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ClientEarth responds to the European Commission's Call for Evidence regarding a potential Fisheries Omnibus on Multiannual Plans (MAPs). The organisation argues that the priority should be the effective implementation and enforcement of existing tools rather than the deletion or weakening of key safeguards, such as the provisions on most vulnerable stocks (MVS) in the Western Mediterranean MAP and the 5% rule in the Northern MAPs. It asserts that failing to rebuild depleted stocks perpetuates 'choke risks' and that the only sustainable solution is to prioritise the recovery of stocks below sustainable levels. The document also suggests that the upcoming EU Ocean Act and the revision of the Multiannual Financial Framework (MFF) should be used to strengthen coherence in ocean policies and redirect harmful subsidies toward climate and biodiversity targets.

The document argues for a shift from simply following single-stock scientific advice to adopting precautionary, ecosystem-based fishing opportunities for 2026. The NGOs demand an end to overfishing, the prioritisation of rebuilding depleted populations regardless of whether they are targeted or bycatch, and the full implementation of the Western Mediterranean multiannual plan and the CFP's landing obligation.

The briefing identifies three primary shortcomings in the ICES scientific advice used by the EU and UK: a lack of focus on rebuilding stocks above sustainable levels (BMSY), insufficient precaution to prevent stocks from falling below biological limits (Blim), and a failure to integrate ecosystem health objectives such as food web integrity. It calls for a formal roadmap to address these flaws and recommends that fishery managers apply additional precaution by setting catch levels below the ICES 'headline' advice until recovery-focused and ecosystem-based advice is available.

The document argues that EU and UK fisheries management has historically prioritized profitable stocks over vulnerable ones, leading to a cycle of overfishing and 'choking'—where fisheries must stop operating because they run out of quota for less abundant species despite having quota for target stocks. To break this cycle, the authors recommend that Total Allowable Catches (TACs) for abundant stocks be set below single-stock scientific advice to protect bycatch, and that decision-makers utilize mixed fishery MSY considerations from ICES geared toward rebuilding depleted populations. Additional proposed measures include implementing spatial closures, mandating Remote Electronic Monitoring (REM) for full catch documentation, and requiring the use of the best available technology to improve gear selectivity.

The briefing highlights the failure of EU Member States to reach target fishing mortality by January 2025 under the Western Mediterranean multiannual plan (West Med MAP). It criticizes the lack of transparency in the 'compensation mechanism' used to reclaim fishing days and calls for robust actions, including strengthened fishing mortality reductions, safeguard measures for critically depleted stocks, and enhanced selectivity and control systems.

A joint response from twelve NGOs urging the European Commission to adopt a fully precautionary, ecosystem-based approach to setting 2025 fishing opportunities, arguing that current Total Allowable Catches (TACs) fail to prioritise the rebuilding of depleted stocks and ignore critical ecosystem dynamics.

The document argues that the proposed WMedMAP is insufficient to reverse the overexploitation of the Western Mediterranean Sea, where over 90% of assessed fish stocks are overfished. The NGOs call for a transition to science-based governance, including the expansion of trawl-free zones to 100m depth, the introduction of Total Allowable Catches (TACs) to supplement effort management, and the adoption of a more participatory, local co-management approach to ensure long-term sustainability and the recovery of key species like hake, red mullet, and anglerfish.

The document introduces the Adaptive Marine Policy Toolbox (AMP-Toolbox), developed under the PERSEUS project to bridge the gap between scientific knowledge and policy execution in marine management. The toolbox is specifically designed to support the requirements of the EU Marine Strategy Framework Directive (2008/56/EC), which mandates the use of an Ecosystem-Based Approach (EBA) to achieve 'Good Environmental Status' by 2020. The AMP-Toolbox provides a structured, four-level web-based framework—ranging from a five-step policy cycle to specific resources and models—that incorporates scenario planning, stakeholder involvement, and cyclical learning to handle environmental uncertainties and climate change impacts. While primarily aligned with EU directives, the authors note the toolbox's transferability to other frameworks like the Mediterranean Action Plan and the Black Sea's Strategic Action Plan. Future implementation will involve pilot testing in the Western Mediterranean, Adriatic, Aegean, and Western Black Sea to refine the tool based on real-world stakeholder feedback.

The joint NGO response argues that EU fisheries management fails to fully implement the Common Fisheries Policy (CFP) and the Marine Strategy Framework Directive (MSFD), leading to missed deadlines for ending overfishing. The authors contend that Total Allowable Catches (TACs) are routinely set above scientific advice, particularly for depleted stocks caught as bycatch, which creates a cycle of overexploitation and 'choke' situations. They recommend setting fishing opportunities well below the 'headline' scientific advice from ICES to account for ecosystem dynamics and uncertainties. Key demands include the full implementation of the Landing Obligation, the roll-out of Remote Electronic Monitoring (REM), and the rejection of any revisions to the Western Mediterranean multiannual plan (MAP) that would weaken its objectives.