In this position paper, CFFA contributes to the Commission open consultation on an EU strategy for fisheries external action. In it, CFFA calls for a strategy that looks into policy coherence for development, including a focus on food security, the importance of participation of stakeholders and of including human rights safeguards. In the second part of the position, CFFA looks at the coherence in the resources put forward to fund this external strategy, as essential for effective action.
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In early July, the European Commission opened a consultation for its “EU strategy for fisheries external action.”
This is part of a larger consultation process started by former Commissioner for Fisheries and the Environment, who launched an evaluation of the Common Fisheries Policy and the current Commissioner for Fisheries and Oceans, Mr. Costas Kadis, who was tasked with developing a “European Ocean Pact” (June 2025).
In response to this consultation, CFFA calls for an EU strategy for fisheries external action focused on transparency, social justice, environmental sustainability and the meaningful participation of African artisanal fishing communities, which are the backbone of fisheries in Africa.
Policy coherence for sustainable development
The definition of the EU strategy for fisheries external action provides an opportunity for the EU to deepen its commitment to Policy Coherence for Development between the European Ocean Pact, Sustainable Fisheries Partnership Agreements and other international commitments on environmental and social sustainability for the EU to lead in global inclusive ocean governance.
1.1 EUROPEAN OCEAN PACT
The European Ocean Pact aims to strengthen the EU's maritime governance and diplomacy in order to ensure the sustainability, security and prosperity of the oceans. It aims to coordinate action at all levels to protect marine biodiversity, combat climate change and promote a fair and resilient blue economy. It also recognises the importance of supporting coastal communities in Europe.
This ambitious vision must be appropriately reflected in the future EU strategy for fisheries external action, particularly with regard to relations with African countries, where small-scale fisheries are the main pillar of the blue economy.
Indeed, African countries now recognise that women and men in small-scale maritime and inland fisheries make a major contribution to livelihoods, employment, food security and conservation.
To ensure the health and resilience of these fishing communities, in line with SDG 14, access rights and tenure rights for small-scale fisheries must be guaranteed, in particular through the establishment of co-managed protected areas reserved for small-scale fisheries, to enable this sector to provide nutritious and affordable food coming from sustainable sources.
This was echoed by the Organisation of African, Caribbean and Pacific States (OACPS), which, at the 8th Meeting of the ocean, inland waters and fisheries ministers of the OACPS (September 2024 in Dar es Salaam), explicitly recognised co-management as an opportunity to contribute to the 30x30 target: “the effective co-management of 100% of artisanal stewardship areas with small-scale fishers, thereby improving the sustainable management of the small-scale fisheries sector, maintaining healthy fish stocks, securing livelihoods, and substantially contributing to conservation targets, including Target 3 of the Kunming-Montreal Global Biodiversity Framework.”
The Kampala Declaration for the Comprehensive Africa Agricultural Development Programme (CAADP) further considers artisanal fisheries to be a key element for food security and resilience in Africa, as part of an integrated approach aimed at human and environmental health.
Given that the EU considers Africa a privileged partner, it is important that it aligns itself with the approach expressed by African countries and their small-scale fisheries, clearly identifying small-scale fisheries as a strategic sector at the heart of ocean diplomacy towards African countries. This will enable the EU to move towards greater coherence with its international commitments, such as the Sustainable Development Goals (SDGs), as well as with the implementation of target 3 of the Global Biodiversity Framework, 30x30, by recognising and respecting local communities and their traditional territories.
The current language of European ocean diplomacy must also evolve.
Currently, the European Ocean Pact emphasises the defence of “EU interests and values.” We believe that truly shared ocean governance is necessary, where African states and their civil societies, including artisanal fisheries, are not mere consumers of EU-dictated standards, but co-builders of equitable and sustainable governance.
The EU “Ocean diplomacy” language must evolve from “EU interests and values” to shared values an interests, where African states and artisanal fishers are not simply facing EU-dictated standards, but become co-builders of equitable and sustainable ocean governance. Photo by Mediaprod.
With this in mind, spaces for dialogue must be strengthened or created. For example, the future International Platform for Ocean Sustainability (IPOS), put forward in the European Ocean Pact, could facilitate a more balanced dialogue with African countries, their civil societies and small-scale fisheries. The EU must also engage in structured dialogue about its strategy for external fisheries action with African regional organisations such as AU-IBAR and ECOWAS, and with pan-African civil society and small-scale fishing organisations such as AFRIFISH-net, AWFISHNET and CAOPA.
It is also necessary to rethink the EU-Africa Partnership for the Ocean, which is structured around a strategic group and a roadmap, implemented through the Africa-Europe Foundation. While its official aim is to strengthen ocean governance by promoting innovation, maritime infrastructure and research, it favours industrial blue growth models at the expense of African small-scale fisheries and their rights. By emphasising public-private partnerships, particularly in the 'Finance and Investment' pillar, to support blue growth through blended finance mechanisms (blue bonds, blue carbon, etc.), it is clear that it will recommend and push for funding to be directed towards the promotion of other blue industries and maritime infrastructures, with a high risk of marginalising artisanal fishing communities in Africa.
The EU-Africa partnership for the ocean must be refocused on local resilience to challenges such as the impacts of climate change and the contribution to sustainable food systems, and must include in the implementation of the roadmap greater representation of coastal communities dependent on fishing in Africa, as well as appropriate means for their participation. This also means encouraging and supporting the active and informed participation of men and women in small-scale fisheries in forums such as the Blue Africa Summit.
“The EU-Africa Partnership for the Ocean favours a vision of industrial blue growth at the expense of African small-scale fishers’ rights. The focus on blended finance mechanisms, such as blue bonds or blue carbon, is particularly concerning, with a high risk of marginalising further artisanal fishing communities””
Finally, the European Ocean Pact actively promotes marine spatial planning (MSP) as a governance tool for organising access to and use of maritime areas between sectors such as energy, maritime transport, conservation and fishing. While this approach can help reduce conflicts of use, MSP poses a significant risk to small-scale fishing. Unlike powerful industrial players – energy, port infrastructure, tourism – artisanal fishing communities will struggle to make their voices heard at the maritime spatial planning table. This is particularly true in Africa, where small-scale fisheries are often still marginalised in national policies. This leads to their gradual exclusion from traditionally exploited areas, without recognition of their ecological, economic and social role in coastal areas.
The EU, as Africa's strategic partner in ocean governance, could play a decisive role in ensuring that African artisanal fishing communities are not marginalised in MSP. It can support, and provide technical and financial assistance for, the adoption of legal frameworks that explicitly recognise the access rights of small-scale fishers to coastal areas, protect their fishing areas from uncoordinated industrial development, and require their informed participation in all stages of the planning process.
In this regard, the EU can notably support African governments in their efforts to establish co-management arrangements, accessible appeal mechanisms, or social and environmental impact assessments, in line with their national policies. By supporting the commitments already made by African countries – in the declarations of the OACPS, the African Union and within the framework of the CAADP – the EU will act as an ally for sustainable development and inclusive governance. This is not about exporting EU models, but about supporting existing African dynamics by promoting the informed participation of the most vulnerable actors.
The EU could also make its investments in the blue economy in Africa conditional on guarantees that they will not lead to the displacement of coastal communities or the degradation of marine ecosystems that are essential to their livelihoods. By systematically integrating gender-sensitive social impact assessments that take into account the impact on food security, alongside environmental impact assessments, the EU would help to make maritime planning a tool for the rights, conservation and resilience of communities, rather than a tool for dispossessing small-scale fisheries in favour of more powerful sectors of the blue economy.
1.2 THE FUTURE OF SFPAs: PRIORITY FOR TANGIBLE BENEFITS IN THIRD COUNTRIES
Sustainable Fisheries Partnership Agreements (SFPAs) remain the EU's flagship instrument for ensuring structured and regulated access for European fleets to African fisheries resources. As geopolitical (growing presence of Asian fleets), environmental (climate change) and social (threats to food security) dynamics evolve, SFPAs must evolve and become, above all, strategic tools for promoting ocean governance, whose value lies in concrete contributions to sustainable development (in particular for communities dependent on fishing), inclusivity and participation, and food security.
We advocate for a new generation of SFPAs based on the following priorities:
1.2.1 Integration of human rights and transparency safeguards
In order to meet the EU's commitments in these areas, future SFPAs must systematically include a reference to the implementation of the Voluntary Guidelines for Sustainable Small-Scale Fisheries (VGSSF), and implement robust transparency clauses in line with what is identified in the international FiTI standard.
In support of the commitment made by the OACPS to establish a register of beneficial owners of fishing vessels at national level in order to enhance transparency in fisheries management, the EU should assist its SFPA partners, that are members of OACPS, in adopting legislation and systems to collect and publish this information on the beneficial owners of industrial fishing vessels operating in their waters.
1.2.2 Transparent, sustainable and beneficial joint ventures with third countries
The increase of joint ventures in the fisheries sector (mainly in capture but also in processing) linked to the European Union raises important questions in terms of environmental sustainability, social justice and transparency. When these joint ventures operate transparently and sustainably, without competing with small-scale fisheries, they can generate significant socio-economic benefits. When this is not the case, they weaken small-scale fisheries (e.g. trawlers fishing for small pelagic species, fishmeal factories, etc.).
Today, European rules governing these joint ventures are inexistant, creating a blind spot in the external dimension of the Common Fisheries Policy. It is therefore crucial that the EU considers joint ventures in the external dimension of the CFP and strengthens its transparency and sustainability requirements in order to avoid negative impacts on marine ecosystems and the livelihoods of small-scale fishing communities in third countries.
To this end, the EU should establish a mandatory register of joint fishing ventures, including disclosure of beneficial owners, areas of operation, target species and licences held. Such a register exists at national level, like in Spain.
The EU must consider EU investments in third countries as part of its external dimension, establishing a register of joint fishing ventures which includes information about beneficial owners. These vessels under joint ventures should comply with the same sustainability standards than those imposed on EU distant-water fleets under the SMEFF. Photo: An Asian-origin vessel reflagged to Guinea Bissau, local source.
The EU should require these vessels under joint ventures to comply with the same sustainability standards as those imposed on European external fleets under the SMEFF (traceability, compliance with scientific advice, AIS/VMS, observers on board), extending requirements beyond environmental sustainability to include social and economic equity (non-competition with small-scale fisheries on zones and resources, working conditions on board, etc).
The EU could make access to the European market and financial instruments (EIB, Global Gateway) conditional on the compliance with clear social and environmental criteria: fair local employment, non-interference in coastal areas reserved for small-scale fishing, selective fishing, etc.
Finally, in countries with a sustainable fisheries partnership agreement (SFPA) with the EU, these criteria should be incorporated into the text of protocols, for example in a specific annex dedicated to joint ventures (establishment and monitoring of existing ones), detailing transparency, sustainability, monitoring, and benefit-sharing obligations.
1.2.3 For better information and participation of local stakeholders
In response to the ongoing demands of African artisanal fisheries and civil society, a new generation of SFPAs must make participation a fundamental principle of good governance of the agreements. The negotiation and implementation of SFPAs must be open to those most affected by their impacts.
“The model of advisory groups established under trade agreements should be used to systematic consultation and effective participation of local fisheries stakeholders in Sustainable Fisheries Partnership Agreements (SFPAs).””
Future SFPAs should incorporate, from the outset, mechanisms for consultation and effective participation of artisanal fishing communities and civil society. This means that SFPAs should provide for the participation of local artisanal fishing organisations, as well as other civil society groups, in joint committees that review the implementation of SFPAs, in ex ante and ex post evaluations, etc.
Where national advisory groups exist, they should be systematically involved. And in partner countries where such bodies do not yet exist, the European Union should promote their creation, based on the model of the advisory groups established under trade agreements, particularly in the chapters on trade and sustainable development.
Such a mechanism would not only enhance the transparency and accountability of agreements, but would also help to anchor SFPAs in local realities, taking into account the needs, knowledge and proposals of coastal communities. It would give small-scale fishers a voice in resource governance, thereby contributing to co-management.
Furthermore, by formally supporting this participation, the EU would send a strong signal of consistency between its external fisheries policy and its human rights commitments.
1.2.4 Promoting food security
SFPAs should include clauses assessing and guaranteeing the availability of species for local consumption, in particular through measures to protect artisanal fishing areas and by promoting a fair and transparent system for allocating access that gives priority to those who fish sustainably, and for human consumption rather than for fishmeal.
Where appropriate, and to the extent that they do not compete with local artisanal fisheries and support the activities of women processors, protocols should also include incentives for landings that supply national or regional markets rather than export chains alone. These landings must be of species consumed locally.
Specific safeguards are needed to ensure that fish used in fishmeal and fish oil production does not undermine local nutrition.
1.2.5 Promoting a regional approach to SFPAs
Tuna agreements
One of the main obstacles to sustainable tuna resource management is the fragmentation of SFPAs into a series of bilateral agreements between the EU and each coastal state in the same region. This bilateral approach is disconnected from regional dynamics, particularly within Regional Fisheries Management Organisations (RFMOs).
To develop a coherent regional approach to SFPA in tuna fisheries, the European Union should commit to coordinating its agreements with coastal states within regional frameworks. Discussions within these regional frameworks should take full account of RFMO recommendations.
Concerning the allocation of tuna resources within these regional frameworks, the EU should advocate with its partners for the development of an approach to access allocation that gives priority to those (local vessels, including artisanal vessels, and foreign vessels) that fish in an environmentally and socially sustainable manner and bring the most benefits to coastal states (local employment, landings, etc.).
Such an approach should also provide for consultation mechanisms between partner countries in the same region and the EU, and include clauses such as requiring that regional fishing effort ceilings not be exceeded, or obliging to take measures to avoid by-catches of sensitive species and juveniles, including through fish aggregation devices.
Finally, a strengthened regional approach to tuna SFPAs cannot ignore the need to fully include the interests of small-scale tuna fisheries (existing or developing). Tuna protocols could actively support the development of the small-scale tuna sector (catches and processing) through improved access for women to the tuna resources they process (for example in Côte d'Ivoire), better local value addition of catches, and financing mechanisms for the sustainable transition of small-scale coastal fisheries to tuna fisheries (Sao Tome). The EU could support regional projects led by artisanal fisher's organisations aimed at strengthening their informed participation in tuna fisheries management and ensuring their place in access allocation systems.
Countries without port infrastructure to land tuna could benefit from a regional approach to tuna SFPAs, such as obtaining support to develop regional infrastructure (training centres) or the development of a local small-scale tuna fishery. Photo: fishers in Mauritius, by Miguel Alcantara.
A regional approach will also be useful for other issues such as the sharing of benefits from tuna agreements at regional level. Indeed, tuna fleets cannot land in all ports of the countries where they fish, but some countries where these fleets do not land could benefit from support to develop regional infrastructure (fishing training centres, training of regional observers, etc.).
Small pelagic stocks – West Africa
In the case of shared small pelagic stocks in West Africa, there is currently no RFMO.
Whereas a majority of these resources are overexploited, the EU maintains an access for its fleets to these resources in several countries in the subregion.
Pending the establishment of an RFMO, the EU can already strengthen its collaboration with coastal states and (sub)regional organisations (CSRP, COMHAFAT, COPACE/FAO) that are engaged in an exercise to determine (e.g. FAO/Nansen project) and harmonise access conditions for small pelagic species (Comhafat, CSRP).
This will harmonise access conditions for SFPA for shared stocks, support regional research, ensure the application of scientific advice and integrate participatory management initiatives established by small-scale fisheries (joint professional committees).
A pilot regional framework could be tested for small pelagic species in West Africa, with an emphasis on transparent participatory stock management systems and regional conservation measures.
1.2.6 Impacts of climate change
Climate change will have major effects on SFPAs between the European Union and partner countries, particularly in Africa. Changes in the distribution of fish stocks due to rising water temperatures, ocean acidification and declining oxygen levels in seawater will lead to shifts or declines in targeted resources (tuna, small pelagic species, shrimp, etc.), directly affecting the economic value of the agreements for third countries. The impacts of climate change also risk reducing the catches available to local small-scale fisheries, increasing competition with industrial fleets (European and others) and calling into question the long-term sustainability of the access protocols negotiated.
In this context, sectoral support in SFPAs is a strategic tool for strengthening the climate resilience of coastal ecosystems and communities. It can finance actions such as improving scientific data, developing fisheries adaptation plans, diversifying economic activities for women deprived of raw materials for processing, and strengthening local capacities for co-management and conservation. It can also be used to strengthen landing and conservation infrastructure, reducing post-harvest losses.
To be truly effective in addressing climate change, sectoral support from SFPAs must be reformed to better integrate environmental and social objectives, closely involving artisanal fishing communities and women in its planning and monitoring, including through artisanal fishers representatives participating to the SFPA joint committees. There is a need to move towards a participatory approach, aligned with national climate priorities and consistent with international commitments on adaptation, biodiversity and food security. In this sense, SFPAs can become instruments of climate solidarity and sustainable development.
2. Coherence of funding resources: essential for effective support
In order to provide genuine support for sustainable fishing, particularly small-scale fishing, in African countries, the EU must mobilise its financial instruments in a coherent, strategic and targeted manner. At the moment, it is not clear that it will be the case.
On the one hand, the European Union's proposal for the Multiannual Financial Framework (MFF) 2028-2034, includes support for the implementation of the CFP, the European Ocean Pact and to the Union’s maritime and aquaculture policy as part of the National and Regional Partnership Plan (NRPP) Fund. The new approach is to streamline implementation by merging cohesion, agricultural, rural and maritime priorities (including fisheries) under national and regional strategies, co‑designed by the Commission and Member States, delivered under a single partnership framework per Member State.
“The Commission needs to urgently clarify under which budget line the SFPAs will be, as there are conflicting documents which situate them under the National Regional Partnership Fund (NRPP) and others under Global Europe.””
The Commission proposal for the NRPP Fund explicitly states that it will continue to be the main instrument to provide financing to “continue the drive for concrete delivery on the Union’s objectives, both within the EU and at international level.” This funding is presented as a key enabler for the strengthening of international ocean governance. The European Commission also underlines the fact that continued funding is needed “to finance the international cooperation: Sustainable Fisheries Partnership Agreements (SFPAs), and Regional Fisheries Management Organisations (RFMOs), creating the appropriate levers and enabling outcomes as well as promoting high global standards and advancing the EU.”
However, on the other hand, the Commission proposal for MFF also includes “Global Europe”, the single instrument for EU external action, merging NDICI, humanitarian aid and pre‑accession support. This instrument covers themes on ocean governance, climate, biodiversity, and sustainable blue economies. In the Commission Communication on MFF (see page 30), the funding of SFPAs and EU action in RFMOs are listed as part of the Global Europe funding line.
So, which is it going to be? This confusion needs to be urgently clarified.
The strong accent put, in the case of the NRPP, on supporting small scale fisheries in Europe, indicates that the Commission has realised the potential of small-scale fisheries to deliver sustainable fisheries and coastal development. This is even more true when it comes to African small scale fisheries, which are the backbone of the coastal communities.
Whether the funding for SFPAs/RFMOs is also under Global Europe or under NRPP Fund, what is essential is that SFPAs become a tool of the strategy for EU external fisheries action, with the primary objective of supporting sustainable fisheries in partner countries, rather than funding EU fleets access.
Adopting this approach, other lines under “Global Europe” (that can finance fisheries initiatives in Africa through projects on capacity-building or climate resilience in coastal communities) should complement SFPA funds by financing initiatives that SFPAs alone cannot cover entirely, - like value‑chain development (landing sites for small scale fisheries, women fish processing activities, or climate adaptation in African small‑scale fisheries), technical assistance to strengthen African countries, and fishing communities, informed participation to RFMOs, or to create a new RFMO on small pelagics in West Africa.
However, without explicit political will to promote coherent support to small scale fisheries in Africa, and appropriate coordination mechanisms, Global Europe projects on oceans may focus on conservation or maritime security, ignoring the necessary support to (artisanal) fisheries, while NRPP funding related to fishing operations in Africa will remain tied to EU fleets access arrangements.
Through its strategy for external fisheries action, the EU needs to align Global Europe fisheries initiatives spending and SFPAs, ensuring synergies between both instruments deliver sustainability, transparency, food security and climate resilience in partner countries.
If the EU was to reduce the allocations of funds for governance and sustainable (fisheries) development, it would risk losing strategic influence facing other strong actors who are present in the region. This would compromise the standards of transparency and good governance the EU has put so much effort into promoting. Photo: A tuna seiner in Mauritius, by Jo-Anne McArthur.
Secondly, it is likely that, overall, amounts devoted to external fisheries action will be lower than in the 2021 - 2027 MFF. In the MFF proposal, EMFAF is ‘absorbed’ into the NRPP Fund, which will be dominated by agriculture and cohesion funds. Global Europe will become a giant fund with no sector specific funding lines. Thus, the share for external fisheries is likely to be diminished compared to agriculture, Ukraine‑related priorities, etc.
If the EU was to reduce its overall support for governance and sustainable fisheries development in partner countries, it risks losing strategic influence to other actors who are increasing their support (like China), and compromising the standards of transparency and good governance that it seeks to promote through its strategy for external fisheries action.
Given this likely reduced funding, efficiency and tangible results are paramount. Ensuring synergies between Global Europe fisheries-related spending and SFPAs is a way to improve efficiency. Focusing the support on small scale fisheries, which are a pillar of coastal economies, food security and climate resilience in partner countries will help to deliver tangible benefits to partner countries. For this reason, it will be essential that the strategy for fisheries external action clearly integrates partner countries’ small-scale fishing communities as a priority sector to support.
Re-allocating European public funds currently allocated to paying for access to resources in SFPAs to sectoral support, in line with the sustainable development priorities of the countries concerned, will also be necessary to improve EU support to sustainable fisheries development in partner countries.
Better coordination between different policies and funding instruments also requires the implementation of regional strategies according to ocean basins, something which was already proposed in a Commission communication a decade ago and backed by the European Parliament. These strategies should be co-constructed with African partner governments and stakeholders, in particular small-scale fisheries, and benefit from strong inter-service coordination between the relevant directorates-general (MARE, INTPA, EEAS).
This coordination could be strengthened by establishing an annual dialogue between EU fisheries and development ministers in order to maintain strong political commitment. At the same time, dialogue between the administrations involved in these initiatives (DG Mare, DG Intpa, Fisheries Cooperation in Member States) should be relaunched. Until about ten years ago, this dialogue existed through EUFDAN (EU Fisheries Development Administrations Network).
Conclusion
Through its strategy for external fisheries action, the European Union will have a powerful lever to advance its international commitments on sustainability, food security, climate justice and human rights.
But to achieve this, particularly in the context of the MFF discussions, it must rethink its instruments, aligning them more closely with the priorities expressed by African partner countries and small-scale fishing communities, which are the backbone of food security, biodiversity protection and resilience to the impacts of climate change.
This requires a renewed approach based on transparency, recognition of SSF communities potential, and the support to SSF as an essential part of the European strategy for external fisheries action.
The strategy for European external fisheries action must be guided by coherence and inclusiveness, where ocean governance is carried out with fishing communities, and not on their behalf. The EU must ensure that its financial, diplomatic and technical choices contribute to strengthening sustainable small-scale fishing communities in partner countries, rather than marginalising it.
By doing so, the EU will not only honour its multilateral commitments, but also position itself as a credible player in inclusive ocean diplomacy, capable of combining social justice, marine conservation and food security for the benefit of current and future generations.
Banner photo: Vigo harbour, the largest fishing port in Europe, in the sunset, photo from Unsplash.
In this position paper, CFFA contributes to the Commission open consultation on an EU strategy for fisheries external action. In it, CFFA calls for a strategy that looks into policy coherence for development, including a focus on food security, the importance of participation of stakeholders and of including human rights safeguards. In the second part of the position, CFFA looks at the coherence in the resources put forward to fund this external strategy, as essential for effective action.