Three Pelagic Fisheries Management Plans - Business and Regulatory Impact Assessment (BRIA)

Executive summary

This partial BRIA describes the anticipated economic impact on the fishing sector and associated businesses of the following three FMPs:

• Proposed North Sea horse mackerel FMP

• Proposed North Sea greater silver smelt FMP
• Proposed West of Scotland greater silver smelt FMP

These three FMPs are part of the 21 FMPs for which the Scottish Government is the co-ordinating authority. They do not result in direct measurable impacts at this stage because the FMPs do not result in new regulation upon publication. Therefore, this document is a narrative assessment and does not include monetised or quantified costs to businesses. As specific actions are implemented, further impact assessments (by all relevant authorities) will be completed that include a more complete assessment of the monetised costs to business associated with that action.

The following options have been considered as part of the partial BRIA:

Option 1 (preferred option): Publication of the three pelagic FMPs

It is considered that pursuing Option 1 and publishing the FMPs would enable the Scottish Government (and the other relevant authorities in the UK) to support delivery of sustainable fisheries for current and future generations. Option 1 would also comply with the statutory obligation in the Fisheries Act 2020 (the 2020 Act) to prepare and publish the FMPs (the FMPs having been included in the Joint Fisheries Statement (JFS) November 2022 (and amended in December 2024).

As noted above, the FMPs themselves will not introduce any new regulatory measures upon publication, accordingly it is not considered their publication would introduce additional costs. The costs associated with implementing measures which may be developed through actions identified within the FMPs depend on the specifics of the measures which are subsequently proposed. As these are currently unknown, they cannot be identified or quantified. However, future costs could arise if fishers need to change where or how they fish, or if they must comply with new gear and equipment requirements. Additional operating and administrative costs may also result from these changes.

The benefits associated with potential new measures developed through implementation of the actions in the FMPs depend on the specific measures proposed. As these are currently unknown, the benefits cannot be identified or quantified at this time but are anticipated to materialise in the form of sustainable fishing opportunities that will provide long-term economic stability to the sector. There may also be environmental benefits realised through improving the underpinning evidence base, facilitating management decision making that considers a wider and improved range of fisheries and environmental data.

Option 1 - Publication of the three pelagic FMPs – is recommended.

Option 2: Business as Usual (Do Nothing) – No pelagic FMPs published

The Scottish Government (and the other relevant authorities in the UK) have obligations arising from the 2020 Act and JFS to publish the FMPs by the specified statutory deadlines. Before proceeding with a business as usual (BAU) option of not publishing FMPs, it would be necessary for steps to be taken to vary the current obligations (through amendments to the JFS).

As a continuation of BAU, Option 2 is unlikely to result in any additional costs to businesses beyond those already incurred by the pelagic fishing sector, and associated business. There may be some benefit in the continuation of BAU, given that it is consistent with regulatory framework of previous years, however, the impact of this benefit is unlikely to be significantly felt by businesses. Option 2 of not publishing the FMPs would lose the benefit of enabling the Scottish Government (and the other relevant authorities in the UK) to support delivery of sustainable fisheries for current and future generations.

Option 2 – Business as Usual (Do Nothing) – is not recommended.

Sectors affected by the policy

The following sectors have been identified as groups who will be affected by the proposal: UK pelagic and demersal fishing industry, international demersal and pelagic fishing industry operating in UK waters, and UK retailers. Businesses will be invited to respond to the public consultation.

Engagement

The three pelagic FMPs have been shaped by a range of stakeholder engagement initiatives, including two pre-consultation events led by the Scottish Government on 25 March 2026 with industry, eNGO, and community representatives. Feedback from these sessions informed the draft content and the development of actions, ensuring the plans reflect stakeholder knowledge and support sustainable future management. Further input gathered through formal public consultation will be used to finalise the FMPs.

Post implementation review

The 2020 Act requires the FMPs to be reviewed at least every 6 years from the date of publication, to assess the extent to which the policies in the plan have been implemented and how the stocks have been affected. This formal review will assess how the FMP has performed in terms of meeting the objectives of the Act. Additionally, progress implementing the policies will be assessed as part a 3-yearly report on the JFS.

Introduction

The Joint Fisheries Statement (JFS), as required by the Fisheries Act 2020 (the 2020 Act), sets out how the UK fisheries authorities (Department for Environment, Food & Rural Affairs (Defra), Scottish Government, Welsh Government and the Department of Agriculture, Environment and Rural Affairs in Northern Ireland (DAERA^[1]) will prepare and publish 43 Fisheries Management Plans (FMPs) by 2026. This includes the Scottish-led FMPs, with some of the remaining plans led by the other UK fisheries authorities to be published by 2028^[2].

The plans bring together the evidence on the state of the stocks and identify measures and actions necessary to improve the evidence base and manage our fisheries in a sustainable way. Policies in an FMP set out both the short-term actions and longer-term vision for the management of the fishery.

This assessment is being undertaken alongside a public consultation on the three proposed pelagic FMPs, jointly developed by the following UK fisheries authorities: Scottish Government, Defra and DAERA. Further information is sought in the consultation regarding additional economic evidence to update this assessment before the publication of the final pelagic FMPs.

This partial BRIA describes the anticipated economic impact of the three pelagic FMPs on the fishing sector and associated businesses.

This assessment document covers the following three FMPs:

• Proposed North Sea horse mackerel FMP

• Proposed North Sea greater silver smelt FMP
• Proposed West of Scotland greater silver smelt FMP

The three fish stocks covered by these FMPs are of limited importance to the UK fishing industry. They are landed in relatively small quantities by UK vessels, make up only a small part of the catch for the fleets that target them, or they are mainly taken as bycatch in other fisheries.

Although UK fishing vessels currently have little direct commercial interest in these stocks, it is still important to manage them sustainably. Catch limits in the form of Total Allowable Catches (TACs) are set annually, informed for the majority of these stocks by scientific advice from ICES. Some of the pelagic FMPs cover more than one ICES advice area and/or TAC, and for some stocks, a single ICES advice sheet may feed into more than one UK quota. These are explained further within the FMPs.

ICES advice is organised into assessment categories ranging from Category 1 (the highest level of information available) to Category 6 (the lowest). Additionally, benchmark exercises are used by ICES to evaluate existing and new scientific evidence and methods and, where relevant, apply them in the stock assessment process. They are part of the continuous improvement process which ensures that ICES advice is based on the best available scientific evidence.

The summary below reflects the ICES assessment framework^[3] in place at the time the draft FMPs were prepared.

1. North Sea horse mackerel

   1. the Western horse mackerel stock is classed as a Category 1* stock;
   2. horse mackerel in the Southern and Central North Sea (SCNS) and eastern English Channel was upgraded to a category 1**** stock following ICES benchmarking exercise in 2024 although at the time of writing this is currently under review.
2. North Sea greater silver smelt is classed as a Category 2* stock based on most recent ICES advice^[4].
3. West of Scotland greater silver smelt is classed as a Category 1* stock at the time of writing this FMP.

(*) The stock has a high level of data available and there is sufficient available scientific evidence for the relevant fisheries policy authorities to make Maximum Sustainable Yield (MSY) assessments for this stock. This includes stocks with quantitative (Category 1) or qualitative (Category 2) assessments.

(****) Although the SCNS and eastern English Channel horse mackerel stock has been upgraded to Category 1, the evidence base remains insufficient to establish robust MSY reference points. The latest scientific assessment indicates that spawning stock biomass is below B_lim and that catch advice is therefore currently set at zero. Strengthening the evidence base remains a priority, particularly because the stock is managed as a bycatch-only stock, limiting the quantity of fishery-dependent data available to inform scientific assessments. While acknowledging these evidence limitations, the stock is currently classed as a Category 1 stock by ICES, therefore, the policies and actions for the SCNS and eastern English Channel horse mackerel stock have been drafted to meet the requirements of section 6(3)(a) of the 2020 Act.

The economic impact of the three proposed FMPs is expected to be limited. North Sea horse mackerel is the only stock associated with a notable commercial fishery for UK vessels, generating average annual landings of approximately 3,800 tonnes and a landed value of around £2.8 million between 2018 and 2024. In contrast, both North Sea greater silver smelt, and West of Scotland greater silver smelt support little or no current UK fishing activity and generate negligible landed value. Consequently, any direct costs or benefits arising from these FMPs are expected to be concentrated on a relatively small number of operators involved in the horse mackerel fishery, with minimal impacts on the wider fishing sector.

Source: SG internal fisheries management data, August 2025. Figures may differ from the published UK sea fisheries annual statistics report 2024.

The principal climate-related impact associated with these three stocks is the increasing uncertainty that climate change introduces to stock distribution, productivity and management. Horse mackerel has already exhibited evidence of climate-related ecological change, while greater silver smelt may be vulnerable to changes in deep-water habitat conditions. Given these uncertainties, the FMPs support a flexible and adaptive management approach that can respond to emerging scientific evidence and changing environmental conditions.

The three FMPs set out policies and actions relating to the stocks which are to be implemented in a way that is consistent with, and supportive of, the wider achievement of the fisheries objectives set out in the 2020 Act, the policies contained within the JFS and other legislative commitments.

These plans also identify evidence gaps and consider research for the species they cover to enhance current management and ensure that sustainability is maintained.

The FMPs describe an overview of the current fisheries for horse mackerel and greater silver smelt in UK waters as well as providing information on available stock assessments, MSY and stock biology.