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The briefing argues that deep-sea fish populations in European waters are either depleted or lack sufficient data for assessment, making them exceptionally vulnerable to over-exploitation due to slow growth and late maturation. It criticizes EU and UK ministers for setting fishing opportunities above precautionary scientific advice from ICES and STECF. The document recommends setting fishing opportunities below single-stock advice, implementing zero-catch Total Allowable Catches (TACs) for endangered species like roundnose grenadier, and enhancing the protection of Vulnerable Marine Ecosystems (VMEs). It emphasizes that these measures are necessary to meet obligations under the EU deep-sea fisheries Regulation 2016/2336, the UK Fisheries Act, and UN General Assembly standards.

The document argues that both the EU and UK consistently set Total Allowable Catches (TACs) above scientific advice, failing to meet legal deadlines for sustainable fishing. It highlights a systemic failure to prioritise the recovery of depleted stocks, often citing 'choke' risks in mixed fisheries as a justification. The briefing calls for a shift toward ecosystem-based management and a quota allocation system that rewards low-impact fishing practices over historical catch data.

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 briefing argues that the lack of comprehensive sharing arrangements for fish stocks shared between the EU, UK, and third countries often leads to catch levels exceeding scientific advice. It calls for the adoption of ecosystem-based fisheries management, the implementation of a genuine precautionary approach, and the avoidance of unilateral quota setting. Specifically, it urges the EU and UK to ensure total fishing limits do not exceed scientifically advised levels and to prioritize resolving allocation disputes for pelagic stocks like mackerel, herring, and blue whiting. The document also emphasizes the need for transparency under the Aarhus Convention and the use of ICES scientific advice as the primary basis for management decisions.

The document advocates for a shift from single-stock fisheries management to an ecosystem-based approach in the EU and UK. It argues that current scientific advice from ICES and STECF often fails to account for the needs of predators and the impacts of climate change. The authors recommend setting Total Allowable Catches (TACs) below headline scientific advice to rebuild fish populations well above sustainable levels (BMSY) and to safeguard the food web, particularly for forage fish like sandeel, sprat, and herring.

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.

The document highlights widespread non-compliance with the landing obligation (LO) in the EU and UK, noting that illegal discarding remains 'prolific' and undermines stock assessments. It argues that setting Total Allowable Catches (TACs) based on catch advice while illegal discarding continues allows for unsustainable fishing levels. To remedy this, the authors recommend the swift roll-out of Remote Electronic Monitoring (REM), setting TACs lower than ICES maximum catch advice in the absence of robust controls, and making quota 'top-ups' conditional on demonstrated vessel compliance. The briefing also suggests using precautionary multipliers in catch accounting to incentivise selectivity and promoting quota redistribution to avoid raising overall TACs.

The document argues that EU and UK fisheries management has failed to rebuild depleted fish stocks, often exceeding scientific advice to avoid short-term economic disruptions. It highlights the risk of 'phantom recoveries' where stock assessments overestimate productivity. To break the cycle of overfishing and 'choke' risks in mixed fisheries, the authors recommend setting Total Allowable Catches (TACs) strictly in line with scientific advice, implementing rigorous rebuilding plans with remote electronic monitoring, and reducing TACs for healthy stocks to protect depleted bycatch species.

The report examines the three types of non-deterioration obligations in the Nature Restoration Regulation (NRL): continuous improvement, non-deterioration of good status, and pre-restoration non-deterioration. It argues that these obligations are not merely effort-based but require 'appropriate measures' and are essential for the long-term success of ecosystem restoration. The analysis highlights the interplay between the NRL and the Habitats Directive, particularly regarding Natura 2000 sites, and critiques the uniform National Restoration Plan (NRP) format for providing inadequate guidance on demonstrating compliance with these obligations. It also details the strict criteria for derogations, such as force majeure and overriding public interest, emphasizing that they must be interpreted narrowly to avoid undermining overall restoration targets.

The document argues that the proposed Omnibus Directive is vulnerable to legal challenges under EU law due to substantive and procedural failures. Substantively, it claims the directive violates the principles of proportionality, legal certainty, and coherence, and breaches the Charter of Fundamental Rights and the EU Climate Law by weakening corporate sustainability and due diligence requirements. Procedurally, it highlights the Commission's failure to conduct required impact assessments, climate-consistency checks, and extensive consultations, which may render the act voidable under the Treaty on the Functioning of the European Union (TFEU).

The document concludes that mandatory CRTP disclosures, based on IFRS S2 and the TPT Disclosure Framework, are unlikely to materially increase liability risks for companies and directors due to existing legal protections and the high evidentiary hurdle of proving dishonesty. It argues that such disclosures may actually reduce overall legal risk by promoting better compliance with existing duties and mitigating greenwashing claims.

A coalition of organisations warns the European Commission that using omnibus procedures to simplify legislation risks deregulation and the undermining of the Birds and Habitats Directives. They argue that permitting delays are caused by administrative capacity and staffing shortages rather than environmental law, and propose alternatives such as digitalising procedures, designating renewable energy areas via science-based mapping, and providing targeted implementation support through the Accele-RES plan and Technical Support Instrument.

ClientEarth advocates for a shift from 'paper commitments' to legal action to address the ocean crisis. The briefing prioritises the enforcement of existing frameworks, such as the UN Convention on the Law of the Sea (UNCLOS) and the Kunming-Montreal Global Biodiversity Framework (GBF), to protect marine biodiversity and combat climate change. It specifically calls for the elimination of harmful fisheries subsidies, the banning of bottom trawling in marine protected areas (MPAs), and the ratification of the BBNJ Agreement to protect the high seas. The document also highlights the need for a 'Protection Principle' that makes ocean conservation the default norm and outlines specific legal priorities for the EU, Mediterranean, China, and the UK.

The document analyzes the legal requirements of Article 9 of the Nature Restoration Law (NRL), which mandates the restoration of at least 25,000km of free-flowing rivers in the EU by 2030. It details the process for creating barrier inventories, prioritizing the removal of obsolete structures, and ensuring these actions align with other EU frameworks like the Water Framework Directive (WFD) and the Habitats Directive. The briefing emphasizes the need for longitudinal, lateral, and vertical connectivity and warns against using the Renewable Energy Directive to justify the retention of obsolete barriers.

Signatories of the Blue Manifesto argue that the draft European Ocean Pact lacks the ambition and enforceability needed to address ocean degradation. They call for binding 2030 targets to protect 30% of EU seas, the phase-out of destructive fishing and offshore oil and gas drilling, the creation of a European Ocean Fund, and the inclusion of civil society in governance structures.

The joint submission argues that rather than mandating UK investment, the government should clarify fiduciary duty laws to allow trustees to consider wider societal and environmental impacts and regulate strategic asset allocation advice provided by investment consultants.

The document examines the opacity of EU trilogue negotiations, where 89% of legislative files reached agreement in the first reading during the 2014-2019 term. It argues that the current lack of transparency allows privileged industry lobbyists access while excluding civil society and enables Member States to later contradict agreed-upon positions, as seen with the Nature Restoration Law and the Corporate Sustainable Due Diligence Directive. The briefing rejects arguments that transparency would entrench negotiator positions, citing CJEU rulings, and asserts that reactive access requests under Regulation 1049/2001 are insufficient due to systemic delays. It recommends the proactive publication of 'four-column documents', agendas, and calendars, and suggests specific regulatory amendments for the European Parliament, Council, and Commission to formalise this openness.

The briefing highlights the failure of the UK Department for Transport (DfT) to hold auto manufacturers accountable for illegal defeat devices, which allow vehicles to exceed emissions limits. Citing ICCT analysis, it suggests 2.4 million UK vehicles may be affected. Commissioned research from the Centre for Research on Energy and Clean Air estimates that since 2009, excess emissions from these devices have caused 16,000 premature deaths and a £96bn economic burden in the UK, with further significant health and financial costs projected through 2040 if no action is taken.

ClientEarth argues that the next EU long-term budget (MFF) must move beyond inconsistent environmental safeguards to implement binding spending targets and strict conditionalities. The organization calls for the legal enshrining of the 'do no significant harm' (DNSH) principle, the creation of a dedicated Nature Restoration Fund and an EU Ocean Fund, and the redirection of harmful subsidies in agriculture and fisheries toward low-impact, small-scale actors and energy communities.