Illegal, Unreported, and Unregulated Fishing and its Links to Labor Abuse
“IUU fishing vessels have been known to subsidize costs using forced labor exploitation, as they are already evading laws, regulations and oversight to drive profits and may be more willing to exploit workers.” —Oceana, Illegal Fishing and Human Rights at Sea

Illegal, unreported, and unregulated fishing
Fishing that occurs outside of fishery laws and regulations, or that outright breaks those laws and regulations, is illegal, unreported, and unregulated (IUU). Here is a closer look at these terms:
- Illegal: Fishing without a license, fishing over a set quota, fishing in a prohibited region, fishing with prohibited gear, or fishing prohibited species
- Unreported: Failing to report or underreporting fish caught
- Unregulated: Fishing in regions with patchy regulation or little enforcement, which is prevalent on the high seas; unmanaged fish stocks, such as noncommercial species or reduction fisheries, also lack ways to assess global catch estimates and may result in challenges to international access negotiations
Estimates of global IUU fishing reach up to 26 million tons of fish caught annually, with a value between 10 billion and 23 billion USD. Worldwide, IUU fishing accounts for around 20 percent of the total seafood catch.
Advocacy organizations have been working toward a definition of IUU fishing that includes fishing associated with forced labor and human trafficking. Civil society has pushed governments to adopt regulation and enforcement measures that tackle these issues concurrently because they are so deeply intertwined.
IUU Fishing and Human Rights Abuses
Overfishing and IUU fishing have resulted in diminishing fish stocks and have led to a decrease in the return on investment for fishing companies and vessel captains. Depleted resources in nearshore waters force vessels to go further out to sea and for longer periods of time to fill their catch quota, increasing fuel and maintenance costs. These circumstances, combined with a high global demand for seafood, increase incentives for labor abuses and other illegal activities. In order to maintain profits, fishing companies may seek to reduce the operating costs within their control by, for example, reducing crew sizes, relying on forced or coerced migrant labor, increasing work hours, and ignoring important health and safety measures.
The remoteness of much fishing activity and the challenges of enforcing laws at sea creates an environment of lawlessness that is ripe for exploitation. Illegal activities that may be conducted at sea include IUU fishing; human trafficking and forced labor; organized crime; and trafficking in wildlife, drugs, weapons, or other goods. Of these activities, research shows that labor abuses account for the most common crimes connected with IUU fishing.
Undocumented or unmonitored steps in supply chains are particularly high-risk due to their lack of transparency. It is hard to quantify the true extent of illegal activity and human or labor rights violations because these practices are hidden. Unauthorized transshipment and the lack of adequate fisheries monitoring, control, and surveillance systems, as well as the lack of transparency about vessel owners and histories have helped create an environment where human rights and environmental violations can occur with impunity.
Countering IUU fishing with Traceability and Engagement
A comprehensive sustainable seafood program requires a deep assessment of both environmental and social components of your company’s supply chain. Given the links between IUU fishing and human rights abuses, best practice includes three steps:
- Assess risk by collecting and analyzing data about products, companies, and people associated with the production of seafood.
- Identify gaps in traceability for products in your supply chain.
- Develop traceability systems to increase visibility and supply chain oversight as well as transparency regarding vessel information and activity.
Traceability is a powerful tool for advancing responsible seafood supply chains. It enables companies to identify and address risks, from food safety concerns to IUU fishing, and human rights abuses. Traceability drives transparency and real accountability, giving stakeholders the visibility they need to take decisive action.
Yet collecting key data elements alone is not enough. Information must be verified, analyzed, and, most importantly, acted upon to close gaps, ensure compliance, protect workers, safeguard public health, and reduce reputational and financial risk. Traceability should not be seen as the end goal, but as one of several tools you can use to build more ethical, resilient, and sustainable seafood supply chains.
Countering IUU fishing is a massive undertaking that cannot be done by seafood businesses alone. Seek out opportunities to engage with multi-stakeholder initiatives, precompetitive collaborations, and government engagement to address this problem. Fortunately, the use of import regulations and collaborative, industry-led traceability initiatives to combat this problem is increasing. Simultaneously, port state measures, investments in producer country infrastructure, and private sector partnership have begun to tackle the challenge of IUU fishing.
You can reference the Seafood Alliance for Legality and Traceability (SALT)’s Comprehensive Traceability Principles for a clear, step-by-step description of how to integrate robust traceability into your human rights due diligence program. SALT is a global community of governments, the seafood industry, and nongovernmental organizations working together to share ideas and collaborate on solutions for legal and sustainable seafood, with a particular focus on electronic traceability.
The engage step of the RISE Roadmap provides guidance for effective collaboration on IUU fishing, including comprehensive guidance on working with supply chain stakeholders, precompetitive collaborations, and governments. The RISE Community is a great place to research and connect to organizations and groups working to reduce IUU fishing.
- Report from Oceana, Transparency and Traceability: Tools to Stop Illegal Fishing
- Fact sheet from the Pew Charitable Trusts, “Port State Measures Agreement: Why Seafood Buyers Should Help”
- Input to the United Nations (UN) Special Rapporteur on Human Rights and the Environment:
Requests the UN and its related agencies to coordinate in order to examine and address the linkages between IUU fishing, forced labor, and human rights abuses.
- Report from FishWise, The Links Between IUU Fishing, Human Rights, and Traceability
- Article from Ian Urbina, “Lawless Ocean: The Link Between Human Rights Abuses and Overfishing”
- Report from Oceana: Illegal Fishing and Human Rights Abuses at Sea: Using Technology to Highlight Suspicious Behaviors
- Web page from U.S. Customs and Border Protection, “Illegal, Unreported, and Unregulated Fishing”
- Joint Executive Letter: Implementation of National Security Memorandum on Combatting Illegal, Unreported, and Unregulated Fishing and Associated Labor Abuses (NSM-11):
Pushes for U.S. agencies to coordinate in tackling IUU fishing and forced labor in the seafood sector as linked issues.
- Press release from Oceana, “Three Coalitions Urge the EU, Japan, and U.S. Governments to Strengthen Cooperation to Fight Illegal Fishing and Labor Abuses in Seafood Supply Chains”
Fact sheet from U.S. Department of State, “U.S. Efforts to Combat Illegal Fishing and Associated Labor Abuses”