Fishing - pelagic quota cuts 2026: business and regulatory impact assessment

Pelagic Quota Cuts 2026 - Scottish Government Response - Final Business and Regulatory Impact Assessment - 17 December 2025

This Final Business and Regulatory Impact Assessment (BRIA) set out why the Scottish Government is amending the economic link requirements to help maintain pelagic landings into Scotland during 2026 by introducing species-specific landing requirements for mackerel and herring at 70%. Following international negotiations (based on advice from the International Council for the Exploration of the Sea (ICES)) Coastal States have agreed to a 48% cut in the North East Atlantic mackerel TAC and a 22% cut for herring. Reductions on this scale present a serious risk to the viability of Scottish pelagic processors and consequences for the wider supply chain. Without action, landings into Scotland will fall sharply, undermining local economies, reducing employment, and weakening investment in infrastructure.

To mitigate these risks, the Scottish Government will amend the economic link licence condition so that applicable vessels are required to land at least 70% of mackerel and 70% of herring into Scotland during 2026. This emergency measure is time-limited to 2026, will be kept under review during the year and evaluated before 2027 to ensure proportionality and effectiveness.

Introduction

This Final Business and Regulatory Impact Assessment (BRIA) sets out why Scottish Government intervention is being introduced to increase the proportion of mackerel and herring landed into Scotland during 2026. Following international negotiations, based on advice from the International Council for the Exploration of the Sea (ICES), Coastal States have agreed to a 48% cut in the Northeast Atlantic mackerel TAC and a 22% cut for herring. These exceptional reductions present a serious risk to the viability of Scottish pelagic processors and the wider supply chain.

Without action, landings into Scotland will decrease significantly (we estimate a drop of around 60% for mackerel compared to 2024 landings), undermining local economies, reducing employment, and weakening investment in processing and port infrastructure.

The Scottish Government will amend the economic link licence condition so that applicable vessels are required to land at least 70% of mackerel and 70% of herring into Scotland during 2026. This approach builds on the amended economic link licence condition introduced in 2023, which strengthened landings requirements and removed alternative compliance routes. The proposed measure seeks to mitigate the negative economic and social impacts of reduction in landings while still allowing vessels choice in relation to a portion of their landings. This emergency intervention is for 2026 and will be evaluated before 2027 to ensure proportionality and effectiveness.

Executive Summary

This document is a Final Business and Regulatory Impact Assessment (BRIA) addressing the implications of substantial pelagic quota reductions recommended by the International Council for the Exploration of the Sea (ICES) for 2026. Following international negotiations a TAC reduction of 48%^[1] is to be implemented for mackerel and a 22% cut for herring. This presents a serious risk to the Scottish pelagic catching, processing and the wider related supply chain. These reductions could lead to decreased landings into Scotland, undermining local economies and investment opportunities.

Following processors calls, the Scottish Government considered regulatory intervention to increase the proportion of mackerel and herring landed by Scottish vessels into Scotland. This builds on the amended economic link licence condition introduced in 2023, which strengthened landings requirements and removed alternative compliance routes such as crewing or expenditure. Voluntary approaches are not considered sufficient to deliver the necessary level of landings and economic benefit.

Following consideration, the Scottish Government is going to increase the landing target element of economic link for pelagic species to 70% for 2026. This adjustment is designed to secure a greater share of pelagic landings into Scotland (particularly for mackerel) during a year of exceptional quota constraint, mitigating risks to processing capacity and associated employment. The option of quota gifting will remain available as an alternative compliance route, consistent with the current economic link framework. For context, under the existing Business-as-Usual (BAU) scenario — where the requirement remains at 55% — anticipated landings of mackerel into Scottish factories would fall to around 39,094 tonnes, a sharp reduction compared to recent years with significant impacts on onshore industries. The proposed increase to 70% aims to address this gap while maintaining proportionality and alignment with national benefit objectives. It will see anticipated that mackerel landings will increase from around 39,094 to 59,324 tonnes as a result of the move to a 70% requirement. The intervention arising from this assessment is for 2026 only and will be assessed before 2027.

Who Will Be Affected

• Directly affected: Scottish pelagic catching sector, processors and ports.
• Indirectly affected: Associated supply chain businesses, transport, and local communities dependent on pelagic landings.

Engagement Completed

• 26 individual meetings (both via Teams calls and in-person meetings) with catching businesses, processors and port authorities and other round table meetings with representative bodies.
• Consultation with Scottish Government policy teams and communication with other UK administrations.

Issue and Why it Needs to be Addressed

Introduction

Following the outcome of international negotiations, it has been agreed that the Northeast Atlantic mackerel Total Allowable Catch (TAC) will be reduced by 48% for 2026, alongside a significant reduction for herring. These combined cuts are unprecedented in scale and present a serious risk to the viability of Scotland’s pelagic processing sector and the wider supply chain.

Without intervention, landings into Scotland will decline sharply. Under the current economic link arrangements (55% requirement), anticipated landings into Scottish factories are projected to fall to around 39,094 tonnes in 2026, compared to over 106,000 tonnes in 2024. This level of reduction would significantly undermine processing throughput, threaten jobs, and weaken investment in port and factory infrastructure.

The Scottish Government has long committed to increasing the proportion of Scotland's key stocks landed into Scotland to strengthen economic benefits for coastal communities and safeguard processing capacity. To this end, in 2023, following consultation, the Scottish Government introduced amendments to the economic link licence condition.

Background on the Economic Link Licence Condition

Economic link licence conditions have been included in UK fishing licences since 1999 and apply to vessels over 10 metres in length. The policy aligns with the national benefit objective in the Fisheries Act 2020, supporting coastal communities and maintaining the role of the seafood sector in employment and food supply. It aligns with the Scottish National Marine Plan, particularly Objective 3 and 4 of the Sea Fisheries policy section. The policy approach aims to ensure that Scottish vessels fishing against Scottish quota (which are distributed yearly by the Scottish Government for no charge) provide genuine economic benefits to Scottish communities dependent on fisheries and related industries. Historically, compliance options included landing a percentage of catch in the UK (the ‘landings target’), having crew resident in the UK, expenditure in the UK, or transferring quota if landing targets were not met. These conditions applied uniformly across the UK until April 2022, when England introduced changes (which increased the ‘landings target’ element to 70% and removed the option for fulfilling economic link obligations expenses incurred in the UK)^[2].

The Scottish Government consulted on amending the requirement in response to increasing quantities of fish — particularly mackerel and herring — being landed abroad, reducing benefits to Scotland.

The aim was to increase the volume of valuable fish stocks landed in Scotland in order to:

• Support the long term, sustainable growth of local economies where fishing is an important driver for business activity (e.g. Peterhead, Fraserburgh, and Shetland) by increasing the volume and regularity of the supply of fish landed and available to process in Scotland;
• Attract greater investment and employment in Scotland’s fishing industry by reducing supply chain risks for Scottish fish processing and handling businesses; and
• Bring greater social and economic benefits to Scotland from a Scottish national resource by spreading the benefit arising from fishing quotas more widely through fishing communities.

Following consultation, amended provisions were introduced from 1 January 2023, making landings into Scotland the main basis for compliance, removing options for crewing or expenditure, and increasing the minimum qualifying landings threshold from 2 tonnes to 10 tonnes. The number of stocks covered was reduced to eight key species (including mackerel and herring), and the landings target was raised from 50% to 55%, with phased targets for pelagic species: 30% (2023), 40% (2024), and 55% (2025). The option of quota gifting remains as an alternative to landing into Scotland. These changes have increased the proportion of mackerel and herring being landed into Scotland — from a pre-policy average of 50% to 57% in 2023 and 63% in 2024. This has helped bring brought an estimated £58 million worth of landings (in its first two years of operation alone) providing a platform for investment in Scottish processing facilities and ports. For further information on the amended economic link arrangements, including an assessment against the original aims, please see the recently published review^[3].

Calls for Further Action

Despite the recent increase in landings following the amended economic link licence condition, the scale of the ICES-recommended quota cuts for 2026 means that landings will fall very sharply and may not be sufficient to maintain throughput for Scottish processors, including secondary processors. This has prompted strong calls for government action from the processing sector, which argues that without intervention, reduced volumes will undermine factory viability, investment and jobs in coastal communities.

However, any such intervention is controversial. Many in the pelagic catching sector are strongly opposed to further regulatory requirements, for reasons such as reduced potential profits and operational flexibility and market access. These businesses will also be affected by the quota reductions themselves, as the available tonnage for mackerel and herring will be substantially lower, reducing earning potential and increasing financial pressure.

Wider market conditions also need to be considered. Price volatility could compound the economic impact of quota reductions, making it harder for both processors and catching businesses to plan and invest. The proposed policy seeks to mitigate these risks by increasing the proportion of mackerel and herring landed in Scotland, while considering measures to reduce unintended impacts on vessel viability and maintain Scotland’s competitiveness in global markets.

Intended Outcomes

The purpose of this assessment is to determine whether government intervention is required in response to the ICES-recommended quota reductions for mackerel and herring for 2026. These cuts present risks to the viability of Scottish pelagic processors, catching businesses, and associated communities.

Key intended outcomes of the policy assessment are:

• Evaluate the necessity and proportionality of intervention in light of quota reductions and their potential economic and social impacts on both the catching and onshore sectors.
• Assess whether intervention is in the public interest, balancing benefits to processors and coastal communities against potential costs and operational challenges for catching vessels taking into consideration wider market dynamics.
• Ensure alignment with Scottish Government strategic objectives, such as optimising the value of the product both on first landing and through the supply chain, contributing to food security and provision of a healthy food source.
• Consider alternative approaches, including maintaining current arrangements, voluntary measures, or regulatory changes, and identify which option best supports sustainable fisheries and fair distribution of benefits.

The ideal outcome is a clear, evidence-based decision on whether additional measures are justified and, if so, what form they should take to deliver maximum public benefit while minimising unintended consequences.