to less double reporting and 
fewer gaps and overlaps, in line with the principle of “collect once, use multiple times”. The 
cooperation between institutions should accordingly be stabilised and regularised with formal 
agreements or legal provisions. For example, Eurostat producing fishing fleet statistics from 
the EU fleet register should be put under the legal framework, which non-EU members could 
then follow to deliver fleet data. Furthermore, all user needs should be reviewed to ensure that 

43 Regulation (EU) 2018/1091 of the European Parliament and of the Council of 18 July 2018 on integrated farm 
statistics and repealing Regulations (EC) No 1166/2008 and (EU) No 1337/2011, OJ L 200, 7.8.2018, p. 1–29 

44 

 
 
 
 
 
 
the new fishery statistics are useful now and in the future. However, this represents a higher 
workload than for the other options, and not  all data may be able to be aligned as different 
organisations can have justified different data needs. For example, administrative control data 
can  have  a  different  scope  than  statistics  intending  to  capture  a  full  population.  Moreover, 
negotiations with different organisations can result in compromises that do not fulfil all of the 
initial goals. 

The  main  risks  of  this  option  are  associated  with  a  protracted  legislative  procedure  due  to 
divergent interests of the Council and the European Parliament, but the modernised legislation 
itself would not be too technically complicated, and as stated, Eurostat has recent experience 
in the legislative process for framework regulations. There could also be a risk in Eurostat and 
the Member States not being able to agree on a renewed confidentiality charter so that some 
confidentiality  problems  would  persist  even  if  the  legislation  would  request  fewer 
disaggregations. 

The following impacts can be expected: 

•  Relevance: EFS would become more relevant as the new legal framework would be 
updated to better reflect current and future user needs in the context of the new CFP 
and of other evolving fishery policy data needs. Redetermining the place of EFS in the 
EU and international fisheries data architecture could for example mean that Eurostat 
would become the single contact point for FAO and OECD in the ESS, instead of both 
Eurostat and the Member States sending data to these organisations, as they currently 
do to some extent. The “Brussels effect” of EFS setting standards for other fisheries 
data collections, sometimes unbeknownst to their users, would likely increase. 

•  Meet EFS user needs better and more flexibly: EFS would become more effective 
as this option would keep their existing benefits, e.g. being a one-stop shop for high-
quality,  comparable  fishery  statistics  with  long  time  series  accessible  to  all,  while 
providing a simpler and more streamlined legal framework that can better integrate and 
serve  new  user  needs  and  increase  coverage.  Reducing  double  reporting  through 
aligning  definitions  and  reorganising  data  flows  would  also  reduce  discrepancies 
between  different  data  sources,  thus  increasing  the  reliability,  accuracy  and 
international comparability of EFS. 

Regarding  efficiency,  EU  Member  States  would  continue  submitting  landings  and 
aquaculture statistics to  Eurostat, and Eurostat would continue compiling, validating 
and disseminating them. Eurostat, the Member States and DG MARE could agree to 
grant Eurostat direct access to the ACDR system for catch data production, similar to 
the status quo for the EU fleet register for fleet statistics. This could further simplify 
data flows, improve timeliness and coverage, and reduce transaction costs and burdens 
for Member States.   

A lower burden and costs for data producers and Eurostat could be expected due to the 
new  harmonised  framework  improving  on  the  problems  of  the  status  quo,  such  as 

45 

 
 
 
 
discrepant  definitions  and  aggregations  between  administrative  data  and  statistics, 
difficult to collect data, a lot of confidential data particularly in aquaculture, and double 
reporting. The potential for improvement is higher for catches and landings than for 
aquaculture  and  fleet  data  because  the  EFS  aquaculture  data  collections  are  already 
integrated to serve both EFS and DCF needs in most countries, and fleet statistics are 
produced by a simple extraction from the EU fleet register. By comparison, EFS catches 
and landings data overlap and are not always consistent with ACDR data e.g. because 
of different definitions. In addition, countries with a large number of small vessels (e.g. 
Italy and Greece) currently have to  conduct surveys on them to provide EFS, as the 
existing Control Regulation does not oblige them to install electronic recording systems 
on  those  vessels.  However,  the  new  Control  Regulation  could  enlarge  the  reporting 
obligation  to  cover  small  vessels  as  well,  which  would  allow  reusing  related 
administrative data for statistics and obviate the need to conduct additional surveys. 

Thus, under the simplest case of option 3, Member States just deliver the necessary data 
under the Control Regulation, and Eurostat extracts the catch statistics needed at EU 
level from them. International organisations would download the data from Eurostat’s 
website, reducing the burden on data producers in Member States. Thus, EU countries 
would  not  need  to  deliver  catch  data  to  Eurostat  or  any  data  to  international 
organisations anymore and could benefit from the reduction of the data flows. 

 The burden reduction potential for data providers is limited. For aquaculture, the burden 
of EFS usually consists of some extra questions in a joint EFS/DCF questionnaire that 
plant managers fill out once a year; a few more or fewer questions would change the 
burden only slightly, even across all EU aquaculture plants. For catches, data providers 
would  still  have  to  provide  CFP  data,  and  after  the  Control  Regulation  reform,  also 
more administrative data on small vessels instead of filling out statistical surveys on 
them. 

Some  adaptation  costs  would  be  incurred  in  the  short  term  by  national  statistical 
authorities through for example having to change questionnaires and databases and by 
Eurostat. But this is a regular occurrence for those authorities and therefore unlikely to 
create implementation challenges. Burden and cost reduction through harmonisation, 
reduction of discrepancies etc. would apply in the mid to long term and therefore have 
a greater effect over time. The annual savings in direct costs linked to the catch data 
collection  for  national  statistical  authorities  are  estimated  to  be  approximately  1.2 
million € as compared to the baseline, mostly due to reduced survey and indirect costs, 
representing a total EFS cost reduction of about 20% (option 3 is expected to be cost-
neutral for data providers and Eurostat) to 0.04% of the EU fisheries and aquaculture 
sector’s annual production value. This is estimated on the basis of the plan for Eurostat 
to collect catch statistics directly from administrative data collected by Member States 
and  providing  it  to  DG  MARE,  without  Member  States  having  to  treat  it  first.  The 
savings potential of option 3 can differ between countries because of different national 
implementations  and  the  varied  fisheries  sector  across  the  EU,  e.g.  vastly  different 
numbers and sizes of vessels with different data collection and treatment challenges. 

46 

 
 
 
 
Increasing and evolving demands for more fisheries data could over time also increase 
burdens and costs again, for example by requiring data on uses of aquaculture products 
beyond human consumption, as some users ask for. On the other hand, streamlining the 
data  flows  between  Member  States,  the  EU  and  international  organisations  would 
increase the long term efficiency of fishery statistics and the fisheries data architecture 
overall. 

As an example of the improvements possible under option 3, currently the EFS catch 
regulations only cover seven FAO fishing areas near the EU: 21 – Northwest Atlantic, 
27 – Northeast Atlantic, 34 – East-Central Atlantic, 37 – Mediterranean and Black Sea, 
41 – Southwest Atlantic, 47 – Southeast Atlantic, and 51 – West Indian Ocean. But e.g. 
Spanish  vessels  already  fish  almost  around  the  globe,  and  if  for  exampleUK-EU 
conflicts  about  the  traditional  fishing  waters  around  Great  Britain    increased,  it  is 
conceivable that more EU fishing nations would explore other fishing areas with their 
bigger vessels, e.g. area 57 – the Eastern Indian Ocean. Incorporating statistics from 
this area would be hard to do in the current EFS regulations as they would need to be 
reopened in a lengthy legislative procedure. But if such a procedure is inevitable,  it 
would be more beneficial to implement bigger changes such as those included in option 
3. This is because legislative procedures require an in large part “fixed” amount of effort 
(e.g. meetings with the European Parliament and the Council of the EU, reconciling 
different versions of amendments etc.) and only some “variable” amount of effort (e.g. 
due to the length and complexity of a proposal). 

•  Resolve EFS confidentiality issues: Rewriting the EFS aquaculture regulation could 
go a long way towards fixing aggregates at a level that balances data needs and the need 
for confidentiality. Developing problems could be tackled by an easier possibility to 
amend the legislation as well as by agreeing to a confidentiality charter in the course of 
developing and negotiating the new legislation. 

•  Solve the quality problems of EFS source data: Cooperation between Eurostat and 
DG  MARE  in  the  CFP  reform  and  adapting  the  new  EFS  legal  basis  to  the 
characteristics  of  the  changed  source  data  can  help  remedy  this  issue  by  improving 
harmonisation between CFP and EFS definitions and classifications and establishing a 
more  formalised  cooperation  in  general,  for  example  with  regularly  scheduled 
realignments.  The improvements  outlined in  option 3 will also  serve to  improve the 
quality of EFS coming from other sources. 

However, this problem is in general difficult to tackle. A series of data comparisons 
between EFS and CFP data has been  made that show the extent of the problem (see 
section 2). The root causes lie in the quality of the data collected and/or in the post-
collection treatment of the data by national authorities. In both  cases, joining efforts 
across  the  data  flows  of  the  statistical  network  and  of  the  fisheries  data  network  is 
necessary to improve data quality. DG MARE has launched a series of action plans to 

47 

 
 
 
 
support improvements of the catch reporting systems in Member States that will benefit 
not only the administrative data, but also the quality of statistical data. 

•  Reduce gaps, overlaps and discrepancies in the EU and global system of fisheries 
data: The internal and external coherence of EFS would increase, as developing and 
implementing the new framework regulation would lead to more alignment both within 
and across the EFS domains as well as with external fisheries data sources. 

•  Clarify the place of EFS in the EU and global fisheries data landscape: This option 
would strengthen the Eurostat objective of the ESP to provide fishery statistics for the 
development and monitoring of the CFP. Users could continue accessing reliable and 
comparable fishery and aquaculture statistics covering all EU Member States and have 
their needs better fulfilled. The new legal framework would be able to include future 
needs to ensure the continued relevance of EFS. The statistical quality of EFS would 
also at least remain the same by them continuing to follow the principles of impartiality, 
reliability,  relevance,  cost-effectiveness,  statistical  confidentiality  and  transparency, 
and would likely increase e.g. through better operational arrangements with holders of 
administrative data sources and better availability of the data due to fewer confidential 
values. 

•  EFS stakeholders preferred this option the most when asked for the evaluation because 
they  saw  it  as  having  the  highest  chance  of  fulfilling  their  needs  and  wishes.  The 
respondents to the public consultation of the impact assessment considered the impacts 
of this option on data providers and producers as neutral to positive and on data users 
as neutral to very positive. 

In all,  this  option  would  results in  improvements in  the relevance and  effectiveness  of EFS 
through the new streamlined legal framework. It would ensure the availability of more high-
quality EFS for wide user groups and improve the efficiency and coherence of fishery statistics 
and  other  fisheries  data.  Such  a  major  reform,  while  entailing  a  certain  workload  and  time 
commitment, would represent a chance to solve many long-standing problems at once instead 
of trying to resolve them over time with less effective approaches that could in the end amount 
to an even higher expenditure of work and time. 

6.4.  Option 4: New legal basis for aquaculture and compilation of other EFS from 

EU level administrative sources 

This  option  would  mean  that  the  current  EFS  aquaculture  statistics  regulation  would  be 
replaced by a new streamlined regulation, in line with the REFIT programme, while the legal 
basis for EFS catch and landings statistics would be discontinued. European fishery statistics 
would from then on only be derived from EU level administrative data to the extent possible, 
similar to the current approach for fishing fleet statistics, which are derived by Eurostat from 
the EU fleet register without an Eurostat regulation that would, for example, require additional 
data. 

48 

 
 
 
 
Technically, this option is relatively straightforward in that the Commission would repeal the 
EFS regulations on catches and landings while developing a new regulation for aquaculture 
statistics,  something  the  responsible  Eurostat  unit  has  recent  experience  in.  However, 
streamlining definitions and classifications could be technically challenging, and politically, 
both data producers and users as well as the European Parliament and the Council could oppose 
repealing EFS for catches and landings, but with little power to stop the repeals. 

The  likely  impacts  for  this  option  would  be  a  mixture  of  those  of  option  3  for  aquaculture 
statistics and those of option 2 for catch and landings statistics:  

•  Relevance, meeting EFS user needs better and more flexibly  and resolving EFS 
confidentiality issues increased for  aquaculture statistics, similar place of EFS in 
the EU and global fisheries data landscape: the new aquaculture regulation would 
entail a lower burden and costs for comparable and high-quality aquaculture statistics 
and better meet current and future user needs. For example by including information on 
aquaponics  or  using  insects  as  feed,  creating  less  confidential  data  through  more 
suitable  data  aggregations,  and  better  aligning  classifications  with  the  latest  CWP 
classifications. EFS data producers would thus continue providing aquaculture data to 
Eurostat, which would continue compiling, validating and disseminating aquaculture 
statistics.  

However,  there  would  likely  only  be  modest  efficiency  gains  because  of  this  new 
regulation, as the streamlining efforts and the new data needs could balance each other 
out. As stated previously, the amounts involved are small in any case as EFS production 
is comparatively very cheap across the EU. These statistics would also continue adding 
EU  value  through  a  common  methodological  framework  creating  comparable,  high-
quality  aquaculture  statistics.  Moreover,  EFS  aquaculture  statistics  are  an  important 
basis  for  DG  MARE  to  analyse  socio-economic  and  environmental  impacts  of  the 
sector. 

•  Relevance, meeting EFS user needs better and more flexibly  and resolving EFS 
confidentiality issues reduced for catch and landings statistics, similar place of EFS 
in  the  EU  and  global  fisheries  data  landscape:  data  producers  would  not  provide 
catch  and  landings  statistics  directly  to  Eurostat  anymore  and  Eurostat  would  stop 
compiling, validating and disseminating them beyond extracting them from available 
administrative  sources  to  the  extent  possible  and  publishing  those  data  as  EFS. 
However, as explained in the impact analysis of option 2, “EFS-like” data would most 
likely continue to be produced by Member States anyway for national and international 
purposes. Therefore, there would likely be only modest gains in efficiency, if any, both 
for  data  providers,  data  producers  and  Eurostat.  Aggregation  and  comparison  costs 
would  increase  because  Member  States  would  choose  different  approaches  in  the 
absence of an EU-wide harmonised legal basis. The use of administrative data without 
significant additional validation steps also entails risks in ensuring coverage, quality, 
data availability, timeliness and long time series. The EU added value of these catch 

49 

 
 
 
 
and landings data produced directly from administrative data would be lower than that 
of EFS because of the lack of additional validations and a common, harmonised legal 
basis that also serves as an inspiration for other producers of fishery data in the world. 
Handling  catch,  landings  and  aquaculture  statistics  differently  would  also  forgo 
opportunities to harmonise all EU fisheries statistics and to enable a more holistic view 
of the fisheries sector that could support better policy-making in this area; for example, 
a lot of aquaculture feed consists of catches of wild fish. Lastly, the legal obligations to 
provide fisheries data to various international organisations would have to be met by 
EU Member States and potentially DG MARE only instead of also by Eurostat. 

Repealing the catch and landings EFS regulations would also reduce double reporting 
by Member States to the EU in line with the principle “collect once, use multiple times”, 
creating a small efficiency gain. In short, there would be a loss of efficiency because 
Eurostat legislation and the ESS offer harmonisation, comparability and standardised 
procedures. 

•  The  objectives  of  solving  the  quality  problems  of  EFS  source  data  and  reducing 
gaps,  overlaps  and  discrepancies  in  the  EU  and  global  system  of  fisheries  data 
would  suffer  under  this  option  because  there  would  be  no  regulations  for  catch  and 
landings statistics anymore imposing common concepts, definitions etc. both on EFS 
themselves  and  on  EU  Member  States  producing  them,  no  integration  of  catch  and 
landings statistics with aquaculture statistics, no in-depth cooperation with the Control 
Regulation system, and no more coordination with international organisations. 

•  Only few EFS stakeholders preferred this option as their first choice when asked for 
the evaluation because they thought that their data needs and requirements e.g. for more 
flexibility of EFS would not be met by a partial repeal. The respondents to the public 
consultation  of  the  impact  assessment  considered  the  impacts  of  this  option  on  all 
stakeholder groups to be negative to neutral. 

In summary, although option 4 improves EU aquaculture statistics, it entails a partial loss of 
reliable, accessible and comparable statistics on catches and landings.  

7.  HOW DO THE OPTIONS COMPARE? 

Given the objectives of streamlining and simplifying EFS as described in section 4, the options 
as  described  in  section  5  and  the  impacts  as  analysed  in  section  6,  the  following  option 
comparison table 1 can be constructed, with thehe  following rows as measured against the 
baseline: 

•  Time horizon: short term  (ST) and  long  term (LT) to  show the different  impacts  of 
adhering to each option over time. In general, as the fisheries sector will continue to 
change as outlined in section 2.2 of this report and EU fisheries policy legislation will 
also change in response, the available data and users’ data needs will over time drift 

50 

 
 
 
 
 
further away from EFS if the legislation they are based on remains inflexible, and EFS 
will thus get progressively worse. 

•  Effectiveness with regard to the objectives 
•  Cost-efficiency 
•  Coherence with EU policy objectives 
•  Impacts on stakeholders, i.e. EFS data users, data producers and data providers. 

Table 1: Option comparison against the baseline. Source: Eurostat. 

Very positive impact 
Positive impact 
Neutral impact 
Negative impact 
Very negative impact 

+ + 
+ 
0 
- 
- - 
ST = short term; LT = long term 

Option 

1: Baseline 
– EFS 
continue 

2: Repeal 
EFS 

3: New 
framework 
regulation 
for all EFS 

ST  LT 

ST  LT 
- - 
- - 

ST 
+ 

LT 
+ +  

4: New 
aquaculture 
regulation, 
repeal catch 
and landings 
ST 
- 

LT 
- - 

0 

-  

- - 
- 
0 

- 

- - 

- - 
- 
0 

0 

+ 

+ 
- 
0 

+  

+ + 

+ + 
0 
+ 

0 

- 

- 
- 
0 

- 

- 

- 
- 
0 

Type of impact 
Time horizon 
Effectiveness with regard to the 
objectives 
Cost-efficiency 

Coherence with EU policy 
objectives 
Impacts on 
stakeholders 

Data users 
Data producers 
Data providers 

It can be seen that option 2 has very negative impacts in the short term and even worse ones in 
the long term. Option 3 is promising in the short term and can be expected to create even more 
positive impacts in the longer term. And option 4 has some negative impacts in the short term 
which can be expected to get worse over time. 

8.  PREFERRED OPTION 

In light of the impact analysis in section 6 and the option comparison in section 7, the results 
of the consultation activities outlined in Annex 2 and in the EFS evaluation, and discussions 
with  the  stakeholders,  the  preferred  option  is  clearly  option  3  –  a  new  streamlined  legal 
framework for EFS. It is supported by the main data users (DG MARE, OECD, FAO, ICES 

51 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
and  several  RFMOs).  A  large  majority  of  the  representatives  of  the  national  statistical 
authorities responsible for fisheries statistics expressed a clear preference for option 3 in the 
meetings of DGAS in June 2019 and again in June 2020. Occasional users of EFS such as the 
Commission Directorate-General for Trade, which mostly uses trade statistics and only rarely 
fisheries production data via EUMOFA, also prefer option 3 to have reliable, accessible and 
comparable fishery statistics that better serve users’ needs.  

Option 3 was also the preferred option in the public consultation. It was supported by seven of 
15 respondents. The supporters of option 3 were regional, national and international authorities 
and NGOs. The respondents also gave their opinions on the expected impacts of the options on 
five stakeholder categories: data producers (statistical authorities), data providers (fishers, fleet 
and aquaculture plant managers), policy makers, professional users (e.g. NGOs and business 
associations),  and  citizens  and  others.  Option  3  scored  the  most  positive  impacts  on  all 
stakeholder  groups.  In  addition,  only  very  few  respondents  identified  negative  impacts  for 
option 3. Table 2 below offers an overview of the preferred option by type of stakeholder group 
by summing up the answers from the various consultations. 

Table 2: Ranking of preferred options by type of stakeholder group. Source: Eurostat. 

Option 1: 
Baseline – 
EFS 
continue 
Not 
impacted 
2. (8%) 

Option 2 
– Repeal 
EFS 

Not 
impacted 
4. (4%) 

Option 3 – New 
framework 
regulation for 
all EFS 

Not 
impacted 
1. (80%) 

Option 4 – New 
aquaculture 
regulation, repeal 
catch and landings 
Not 
impacted 
2. (8%) 

4. (0%) 

4. (0%) 

1. (100%) 

4. (0%) 

3. 

4. 

       1.  

2. 

Data 
providers 
Data 
producers 
Data users 
EU 
Institutions 
International 
organisations 

Option  3  responds  best  to  the  objectives  of  the  REFIT  programme  by  simplifying  and 
streamlining the five legal texts currently governing EFS into one coherent legal framework. 
Option 3 is also most in line with the mission and strategy of Eurostat. Independent EFS are 
inherently important for the design, implementation, monitoring and evaluation of the CFP and 
related EU policies. Option 3 allows aligning statistical requirements flexibly with evolving 
user needs and to develop a coherent Commission-wide strategy and renewed architecture for 
fisheries data instead of the current partly uncoordinated and duplicated approaches. This is 
important for efficient policy delivery and resource use. 

The expected cost savings of pursuing option 3 are detailed in table 3 below. The option will 
lead  to  the  reduction  of  costs  and  burdens  in  several  ways.  Firstly,  it  will  cut  double  data 
collection for catch statistics, as the data will be taken directly from an EU-level administrative 

52 

 
 
 
 
 
 
 
source. This reduces the administrative and data collection costs and also the time expenditure 
for data respondents, i.e. fishers and aquaculture plant managers. Secondly, other international 
organisations can take the data, which better meet their needs, directly from Eurostat without 
also asking EU Member States to deliver it to them. Thirdly, more data will become available 
to data users when the data structure for aquaculture will be simplified, and consequently less 
data will be confidential. And fourthly, the simplification of the data will ease the burden on 
data providers and data producers.  

Lastly, option 3 is a proportional response to achieve the objectives outlined in section 4 and 
solve the problems described in section 2. This is because a less comprehensive legislative and 
organisational  reform  of  EFS  would  not  be  able  e.g.  to  meet  user  needs  better  and  in  a 
structurally  more  flexible  fashion,  nor  to  redefine  the  place  of  EFS  in  the  fisheries  data 
landscape, as explained in section 6. And as described in section 3, EU Member States could 
not achieve the necessary harmonisation and coordination to produce coherent EFS acting on 
their own. At the same time, a new streamlined legal framework for EFS would not go beyond 
what is necessary to modernise the data collections for catches, landings, aquaculture and fleet 
while  respecting  the  principle  of  subsidiarity,  e.g.  by  leaving  the  choice  of  data  sources  to 
Member State authorities. 

The preferred option is also proportional to the general and specific objectives and does not go 
beyond  what  is  needed  to  address  the  identified  problems  because  in  principle,  legislative 
flexibility requires implementing and delegated acts because those can amend important and 
non-essential  elements,  respectively,  of  legislation  faster  and  with  less  overhead  than  an 
ordinary  legislative  procedure.  But  there  should  still  be  a  harmonised,  permanent  act  for 
elements that need to be standardised across secondary legislation and are unlikely to change 
much over time, such as scope, coverage or quality requirements. From  these constraints, a 
framework  structure  with  a  basic  regulation  and  several  implementing  and  delegated  acts 
follows naturally, so it can be seen as proportional to solve the problems. At the same time, 
there will be safeguards and limits so that subsidiarity and proportionality will be respected 
and burdens and costs kept in check. 

8.1.  REFIT (simplification and improved efficiency) 

Table 3: REFIT cost savings of preferred option 3. Source: Eurostat. 

Description 

Amount 

Comments 

Catch data collection: Reduction of 
burden and costs by cutting double 
data collections for catches 

Annual savings for direct costs 
linked to the catch data collection 
estimated to be approximately 1.2 
million € if compared to baseline 

It is planned to produce the catch 
statistics from an EU-level 
administrative data source. The Member 
States would not need to collect catch 
statistics any more.  

Direct and indirect cost savings to data 
producers (national statistical institutes 
and other national authorities). The cost 

53 

 
 
 
 
 
Use of the same data by international 
organisations 

Slight reduction in burden at 
Member State level and at 
international organisations 

Improving effectiveness: reduction of 
confidential data 

About 20% more data will be 
accessible to data users with the 
same cost as before 

Simplification of the collected data 

Slight reduction in administrative 
burden and burden on respondents 

savings are based on the figures 
provided by the Member States and they 
stem mostly from indirect costs and 
survey costs.   

The change is estimated to be cost 
neutral to Eurostat. 

Data producers (national statistical 
institutes and other national authorities) 
and data users (international 
organisations) benefit from simplified 
data flows; “collect once, use multiple 
times” 

Effectiveness improvement as more data 
becomes available to data users with the 
same cost and burden on data providers 
and data producers. This saving is 
produced by simplifying the data 
structure of aquaculture and thus making 
more data available to users with a 
slightly reduced cost.  

Data producers (national statistical 
institutes and other national authorities) 
and data providers (fishers and 
aquaculture plant managers) benefit 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The  existing  monitoring  and  evaluation  tools  which  are  in  place  and  being  used  for  the 
statistical production and dissemination of European statistics will also be used to monitor and 
evaluate the impacts of EFS. These tools will enable analysis of the effectiveness and efficiency 
of the new statistical initiative and of the quality of the data produced. In detail, they are:  

•  The ESPs foresee systematic mid-term and final evaluations. Fisheries statistics are part 

of this reporting mechanism44 

•  The Eurostat Management Plan foresees the follow-up of key performance indicators, 

which also applies to fisheries statistics45 

44 See https://ec.europa.eu/eurostat/web/quality/general-evaluation-results 

45 The five key performance indicators are the following ones:  1) number of data extractions made by external 
users from the Eurostat reference database via the Eurostat website; 2) percentage of users that rate as "very 
good" or "good" the overall quality of European statistics; 3) percentage of users that rate as "very good" or 
"good" the timeliness of European statistics for their purposes; 4) percentage of users that rate as "very good" 
or "good" the comparability of European statistics among regions and countries; and 5) residual error rate. 

54 

 
 
 
 
 
 
 
 
•  User satisfaction surveys are carried out on an annual basis46 
•  EFS  also  requires  the  production  of  standard  quality  reports,  regularly  produced  by 
Member States and Eurostat, as part of the Statistical Quality Assurance Framework. 

Eurostat and the national statistical authorities will further improve the standard metadata and 
quality reporting system for fishery statistics. This will allow a more sophisticated monitoring 
and  evaluation  of  the  statistical  processes  used  in  the  Member  States  and  of  the  output 
disseminated.  For  example,  more  detailed  information  will  be  available  on  the  use  of 
administrative data sources by Member States, which can lead to a reduced burden. The results 
and  the  effects  of  the  EFS  legislative  initiative  will  regularly  be  monitored  via  annual 
compliance  and  quality  reports.  In  order  to  measure  the  progress  towards  achieving  the 
objectives of the initiative, the list of monitoring indicators in table 4 below has been defined. 
These indicators are juxtaposed against a list of operational objectives which have been derived 
from the specific objectives. The indicators will be measured against the benchmark targets 
indicated in the last column of the table. 

Eurostat needs to rely on user surveys and direct contacts with data producers and data users 
in order to monitor and evaluate the impacts of its statistics since, as explained, the statistics 
do not have a direct effect in the world by themselves. But Eurostat’s cooperation with data 
producers and data users is long established, trustful and takes place in regular fora and frequent 
informal  exchanges;  in  fact,  most  problems  of  EFS  and  the  main  requests  to  improve  the 
statistics were brought up within this cooperation, so it can be expected that the actual effects 
of a modernisation of EFS, whether positive or negative, will also be comprehensively raised 
during future exchanges with the data producers and users. 

Compliance is usually not a large problem for EFS because the statistics are either based on 
administrative data which are obligatory under the Control Regulation or on surveys where the 
response rate is generally high. Sometimes the data are sent to Eurostat with a short delay, for 
example  due  to  a  change  of  information  technology  systems.  The  new  legislation  in  the 
preferred  option  3  is  not  expected  to  affect  compliance  in  a  negative  way;  on  the  contrary, 
compliance should improve as less data are expected from Member States and more statistics 
can be drawn directly from Control Regulation data by Eurostat.  

Table 4: Monitoring and evaluation indicators. Source: Eurostat. 

SPECIFIC 
OBJECTIVES 

OPERATIONAL 
OBJECTIVES 

KEY PERFORMANCE 
INDICATORS 

TARGETS 

• 

Increase the relevance 
of EFS 

• 

Increase the number of users of 
EFS 

KPI1 

Number of data 
downloads from 
Eurostat’s database 

Source:   Eurostat data 

download statistics 

50% increase by 5 
years after the start 
of the application of 
the EFS Regulation 
(as compared to the 
last year before the 
entry into force) 

46 See http://ec.europa.eu/eurostat/web/quality/general-evaluation-results 

55 

 
 
 
 
 
 
 
 
 
Introduce new data requirements 

Cover all FAO fishing areas in 
catch statistics 

KPI2 

Inventory of new data 
needs and when they 
have been answered 

Source:   Data users’ 

consultations 

KPI3  

percentage of FAO 
fishing areas covered 
by catch statistics  

Source: EFS quality reports 

• 

• 

• 

• 

• 

KPI4 

Percentage of users 
that rate as "very 
good" or "good" the 
overall quality of EFS 
provided by Eurostat 

Percentage of users 
that rate as "very 
good" or "good" the 
timeliness of EFS for 
their purposes 

Percentage of users 
that rates as "very 
good" or "good" the 
comparability of EFS 
among countries 

Meet EFS user needs 
better and more flexibly 

•  Define a harmonised data quality 

framework across EFS 

KPI5 

KPI6 

• 

Resolve the EFS 
confidentiality issues 

• 

Increase the data availability 

Source:  Annual Eurostat user 

satisfaction survey  

KPI7 

Reduce the number of 
confidential data cells 
in aquaculture 

KPI8      Increase the number of 
published EU-
aggregates in 
aquaculture 

Source:  Eurostat’s database 

Solve the quality 
• 
problems of EFS source 
data 

Ensure the quality of source data  

KPI9       Improve in quality 
assurance of source 
data 

A draft reply to new 
data needs received 
in year t is discussed 
with the experts of 
the relevant working 
group in year t+1 

100%   

60% within 5 years 
of implementation of 
EFS 

60% within 5 years 
of implementation of 
EFS 

60% within 5 years 
of implementation of 
EFS 

20% reduction by 5 
years after the start 
of the application of 
the EFS Regulation 
(as compared to the 
last year before the 
entry into force)  

20% increase by 5 
years after the start 
of the application of 
the EFS Regulation 
(as compared to the 
last year before the 
entry into force)  

Quality assessment 
of administrative 
source data aligned 
better with statistical 
quality criteria 

Reduce gaps, overlaps 
and discrepancies in the 
EU and global system 
of fisheries data 

Promote the use of administrative 
data for statistical purposes 

Apply the “collect once, use 
multiple times” principle 

56 

KPI10  Number of 

Increase in number 

administrative sources 
used replacing survey 
data  

Source: national and EU-level 
metadata and quality 
reports 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
KPI11     Reduction in number 

Reduction in number 

of data flows from 
countries to EU and 
int. organisations 

Clarify the objectives of EFS 

KPI12  Objectives of EFS 

clearly stated in one 
document 

Single EFS 
objectives document 

Clarify the place of EFS 
in the EU and global 
fisheries data landscape 

Clarify the place of EFS in the 
fisheries data landscape 

KPI13  Discussion of the  

fisheries data  
landscape in relevant 
venues 

Fisheries data 
landscape discussed 
at DGAS, within the 
EU and 
internationally (e.g. 
CWP) 

57 

 
 
 
 
 
 
 
 
 
  
  
  
 
ANNEX 1: PROCEDURAL INFORMATION 

Lead DG, DEcide Planning/Commission Work Programme references 

Lead DG: DG EUROSTAT 

Decide planning reference: PLAN/2020/6889 

Organisation and timing 

Eurostat set up an Inter-Service Steering Group (ISG) for the impact assessment of EFS 
by  inviting  the  interested  DGs  to  join  on  18/02/2020.  The  following  DGs  nominated 
representatives: DG Environment, DG Maritime Affairs and Fisheries, DG Trade, and the 
Secretariat-General.  

The ISG met five times: 

•  27/02/2020 to discuss the inception impact assessment, 
•  11/05/2020 to discuss the consultation strategy, 
•  29/06/2020 to discuss sections 1-4 of the draft impact assessment report, 
•  10/12/2020 to discuss the results of the consultations and sections 5-9 of the draft 

impact assessment report, and on 

•  23/04/2021 to discuss the draft final impact assessment report. 

The  inception  impact  assessment  was  published  for  feedback  on  the  European 
Commission’s “Have your say” platform from 21/04/2020 to 19/05/202047. There was no 
feedback. 

Consultation of the Regulatory Scrutiny Board 

The  draft  final  impact  assessment  was  submitted  to  the  Regulatory  Scrutiny  Board  on 
03/05/2021.  The  Board  met  with  Eurostat  representatives  on  02/06/2021.  It  issued  a 
positive  opinion  on  04/06/2021,  noting that  the  report  should  further  be  improved  with 
respect  to  the  following  aspects:  1)  the  impact  analysis  and  the  comparison  of  options 
should  be  presented  more  clearly,  and  2)  stakeholder  views,  including  dissenting  ones, 
should be more fully integrated into the report. In addition, the board gave a number of 
more technical recommendations. Eurostat has implemented these recommendations. The 
ISG approved the changes in a written procedure concluding on 22/10/2021. 

Evidence, sources and quality 

The specific evidence sources used are referenced throughout the document whenever they 
are used. In particular, the main problems of EFS are evidenced by substantial, regular, in-

47 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12344-European-fishery-

statistics  

58 

 
 
 
 
 
 
depth stakeholder consultations and events for several years, by reports of the European 
Court  of  Auditors,  and  by  the  evaluation  of  EFS.  The  main  quantitative  analysis  of 
administrative  burden  and  cost  impacts  is  based  on  stakeholder  information  (targeted 
questionnaires, financial statements, legal reporting obligations etc.) This information is 
considered  to  be  robust  and  complete  enough  to  estimate  the  magnitude  of  costs  and 
benefits.   

Stakeholders' issues with EFS are considered to be represented and evidenced faithfully 
and completely in the EFS evaluation and the stakeholder consultations and events. In fact, 
these seminars and meetings mainly exist to create a regular exchange between Eurostat 
and the main data users and producers.  

External expertise 

The ISG created in the context of this impact assessment, in which the above-mentioned 
DGs  were  represented,  constituted  a  very  relevant  source  of  external  expertise  for  the 
preparation  of  the  impact  assessment  because  these  DGs  are  the  main  users  of  EFS,  in 
addition  to  the  ISG’s  already  established  function  of  steering  the  impact  assessment 
process and contributing to the collective preparation of the impact assessment report. 

The expertise of the NSIs has also been profoundly relied upon. Namely, there have been 
extensive discussions and exchanges of views as part of regular domain-specific working 
groups, task forces and the directors’ group on agricultural statistics. 

Otherwise, this impact assessment report was written internally in Eurostat.  

59 

 
 
 
 
 
 
 
ANNEX 2: STAKEHOLDER CONSULTATION 

Stakeholder analysis 

The main categories of stakeholders of EFS are: 

•  Data providers, i.a. fishers, aquaculture producers and others providing source 
fisheries  data  either  as  administrative  data  e.g.  from  logbooks  and  landing 
declarations or in surveys and censuses. They have a moderate influence over EFS 
and are moderately interested in them. 

•  Data  producers,  i.e.  national  statistical  institutes  and  other  national  authorities 
collecting  and  treating  fisheries  statistics  and  transmitting  them  to  Eurostat  and 
other organisations. They have a high influence on EFS via the relevant Eurostat 
expert groups and a high interest in them. 

•  Data users (see Figure 4 below): 

o  Institutional  users  are  ones  that  are  directly  involved  in  EU 
policymaking. At EU level, they are the actual policy makers, and at 
international  and  national  levels,  they  support  policymaking  and 
contribute  to  it.  Institutional  users  include  EU  bodies,  international 
organisations,  national  ministries,  other  fisheries  authorities  and 
national research institutes linked to the DCF. These users have a high 
interest in and influence on EFS. 

o  Redistributors  are  users  that  depend  on  EFS.  They  create  and  share 
publicly products based on EFS. The European Marine Observation and 
identified  as 
(EMODnet)  and  EUMOFA  are 
Data  Network 
redistributors. At international level, FAO, OECD and the World Trade 
Organization  (WTO)  are  at  the  same  time  institutional  users  and 
redistributors.  They  have  a  high  interest  in,  but  only  a  moderate 
influence on EFS. 

o  Other professional users contribute occasionally and indirectly to the 
policymaking  process  at  EU  level  or  structurally  provide  fisheries 
information.  These  are  EU  professional  fisheries  organisations, 
advisory  councils,  NGOs  with  marine  programmes,  sea  conventions, 
specialized  fisheries  media,  universities,  research  institutes,  national 
fisheries organisations and individual private companies. They have a 
high interest in, but a low influence on EFS. 

o  The  general  public  and  media  only  has  a  low  interest  in  fisheries 

statistics and very limited influence. 

60 

 
 
 
 
 
 
Figure 4: Data user classification. Source: Eurostat. 

According to the online survey and the public consultation organised in the context of the 
evaluation, there are a wide range of groups using EFS. The largest groups identified were 
national  public authorities mainly  responsible for fisheries  policies (21%), NSIs  (16%), 
and researchers working for the DCF, for fisheries research in other contexts and for other 
purposes  (14%).  The  other  half  is  distributed  between  specialised  users  (international 
organisations, fisheries associations, NGOs, EU services, and businesses) and the residual 
class of 'other users', including private persons, regional bodies etc. (11%). This analysis 
may not be exhaustive as the on-line survey was sent to a contact list of known potential 
users identified by Eurostat. However, the links to the survey and the open consultation 
were also available on the Eurostat website and social media, so they reached a wider user 
group. 

61 

 
 
 
Most users said that they use EFS for more than one purpose. The most common purpose 
was  linked  to  the  CFP  at  either  national  or  EU  level  (36%).  Research  (16%)  and 
commercial  purposes  (14%)  were  the  second  and  third  most  common  uses  before 
environmental policy, blue economy policy, other policies and media uses. 

Consultation strategy 

The evaluation of EFS, which preceded this impact assessment, was supported by a large 
range of consultation activities. The evidence collection for the evaluation included: 

•  a workshop with Member States on the strengths, weaknesses, opportunities and 
threats of EFS from national statistical institutes’ point of view. The first major 
consultation was a one-day workshop organized back to back with a meeting of 
the Eurostat expert group "Fisheries Statistics Working Group" in October 2018. 
It  focused  on  the  strengths  and  weaknesses  of  the  current  EFS  and  the  future 
opportunities and threats from the national data providers' point of view (NSIs and 
other  national  authorities).  In  addition  to  national  members  of  the  Fisheries 
Statistics Working Group, who are responsible for providing EFS, representatives 
from FAO, OECD and ICES took part in the workshop as well.  

•  16  in-depth  interviews  with  key  stakeholders,  for  example  policymakers  and 
contributors  to  the  CFP,  on  their  EFS  use,  needs  and  wishes.  The  in-depth 
interviews  were  principally  undertaken 
to  consult  specific  stakeholders: 
redistributors  (organisations  that  redistribute  EFS  through  their  own  databases, 
adding  information  from  other  countries  or  areas,  here  e.g.:  FAO,  OECD  and 
EMODnet)  and  regular  professional  users  (organisations  that  need  EFS  for  the 
execution of their main professional activities, here e.g. DG MARE, EUMOFA, 
the JRC and ICES). The aim of the interviews was to gather detailed information 
on how EFS are used by these organisations, how they rate the quality of EFS, and 
how EFS could be improved in the future.  

•  Six national case studies and one cross-country aquaculture case study to provide 
overviews  and  detailed  analyses  of  different  data  collection  and  collaboration 
approaches.  The  purpose  of  the  case  studies  was  to  provide  an  overview  on 
national set-ups for collecting EFS and to analyse them in a more detailed manner. 
They also served as a basis for understanding how various fisheries-related data 
collaborations are organised in Member States and how organisations cooperate. 
In addition, the case studies aimed at analysing how national data users use EFS 
and to assess whether EFS are meeting their needs from a national perspective. 
The national  case studies took place in Denmark, France, Greece, Ireland, Italy 
and Poland. In addition, the supporting horizontal case study on aquaculture with 
particular emphasis on the data confidentiality issue covered the above-mentioned 
countries and Germany.   

62 

 
 
 
 
•  an  online  survey  as  a  targeted  expert-oriented  consultation  with  general  and 
specific questions about EFS; an online questionnaire targeting EFS data users and 
producers collected feedback about their views of EFS covering a range of topics 
including the utility, ease of use, cost of collection, statistical quality, efficiency, 
effectiveness and coherence relevant to EFS. It ran from 13/12/2018 to 28/01/2019 
and was  circulated to  353 organisations or individuals  identified by Eurostat  as 
potential users of EFS. The questionnaire included general questions addressed to 
all respondents and three routings categorizing respondents as users, producers, or 
combined  users  and  producers  of  EFS  statistics.  135  respondents  answered  the 
questionnaire,  representing  38.2%  of  the  identified  target  audience.  Responses 
were received from 33 out of 36 EU Member states, EFTA countries, candidate 
and potential candidate countries. 

•  a public consultation to gather information from professional users, citizens and 
other  stakeholders  on  their  experiences  with  EFS;  the  consultation48  was 
conducted  through  the  Commission’s  dedicated  website  for  consultations  (EU 
Survey) and conformed to the Commission’s general principles and standards for 
consultation. It was launched on 18/01/2019 and closed on 12/04/2019. In total, 
24 respondents answered the questionnaire. 

The consultation strategy for the impact assessment was twofold:  

1)  As the impact assessment followed immediately after the evaluation, the evidence 

collected for it was also used where applicable for the impact assessment.  

2)  Impact assessment specific consultations of the general public (public consultation 
covering  all  target  groups:  data  providers,  producers  and  users),  experts  (expert 
consultation targeting mostly data users) and data producers (consultation of the 
DGAS, which also covers fishery statistics) were organised. 

It was decided not to conduct further case studies or interviews for this impact assessment. 
The reason is that the public and expert consultation as well as the recent consultations for 
the evaluation cover a wide range of stakeholders and perspectives (see also table 5 below), 
enabling a detailed fleshing out of the context of EFS, its problems and the objectives. The 
development of the impact assessment report also did not reveal any substantial gaps in 
required elements, evidence or logic to be filled with more consultations. For these reasons, 
additional consultation activities were not seen as cost-effective. 

In sum, the consultations for the EFS evaluation and this impact assessment provide a good 
overview  of  the  views  of  data  providers,  data  producers,  institutional  users  and 
redistributors. However, the response rate of NGOs, the business sector, academia, media 

48 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1857-Evaluation-of-the-

European-Fishery-Statistics/public-consultation  

63 

 
 
 
 
 
 
and the general public was low, so that no representative conclusions can be drawn from 
them  by  stakeholder  group.  This  was  expected,  as  fisheries  statistics  in  general  and  in 
particular their legal reform do not attract much interest outside the management of the 
fishery statistics sector and their immediate main user circle. 

Table 5: Impact assessment consultation methods to reach the stakeholder groups 
of EFS. Source: Eurostat. 

     Activity 

Public 
consultation 

Expert 
consultations 

DGAS 
workshop 

Stakeholder Group 
Data producers 
Institutional users 
Data providers 
Redistributors 
Other professional users 
General public/media 

X 
X 
X 
X 
X 
X 

Impact assessment public consultation  

X 
X 

X 
X 

X 
X 

The  public  consultation  focused  on  whether  EFS  meet  respondents  needs,  let  them 
comment on and rank the objectives and possible options, and let them give feedback on 
potential  impacts  of  the  options.  It  was  online  from  20/07/2020  to  23/11/2020  and 
translated into 23 EU languages. The consultation was promoted widely on the EU’s “Have 
your say” platform49, the Eurostat website50 and social media with monthly reminders, and 
a mail was sent to Eurostat fishery stakeholder contacts. All results are published on the 
“Have your say” platform51. 

The  consultation  garnered  15  responses.  Almost  half  of  the  respondents  were  public 
authorities, two represented NGOs, two business associations, two citizens, one businesses  
and one an international organisation (other) (see Figure 5). 11 EU Member States and the 
UK were represented. 

49 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12344-European-fishery-

statistics/public-consultation  

50 https://ec.europa.eu/eurostat/about/opportunities/consultations/european-fishery-statistics-2020 

51 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12344-European-fishery-

statistics/public-consultation  

64 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 5: Respondents to the public consultation. Source: Eurostat. 

Other
7%

Business
7%

Citizens
13%

Business association
13%

NGO
13%

Public authority
47%

The respondents said that they use EFS moderately because there are other sources and 
because  EFS  lack  certain  breakdowns  and  the  non-confidential  aquaculture  data  they 
require. The objectives of the EFS modernisation were seen as important or very important 
and as “about right” by 11 respondents, 3 wanted more ambition and mentioned known 
problems, and 1 wanted less. 11 respondents also liked the range of options offered. 

The preferred option of 7 respondents was option 3: a new streamlined legal framework 
for EFS, followed by 4 preferring option 1: continue as now (baseline), and 3 option 4: a 
new  legal  basis  for  aquaculture,  abolish  catch  and  landing  statistics.  Nobody  preferred 
option 2: discontinue EFS, and 1 respondent did not support any of the proposed options 
(see Figure 6). 

65 

 
 
 
 
Figure 6: Preferred option. Source: Eurostat. 

Option 1: Continuation as now

Option 2: Discontinue EFS

Option 3: New framework law for EFS

Option 4: New law for aquaculture, abolish
catch and landings EFS

None of them

0

1

2

3

4

5

6

7

8

The supporters of option 3 were regional, national and international authorities and NGOs. 
Option 1 was preferred by business organisations, one representative of a national authority 
and a non-EU citizen. Option 4 was preferred by a public authority, a business association 
and an EU citizen.  

The  respondents  were  also  giving  their  opinions  on  the  impacts  of  the  options  on  five 
stakeholder categories: data producers (statistical authorities), data providers (fishers, fleet 
and  aquaculture  plant  managers),  policy  makers,  professional  users  (e.g.  NGOs  and 
business associations), and citizens and others (see Figure 7). 

Option 3: “A new streamlined legal framework for EFS” scored the most positive impacts 
on  all  stakeholder  groups.  In  addition,  only  very  few  respondents  identified  negative 
impacts  for  option  3.  Option  2,  “Discontinuation  of  EFS”,  was  considered  as  the  most 
negative  in  particular  for  the  data  user  category.  Option  1  “Continuation  of  the  current 
policy” was considered rather neutral in its impacts. Lastly, option 4: “ New legal basis for 
aquaculture  and  compilation  of  other  fisheries  statistics  from  EU  level  administrative 
sources” had similar positive impacts as option 3, but to a lesser extent, and at the same 
time many respondents also identified negative impacts. This is explained by the different 
treatment of aquaculture and other fisheries statistics in this option.    

66 

 
 
 
 
 
 
 
 
Figure 7: Public consultation opinions on the impacts of the options on stakeholders. 
Source: Eurostat. 

4
n
o
i
t
p
O

3
n
o
i
t
p
O

2
n
o
i
t
p
O

1
n
o
i
t
p
O

Citizens and others
Professional users
Policy makers
Data providers
Data producers

Citizens and others
Professional users
Policy makers
Data providers
Data producers

Citizens and others
Professional users
Policy makers
Data providers
Data producers

Citizens and others
Professional users
Policy makers
Data providers
Data producers

0

2

4

6

8

10

12

14

16

Do not know

Very negative

Negative

Neutral

Positive

Very positive

In  conclusion,  there  was  a  range  of  responses  to  the  public  consultation  despite  the 
comparatively low number of respondents. They mostly confirmed issues already known 
from other stakeholder consultations, they approved of the EFS modernisation objectives, 
and  they  preferred  option  3.  Given  the  limited  participation  to  the  consultation,  these 
results need to be treated with caution, but  they point in the general direction the other 
consultations do. 

Expert consultation  

The expert consultation targeted data needs. It ran from 16/07/2020 to 31/08/2020 on EU 
Survey. The invitation to participate was sent to more than 300 contacts and promoted on 
Eurostat’s website. The consultation received 35 responses from 14 countries, of which 22 
were  from  professional  organisations  (4  EU,  14  national,  4  regional),  9  from  data 
producers,  3  from  redistributors,  and  1  from  a  NGO.  The  respondents  gave  detailed 
responses on their data needs for catches, landings and aquaculture, their frequency and 
timeliness  preferences,  and  the  purposes  they  use  EFS  for  (e.g.  market  and  traceability 
analyses). 

The summarised results are:  

Catches 

•  Expert users rely on catches to be derived from weighted landed products rather 

than catches estimated on board. 

67 

 
 
 
 
 
 
 
•  The part of the catches that is not landed or is not the target species is interesting 

for more than half of the respondents. 

•  More than 70% of the respondents use landings for fish market analysis, while more 

than 52% use it for traceability. 

•  The most demanded breakdowns for catches (in addition to species) are the flag of 

the vessel, the FAO fishing region and the country of landing. 

•  77%  of  the  respondents  are  interested  in  bycatch;  out  of  those,  almost  90%  are 
interested in bycatches at species level and 70% on both fish and non-fish species 
(marine mammals, birds, reptiles). 

•  Most of the respondents would appreciate that catch statistics for the reference year 

n become available in the second quarter of year n+1 at the latest. 

Landings 

•  Almost 70% of the respondents interested in landings use it for analysis of the fish 
market, while traceability is interesting for more than half of the respondents. 

•  Weight  of  fishery  products  and  their  value  stand  out  as  the  most  interesting 

variables for expert users. 

•  As  regards  coverage,  more  than  half  of  the  users  need  data  on  fishery  products 

fished by EU and EFTA vessels and landed anywhere in the world. 

•  For breakdowns to present variables, the higher interest is on fishing area, country 
where  products  are  landed,  flag  of  the  vessel,  intended  use  of  the  product,  and 
presentation and preservation status.  

•  Expert users are interested in the breakdown between landed fishery products for 
economic  purposes,  and  those  landed  for  conservation  purposes  (landing 
obligation). 

Aquaculture 

•  A majority of users is interested in covering all aquaculture (for example extensive 

aquaculture) rather than only commercial aquaculture. 

•  Remaining stocks are interesting for the respondents (69%). 

•  For a majority of users, official statistics are the only source for aquaculture. 

•  Some  professional  organisations  (including  at  EU  level)  are  running  their  own 

questionnaires. 

•  On the structural dimensions and variables proposed, production capacity scores 
the highest, together with number of companies, geographical location, number of 
production  sites,  and  environments.  Environmental  measures  and  data  on  the 
structure of the aquaculture sector score the lowest. 

68 

 
 
•  Aiming at the second or third quarter of year n+1 for data delivery would satisfy 

most of the users. 

The results of the consultation thus confirmed that there is a need to update the legislation 
in order to accommodate new data needs.  

Consultation of DGAS 

DGAS organised a workshop on “Future options for European fisheries statistics” on 5-
6/06/2019 in Luxembourg. It was attended by all Member States and EFTA countries as 
well as by some candidate and potential candidate countries. In that way, all data producers 
were reached (NSIs and other national authorities). 

The workshop  focused on the preparation of the EFS impact assessment.  The objective 
was to brainstorm potential impacts of the draft options, propose other options, rank the 
preliminary options and contribute to the impact assessment. The four preliminary options 
discussed in splinter sessions were the following:  

Option 1: Baseline scenario: Continuation of the current policy 

Eurostat continues producing the EFS under the current legal framework, but streamlines 
and simplifies the legal framework through delegated acts. 

Option 2: Discontinuation of EFS 

The EFS regulations are repealed, and Eurostat would stop producing EFS. 

Option 3: New streamlined legal framework for EFS 

A new streamlined framework regulation for EFS covering catches, landings, fishing fleet 
and aquaculture statistics is adopted. 

Option 4: Integration of streamlined aquaculture statistics into SAIO and compilation 
of other fisheries statistics from EU level administrative sources 

Integration of streamlined aquaculture statistics into the SAIO regulation; the legal basis 
for  catch  and  landing  statistics  is  discontinued,  and  EFS  are  derived  from  EU  level 
administrative data to the extent possible. 

The outcomes of the DGAS workshop were as follows: 

Option 1: Baseline scenario: Continuation of the current policy  

Member States and data providers have a good understanding of the current policy and 
legal framework for EFS. This is a strength of the current system, and the risk of upheaval 
and  the  transformation  costs  in  data  collection  and  preparation  of  statistics  under  any 
alternative approach should be considered more fully in the impact assessment. The main 
benefits that would be retained under the baseline option are the continuation of the long 

69 

 
 
time series of statistics  which have been compiled, and the industry, user and producer 
familiarity with the system.  

However, several significant disadvantages to continuing with the current approach were 
identified, and importantly, the working group considered that the most significant of these 
could not be solved through delegated acts to the current legal acts. Retaining the current 
approach would not address: 

the need for consistency in definitions and classifications used under the EFS; 

• 
•  double reporting of data to different users; and 
• 

the need for flexibility in the statistics to allow a response to new and emerging 
user needs, and technological developments in the sector, especially in aquaculture. 

Retaining the current approach would enable small improvements to streamlining quality 
reporting  and  methodological  updates.  The  group  concluded  that  the  time  and  effort 
required to make minor amendments to the current legal basis for this purpose would not 
be justified as it would not respond to the primary weaknesses of the current system. The 
burden of double reporting would remain due to the lack of harmonisation. 

This  was the least  preferred of the “do something” options based on the poll of DGAS 
attendees, but still preferred to discontinuing EFS altogether.  

Option 2: Discontinuation of EFS 

Within the ESS, Member States produce high quality and comparable data. The prospect 
of being unable to benefit from these harmonised standards across the EU would jeopardize 
data comparability and availability.  

Discontinuing EFS also poses a risk to data users: unavailability of long time series or, in 
the best-case scenario, breaks in time series could be foreseen. The lack of independent 
statistical  data  could  lead  to  data  from  administrative  sources  only  being  collected  to 
respond  to  short-term  policy  needs,  which  could  result  in  the  meaning  of  variables 
changing  over  time.  With  regard  to  data  availability  for  users,  the  risk  is  higher  for 
aquaculture, as catches and landings data will continue to be collected due to the CR. 

In the case of discontinuation at EU level, national regulations on aquaculture statistics 
risk being  repealed,  and  instead  rough estimates could  potentially be used by statistical 
offices, resulting in a decrease in quality. 

There are marginal benefits to not reporting catches and landings data twice; the data has 
to be collected and produced anyway. 

Fisheries statistics are needed to build national accounts by NSIs. Some countries conduct 
sample  surveys  to  complement  administrative  data,  for  example  to  cover  small-scale 
fishing fleets in the case of catch statistics; discontinuing EFS would result in incomplete 
data. 

70 

 
 
This  was  the  least  preferred  option  in  the  poll.  Only  one  participant  identified 
discontinuation of EFS as the preferred option, while 19 of the 26 respondents identified 
option 2 as the least preferred option of the four presented.  

Option 3: New Streamlined Legal Framework for EFS  

There  was  a  strong  view  that  any  simplification  of  EFS  should  be  aligned  with 
administrative  data.  In  particular,  it  was  suggested  that  EFS  adopt  the  same  level  of 
aggregation as administrative data, i.e. not request additional information which leads to 
additional  work  and  inconsistencies.  It  was  noted  that  it  is  difficult  to  collect  detailed 
species  data  for  catch  and  landing  statistics  and  that  there  is  a  desire  to  move  to  more 
aggregated  data  (i.e.  genus,  family  level)  for  some  species  that  are  of  minor  economic 
importance.  

Simplification of EFS should ensure the harmonisation of data collection and avoid the 
double reporting that occurs under the current system. It is considered essential that other 
organisations such as FAO and OECD are involved in the process to ensure that their needs 
are addressed and to secure alignment of definitions and approaches so that the needs of 
these  users  and  the  Commission  are  met  without  the  need  for  double  reporting. 
Furthermore, wider user needs should be reviewed to ensure that the statistics under the 
“new” EFS are useful now and for the future.  

Regarding aquaculture, simplification is needed particularly with respect to data collected 
on methods of production, which are considered difficult to collect. More generally, there 
is a need for less disaggregation of aquaculture data to avoid the current problem of data 
being flagged as confidential. There is also a need to ensure greater harmonisation of EFS 
aquaculture data with DCF data. 

In addition to simplification, any new legal framework should ensure the streamlining of 
definitions,  classifications,  concepts  and  timings  of  data  transmission  compared  to  the 
current situation. This would allow for one single point of data reporting and eliminate the 
need for double reporting.  

Other  out-of-date  and  limiting  aspects  of  the  current  legal  framework  could  also  be 
addressed  under  this  option  to  better  meet  user  needs.  For  example,  the  geographical 
coverage of catches and landings (global catches in marine and inland waters and global 
landings by EU and EFTA vessels) could be extended.  

Option 3 received the highest number of first choice votes in the informal poll taken during 
the event. Of the 26 responses received, 21 (80%) chose option 3 as their preferred option 
of the four presented.  

Option 4: Integration of streamlined aquaculture statistics into SAIO and compilation 
of other fisheries statistics from EU level administrative sources 

71 

 
 
Integration of aquaculture into SAIO 

The  general  understanding  is  that  there  is  a  need  to  develop  a  new  streamlined  and 
simplified  regulation  for  aquaculture,  which  could  be  integrated  into  SAIO  or  as  an 
alternative option, as a stand-alone regulation. 

The  integration  into  SAIO  seems  difficult  for  marine  aquaculture,  mainly  because 
aquaculture belongs to the same policy area as fisheries in many organisations, and would 
need more harmonisation, for example on species, than agriculture statistics. Wild catches 
are also a particular case which is different to agricultural production. From the production 
point  of  view,  especially  for  inland  aquaculture,  there  are  more  similarities.  The  group 
identified  a  potential  issue  linked  to  the  availability  of  funding  instruments  for  the 
production of aquaculture statistics if they were to be covered under SAIO.  

Integration  into  SAIO  could  potentially  require  an  increased  effort  to  achieve 
harmonisation  between  domains,  while  keeping  the  link  with  catches  and  landings. 
However,  integration  into  SAIO  could  be  an  opportunity  to  collect  information  on 
innovative ways of producing food, such as aquaponics or using insects or algae for feed. 

The participants discussed how to improve the problems of aquaculture data availability 
due to confidentiality. Streamlining and simplifying data collection through targeting user 
needs could help, for example by reducing the breakdowns of the data to be disseminated 
and using scientific use files for research-related users. Another alternative could be using 
perturbation techniques instead of suppression. 

Compilation of other fisheries statistics from EU level administrative sources 

The participants also indicated that the use of administrative data involves some risks in 
ensuring  coverage,  quality,  data  availability  and  timeliness.  In  particular,  when  other 
statistical domains such as accounts need fisheries data, their needs could potentially not 
be met. 

The participants of the DGAS seminar stressed that administrative data must be used to 
produce  statistics  where  possible.  To  do  this,  the  European  Commission  was  asked  to 
ensure that administrative data sources used meet the quality criteria required to produce 
reliable official statistics.   

This was the preferred option for two respondents to the poll, and the second choice option 
for 14 of the 26 respondents (all of whom ranked option 4 second to option 3). 

Additional options 

One additional option for consideration in the impact assessment was proposed, a hybrid 
of options 3 and 4 whereby there would be a single legal framework developed for EFS 
fisheries statistics (catch, landings and fleet), while aquaculture would be integrated into 
the SAIO regulation. 

72 

 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

Practical implications of the initiative 

The practical implications of implementing option 3, a new streamlined legal framework 
for EFS, would mainly affect three stakeholder categories:  

•  Data providers: this category includes not only  the respondents to surveys (i.e. 
fishers, vessel owners and aquaculture businesses) but also national institutions that 
are  keepers  of  administrative  data  files,  such  as  national  fisheries  authorities 
keeping fleet, catch and aquaculture business registers.    

•  Data  producers:  this  category  comprises  the  authorities  responsible  for  the 
collection  and  compilation  of  fisheries  statistics.  It  mainly  includes  NSIs,  other 
national authorities such as fisheries agencies, and Eurostat.   

•  Data users: this category includes institutional users such as Commission services, 
other EU institutions, international organisations such as FAO, ICES, OECD, and 
RFMOs,  national  administrations,  businesses,  NGOs,  research  institutions  and 
academia, media and the general public.  

The practical implications for these groups would be as follows: 

•  The  implications  for  the  data  providers  would  mainly  touch  aquaculture 
businesses and fisheries authorities keeping the administrative registers. The less 
complex  data  collection  for  aquaculture  would  slightly  decrease  the  burden  on 
aquaculture  businesses.    Most  of  these  enterprises  are  small  and  medium  sized. 
There are no impacts on their competitiveness. The other fisheries businesses are 
not  directly  influenced  by  the  new  streamlined  legal  framework  for  EFS,  as  the 
statistics are to be drawn from the administrative registers kept primarily for other 
than statistics purposes.  

The implication for the national  fisheries  authorities would materialize in  closer 
co-operation with statistical authorities as more administrative data would be used 
directly for providing  statistics. This  would require fine-tuning the validation of 
administrative data. 

•  Data  producers  would  have  to  adapt  their  data  collection,  production  and 
dissemination systems to new or different variables in the data collections. National 
data  producers  would  benefit  from  reduced  costs  of  data  collection,  as  Eurostat 
would  draw  the  statistics  for  catches  directly  from  administrative  data  used  for 
managing the CFP and national fisheries administrations. In the short term, national 
statistical  authorities  would  need  to  invest  in  closer  co-operation  with  fisheries 

73 

 
 
 
 
 
 
 
authorities for improving the validation of the administrative data. The impact on 
Eurostat is estimated to be cost-neutral.  

•  The most significant implications would touch data users as the new streamlined 
legal framework for EFS would increase the availability of data and improve the 
coherence of the data. This would enable them to use better statistical data on which 
to base their work and decisions.   

International organisations, in particular FAO and OECD, could directly use EFS 
without conducting separate data collections from the countries. This would save 
them time and effort and the countries as well. 

The summary of benefits and costs is presented in table 6 below. 

Table 6: Benefits and costs of the preferred option. Source: Eurostat.  

Description 

I. Overview of Benefits – Preferred Option 

Amount 

Direct benefits 

Comments 

Catch data collection: 
Reduction of burden and 
costs: Cutting double data 
collections for catches 

Annual savings for direct costs linked to the 
catch data collection estimated to be 
approximately 1,2 million € if compared to 
baseline 

It is planned to produce the catch statistics 
from an EU-level administrative data source. 
The Member States would not need to 
collect catch statistics any more. 

Direct and indirect cost savings to data 
producers (national statistical institutes and 
other national authorities). The cost savings 
are based on the figures provided by the 
Member States and they stem mostly from 
indirect costs and survey costs. 

The change is estimated to be cost neutral to 
Eurostat. 

National statistical institutes, other statistical 
authorities and international organisations 
benefit from simplified data flows; “collect 
once, use multiple times” 

This saving is produced by simplifying the 
data structure of aquaculture and thus 
making more data available to users with a 
slightly reduced cost.  

Effectiveness improvement as more data 
becomes available to users with the same 
cost and burden on providers and producers. 

Use of the same data by 
international organisations 

Slight reduction in burden at Member State level 
and at international organisations 

Improving effectiveness: 
Reduction of confidential 
data 

Indirect benefits 

About 20% more data will be accessible to data 
users with the same cost as before 

74 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Simplification of the 
collected data 

Slight reduction in administrative burden and 
burden on respondents. 

NSIs and other statistical authorities as 
well as fishers and aquaculture plant 
managers benefit 

II. Overview of costs – Preferred option 

Citizens/Consumers  

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Adjusting 
data 
collection   

Direct costs 

None 

Indirect costs 

None 

None 

None 

None 

None 

None  

None  

Small 

Small 

None 

None 

75 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

Analysis of the potential impacts of the different policy options for the future EFS has been 
based on the methodology proposed in the Better Regulation Guidelines of the European 
Commission. As a first step, potential impacts were identified in relation to the different 
options. This was followed by a primarily qualitative analysis in order to identify the more 
important  impacts  of  the  various  options.  This  analysis  was  complemented  with 
information available from a number of monitoring and evaluation documents linked to 
the  implementation  of  the  current  EFS,  as  well  as  from  a  series  of  consultations  with 
stakeholders of EU fisheries statistics, the results of the public consultation, and several 
other  documents  outlined  above.  When  analysing  the  impacts  of  the  different  options, 
factors such as relevance, effectiveness, efficiency, coherence, EU added value, statistical 
quality,  EFS  stakeholders’  opinions,  and  the  technical  feasibility  of  implementing  the 
respective option were taken into account. 

In  line  with  the  Better  Regulation  guidelines,  impact  assessments  should  also  provide 
details  for  all  options  on  the  information  obligations  for  businesses,  citizens  and 
national/regional/local  administrations which are likely  to be added or eliminated if the 
option were implemented. In those cases in which the change in administrative burden is 
likely to be significant, the effects should be quantified using the EU Standard Cost Model. 
However, this approach is difficult to apply while analysing the impact in terms of costs 
and  burden  of  EFS.  To  make  this  analysis  for  the  different  policy  options,  Eurostat 
therefore  relied,  inter  alia,  on  the  evidence  gathered  from  previous  and  ongoing 
quantitative  and  qualitative  assessments  of  costs  and  burdens  related  to  statistical 
production in the field, in order to assess the expected costs and burdens of data collection 
for respondents and producers of fishery statistics. 

Cost estimates 

The costs of the data collection are regularly collected from the Member States as part of 
the  activities  of  Eurostat’s  Resource  Directors  group.  Costs  estimation  methodology  is 
based on the costs declarations done by countries to the ESS. It is often difficult for the 
countries to assess the costs for catches and landings separately, as the two data collections 
are    to  some  extent  intertwined  –  catches  are  mostly  calculated  from  landings  using 
conversion  factors  as  “nominal  catches”.  In  addition,  the  indirect  costs  are  difficult  to 
assign  per  data  collection.  A  further  challenge  for  fisheries  statistics  is  posed  by  data 
collections carried out outside of NSIs in other national authorities; in some cases, NSIs 
were not able to report on costs incurred in other institutions. For these reasons, the cost 
savings are estimations. The saving of 1.2 million € is estimated on the basis of the plan to 
collect  catch  statistics  directly  by  Eurostat  from  the  administrative  data  collected  by 
Member States and provided to DG MARE. Currently Member States spend 1.5 million € 
on catch statistics annually. This cost is estimated to drop to 0.3 million € as only the costs 

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resulting  from  the  cooperation  on  the  data  quality  with  the  fisheries  management 
administration would stay.  

Assessing the relevance of statistics 

The relevance of statistics is normally assessed when the legal basis is adopted, and hence 
it is not part of the regular assessment of statistical quality. EFS are produced under the 
expectation that the main users are policy  users, mainly those working on the CFP, and 
also  those  working  with  environmental  and  trade  policies.  Inside  the  European 
Commission  this  includes  DG  MARE,  the  JRC  (in  support  tasks  to  DG  MARE),  DG 
Environment and DG Trade. EFS are also assumed to  be used by other EU Institutions 
(e.g.  the  European  Parliament,  the  European  Court  of  Auditors  and  the  Council  of  the 
European  Union  as  linked  for  example  to  fishery  quotas),  international  organisations 
(FAO, OECD and ICES), regional fisheries bodies (e.g. RFMOs), national administrations 
(ministries), national statistical institutes (NSIs) and research institutes, the business sector, 
media and the public in general. 

Eurostat regularly carries out  user satisfaction surveys;  EFS are  clustered together with 
agricultural statistics. Due to the limited number of replies on these areas, it is not possible 
to draw substantive conclusions for EFS except rough user sentiments. Partly because of 
this,  Eurostat  uses  the  number  of  downloads  of  EFS  from  its  online  database  as  an 
indication  of  their  relevance.  In  a  five-year  period  (2013  to  2017),  the  number  of 
downloads  almost  tripled,  reaching  24.000  downloads  in  2017.  The  downloads  are 
relatively evenly spread between dataset groups, with catch statistics being slightly more 
used than the other dataset groups. 

These  downloads  do  not  however  reveal  what  the  statistics  are  used  for.  Hence,  more 
contextual and qualitative information needs to be used to assess statistics’ relevance and 
impact. 

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