Proposed Fisheries Management Measures within Scottish Inshore Marine Protected Areas (MPAs) and proposed Priority Marine Feature (PMF) Management Areas - Partial Business and Regulatory Impact Assessment (BRIA)

5. Costs, impacts and benefits

This section estimates the costs for each policy option. Although focus is placed here on costs to the private sector and the public sector, wider costs and benefits have been estimated as part of the SEIA; these include costs and benefits to ecosystem services, social impacts, and other non-quantifiable costs. Due to the variability in potential costs to the fishing industry, values presented are an estimate based on best available data, and it is acknowledged that impacts will likely fall between the figures given. Site and area-specific industry costs can be found in SEIA Appendices E to Q.

5.1 Impacts to commercial fisheries and processors

Commercial fishing takes place throughout Scottish waters by UK-flagged vessels, as well as vessels from other EU Member States and non-EU countries. Within 12 nautical miles (NM), only UK-flagged vessels are permitted to fish. In 2022, the Scottish fleet was responsible for landing 62% of the total value and 67% of the total volume of UK fish and shellfish landings^[10]. In the Scottish inshore areas, fishing activity is predominantly carried out by Scottish vessels (non-UK vessels do not have access to the 0–6 NM zone, and the UK-EU Trade and Cooperation Agreement^[11] removed historic access rights to the 6–12 NM area for EU vessels around Scotland). Close to the coast is mainly fished by smaller vessels (under-12 metre). Further offshore, there is more activity by larger vessels.

Demersal species (including monkfish, cod and hake) and shellfish (including scallops, crabs and Nephrops) predominate in the inshore area. These made up 56% by value of landings by Scottish vessels in 2022, with a total value of £170 million and £172 million, respectively.

Due to Covid-19 during 2020 and 2021, the closure of the restaurant and hospitality sector in the UK and abroad adversely affected the demersal and shellfish sector. The pelagic sector, being seasonal and operating with larger vessels, was mainly unaffected by the impacts of Covid-19, with increasing tonnage and value from 2019 (Scottish Government, 2023). Part-time fishers in 2022 decreased by 25% since 2021, which was attributed to Covid-19^[12].

Impacts on commercial fisheries are presented by site, for each type of site (NCMPAs, SACs, SPAs), and proposed PMF management areas. More site and area specific information can be found within the SEIA Appendices E to Q.

Impacts to commercial fisheries have been estimated in terms of value of landings using Vessel Monitoring System (VMS) data linked to landing records and International Council for the Exploration of the Sea (ICES) rectangle landings data. Data from the last five years are used to calculate an annual average value that takes account of annual variations in fishing patterns. The years used are 2016 to 2022, excluding 2020 and 2021 due to the disruption during the Covid-19 pandemic.

The value of landings affected was converted into direct gross value added (GVA) using fleet segment-specific GVA multipliers, and the direct, indirect and induced impacts on GVA and employment were calculated from Scottish (national) multipliers.

Impacts on direct GVA are calculated using fleet segment-specific multipliers from Seafish economic data. This is based on GVA as a proportion of fishing turnover. This gives a reasonable approximation of direct GVA that is specific to the fishing sector and to different vessel sizes and gear types, however, the impact on individual vessels may differ from the fleet segment averages.

The impacts were estimated in annual terms using a baseline of 2016 to 2019 and 2022 average fishing data. These estimated annual impacts were then summed over the assessment period (20 years), and the present value (PV) was calculated using discounting in line with the HM Treasury Green Book (2022).

Across the entire suite of MPAs and proposed PMF management areas, over the assessment period the proposed management measures are estimated to (worst case scenario):

• Reduce the average annual value of output landed by the commercial fisheries sector for Option 1 by between £0.6 million and £1.4 million, and for Option 2 by between £9.7 million and £10.3 million;
• Reduce average annual Gross Value Added (GVA) (direct and indirect) for Option 1 by £0.3 million to £0.7 million, and for Option 2 by between £4.7 million to £5.1 million;
• Reduce GVA (direct and indirect) for Option 1 by £4.1 million to £10.2 million, and for Option 2 by £69.5 million to £74.3 million over the 20-year assessment period; and
• Reduce the average (mean) number of jobs (direct and indirect) for Option 1 by between 6 and 16 jobs, and for Option 2 by between 109 and 117 jobs (full-time equivalents, UK vessels and upstream supply chain).

The ranges reflect the different management options and assumptions assessed. The higher estimates from the upper end of Option 2 represent stronger management measures (whole site measures or more precautionary PMF management areas) and a worst-case assumption that the displaced fishing effort does not move to other locations, resulting in a reduction in landings. The lower estimates from the lower end of Option 1, are based on more focussed and zoned or temporal management measures and refined PMF management areas and assume that displaced fishing effort can move to other locations (under certain circumstances, determined by the ‘displacement test’), without significant environmental or socio-economic consequences. Likewise, the upper estimate for Option 1 represents an assumption that no displacement takes place, the lower estimate for Option 2 represents an assumption that fishing displacement will take place. The displacement test can be found in the SEIA section A.6. Table 2 below summarises the above distinctions:

The number of fishing vessels and the value and proportion of landings affected may be different for each of these four estimates. The value of landings lost is lowest for the Option 1 including displacement estimate and is highest for the Option 2 excluding displacement estimate. The proportional impact on landings may be higher when displacement is included given those vessels with smaller proportional impacts may be able to displace their fishing effort.

The lower end of the range for Option 1 is estimated to have minor impacts on fisheries, with Option 2 having potentially significant impacts (Table 4)

Under Option 1:

• the regions most affected are West Highlands and Hebrides Shelf, followed by Outer Hebrides and Forth and Tay;
• the impacts on value of landings in the context of total value of landings from each region, are minor, up to 1% of the total value of landings from each region.

Under Option 2:

• the region most affected is Moray Firth, followed by West Highlands and North East;
• the impacts are potentially very significant in certain regions – almost two thirds of landings from Moray Firth region (59%) are affected, and one fifth of landings from the North East region (18%).
• impacts in West Highlands (5%–6%), Clyde (3%) and Forth & Tay (2%) are notable.

The impacts fall predominantly on over-12 metre demersal trawls and mechanical dredges, and under-12 metre demersal trawls. Mechanical dredges are mostly impacted in the Outer Hebrides, West Highlands, Clyde, and North East regions. Demersal trawls are mostly affected in the West Highlands region, as well as Forth and Tay, Moray Firth, and North East regions.

There are other impacts that have not been quantified. If the displaced fishing effort moves to other locations, there may be additional fishing pressure outside of the sites and areas, although this may be on less sensitive habitats. Affected vessels may have to steam further to reach fishing grounds, and may have to fish on less productive grounds, fishing harder to maintain catches, resulting in potential changes to vessels cost and revenue profiles. There may be increased conflict between vessels and fleet segments.

In sites and areas where all demersal mobile gears have been excluded, this may provide an opportunity for static gears or hand divers to operate. This may result in additional landings for those operators. There is potential for this in 14 of the sites, and in the proposed PMF management areas.

5.2 Impacts by SMR where catches are taken

The proposed fisheries management measures have a cumulative impact on the value of landings from the fishing sector of £0.6 k to £1.4 million for Option 1, increasing to £9.7 million to £10.3 million for Option 2 (annual average, 2024 prices).

The regions most affected under Option 1 are West Highlands and Hebrides Shelf, followed by Outer Hebrides and Forth and Tay. Under Option 2, the region most affected is Moray Firth, followed by West Highlands and North East. These also tend to be the regions most affected in terms of landings compared to the value of landings from the region.

Under Option 1, the impacts on value of landings in the context of total value of landings from each region, are minor. In all cases, the impacts are up to 1% of total landings from the region, and the highest impact is in the North East region at 1.3%.

Under Option 2, the impacts are potentially very significant in certain regions. Almost two thirds of landings from Moray Firth region (59%) are affected, and one fifth of landings from the North East region (18%) are affected. Additionally, impacts in West Highlands (5% to 6%), Clyde (3%) and Forth & Tay (2%) are notable. Further site and area specific information can be found within the SEIA section 8.

5.3 Impacts by individual vessel

At the level of individual vessels, impacts are generally less than £10,000 landings value per year under Option 1 for all vessel sizes. Under Option 2, between £10,000 and £100,000 of landings value affects 41 under-12 metre vessels and 130 over-12 metre vessels. Larger impacts, of more than £100,000 of landings affected, are felt by 15 over-12 metre vessels and two under-12 metre vessels.

The majority of vessels have less than 1% of their total landings from Scottish waters affected under Option 1. Under-12 metre vessels are more significantly affected than over-12 metre vessels, with 87 vessels affected by 1% to 5% of their landings, and 61 vessels with more than 5% of their landings affected, including 13 vessels with over 25% of their landings affected. Under Option 2, a greater number of vessels have a high proportion of their total landings from Scottish waters affected; there are 74 under-12 metre vessels, and 44 over-12 metre vessels, with over 25% of their landings affected.

5.4 Impacts by landing port

The impacts on landing ports, by port district, fall mostly on the west coast and Outer Hebrides under Option 1. The port districts most affected are Stornoway (Outer Hebrides), Mallaig (West Highlands), Ullapool (West Highlands), Eyemouth (Forth and Tay) and Lochinver (West Highlands).

Under Option 2, the impacts fall predominantly on port districts in the Moray Firth and North East, namely Fraserburgh and Buckie, followed by Mallaig (West Highlands), Peterhead (North East), Stornoway (Outer Hebrides) and Campbeltown (Argyll).

The value of landings affected as a percentage of total landings to each port district is potentially low under Option 1, if displaced effort is able to move to other locations and take additional catches. If displaced effort cannot move to other locations, the port district of Mallaig has the highest relative impact, with 2% of total landings to the port district affected.

Under Option 2, the impact on landings to several port districts is very significant, with 51% of landings to Buckie affected, 10% to 12% of landings to Mallaig affected, and 7% of landings to Fraserburgh affected. There is limited potential for displaced effort to move to other locations under Option 2, making these impacts more likely to be realised. The port districts of Stornoway, Campbeltown and Eyemouth each have 2% of the total value of landings to the district affected.

The downstream supply chain and processing sector could be impacted in these regions, particularly where businesses rely on locally landed catches. This is likely to be the case in West Highlands, Outer Hebrides, and Moray Firth SMRs in particular.

5.5 Public Sector Costs

The estimated potential costs to the public sector at a national level over the assessment period are summarised in Table 5. These range from a present value over the assessment period of £2.9 million under Option 1, to £4.4 million under Option 2.

Public sector costs are related to the preparation of statutory instruments or fishing orders, and the potential need for increased resources at the UK Fisheries Monitoring Centre (UKFMC) and for additional site-based inspection activity.

The public sector costs for Option 1 and Option 2 are mostly influenced by assumptions of the level of increased staff resources in the UK Fisheries Monitoring Centre. A higher level of staff resources for Option 2 is assumed throughout the assessment period. This is not necessarily required as a result of the management measures proposed for Option 2, but this provides a range of potential costs.

There are a number of uncertainties surrounding the estimates of costs to the public sector, in particular, the level of costs for additional monitoring from the UK Fisheries Monitoring Centre and for additional site-based inspection activity. It is not clear whether costs for implementation of iVMS on under-12m vessels would fall on the public sector or on the vessels themselves and whether this is attributable to the introduction of fisheries management measures or if this is adopted as part of other policy streams.

Condition monitoring of sites or areas and associated features may be required, to determine whether the fisheries management measures are having the intended effect. For MPAs, these costs have been considered when sites were designated and are therefore not considered here. There may be a requirement for condition monitoring of PMFs in the proposed management areas, which has not been quantified here. These cost and impacts are discussed further in the SEIA section 7.

5.6 Cumulative Impacts

The impacts of the proposed measures have the potential to impact on the same fleet segments as recent interventions and future plans and projects, resulting in in-combination impacts.

• Phase One MPA and SAC measures
• Fisheries management measures in offshore MPAs
• Offshore renewable energy developments

The MPA socio-economic monitoring report in 2019^[13] identified a number of localised positive and negative impacts on coastal communities and industries, often due to a combination of factors, one of which was MPA fisheries management measures. Specific changes identified included:

• Decreases in landings of trawled Nephrops and dredged scallops from some ICES rectangles containing MPAs and increases in creel-caught Nephrops and hand-dived scallops.
• Displacement of fishing activity – there were catch reductions of 25%–30% for trawl vessels from affected ICES rectangles, with vessels found to compensate for this by fishing more heavily in rectangles without MPA designations (i.e. displacement of activity).

For most vessels, total landings remained the same or higher, although vessels that were particularly heavy users of the affected fishing grounds suffered a 12% reduction in landings, on average.

5.7 Phase One MPA and SAC Measures

The proposed fisheries management measures have the potential to impact on the same fleet segments in the same regions as the Phase 1 fisheries management measures. This is most likely to be a concern for demersal trawls and dredges in the following regions:

• Clyde (South Arran NCMPA in combination with Clyde Sea Sill NCMPA).
• Argyll (Loch Sunart to the Sound of Jura NCMPA in combination with proposed PMF management areas); and
• West Highlands (Wester Ross NCMPA in combination with Small Isles NCMPA and proposed PMF management areas).

The proposed fisheries management measures have the potential to exacerbate the already observed impacts in these regions, notably:

• a shift from trawled Nephrops and dredged scallops to creel-caught Nephrops and hand-dived scallops negatively impacting mobile demersal fleet segments and benefiting static gear and hand-dived fleet segments (and the employment within these fleet segments).
• reductions in landings for trawl and dredge vessels and increases in fishing intensity in areas outside of MPAs.
• reduction in supply to processors on the west coast, in particular during periods of poor weather due to reduced access to sheltered fishing grounds; and
• changes to fleet profile, either from a shift to larger vessels that are capable of fishing further offshore, or a shift to smaller vessels with lower operating costs, and some vessel owners may leave the fishery altogether.

5.8 Fisheries management measures in offshore MPAs

The Scottish Government has now introduced fisheries management measures in offshore MPAs, following a recent consultation on the proposals. Smaller vessels are less likely to be fishing in offshore regions, and therefore less likely to suffer in-combination impacts from the measures in offshore MPAs. However, 82%–88% of the impacts on landings value of the proposed fisheries management measures fall on over-12m vessels. There is potential for an in-combination impact of the proposed measures with the fisheries management measures in offshore MPAs for these vessels.

The majority of the impacts of the offshore MPA fisheries management measures are anticipated to fall on over-12m demersal trawl vessels. The main impacts are anticipated to fall on vessels fishing in Fladen, North Scotland Coast and East Scotland Coast regions (Clean and Safe Seas Evidence Group, CSSEG, regions).

5.9 Offshore renewable energy developments

Consents have been granted for a number of offshore windfarms. Several have completed construction and are operational, some are under construction, and others are still in the planning process. In addition, the Sectoral Marine Plan for Offshore Wind Energy (SMP-OWE)^[14] proposes 32 Option areas for potential development of 37 GW of offshore wind across five offshore energy regions and Test and Demonstration (T&D) projects with a maximum installed capacity of 1 GW.

The social and economic impact assessment^[15] for the Sectoral Marine Plan for Offshore Wind Energy (SMP-OWE) in 2025 indicates that the greatest impacts on fisheries are likely to be in the North East Sectoral Marine Plan (SMP) region (corresponding to Moray Firth, Orkney Islands and Fladen and Moray Firth Offshore regions) and Shetland SMP region (corresponding to Shetland Isles region), followed by the East SMP region (corresponding to Forth and Tay, and North East regions). The majority of impacts are likely to fall on over-12m midwater trawls and demersal trawls and seines. The assessment is currently being updated through the Iterative Plan Review process. Further information on in-combination impacts can be found in the SEIA section 8.6.

5.10 Limitations and uncertainties

There are considerable uncertainties concerning the estimate of potential impacts. These particularly relate to uncertainties concerning the actual value of landings at risk within each site or area and uncertainties concerning how much of this activity might be displaced (and to where) or removed from the system.

For under-12m vessels, reported ICES rectangle data are proportioned to c-squares based on activity from daily positions (one position reported per vessel per day) by species and gear type, which may over- or under-estimate activity in individual c-squares. The classification of gear types relies on the information reported in FISH1 forms and logbooks; some gears may be wrongly classified. This is a concern for all gear types, but particularly for set nets, which are known to be used by under-12m vessels in the Outer Hebrides, but which do not come through in the data.

For over-12m vessels, VMS pings occur at least every two hours and therefore do not provide a complete picture of fishing activity. However, by using data over a five-year period this limitation is minimised. The process of averaging daily logbook landings data across VMS positions at fishing speed may result in landings values being over- or under-estimated for individual pings. The classification of gear types relies on the information reported in logbooks; some gears may be wrongly classified.

The extent to which displacement of fishing activity will occur (rather than loss of the value of landings), and the nature of displacement (areas or gear types to which effort might be displaced) is uncertain. The knock-on impacts in terms of environmental impacts, impacts on vessels affected and impacts on other vessels, are also uncertain. For those gears that did not pass the displacement test, it was assumed that the value of landings would be lost. However, in practice it is likely that at least part of the effort would be displaced, and this could result in additional environmental impacts, impacts on the vessels displaced, and on other vessels. Conversely, for the higher end of the range for the estimates, it is assumed that all of the value of landings affected would be lost, but in reality, a level of displacement of activity is likely to occur.

As the value of future landings cannot be forecast, it is assumed that the value of landings is constant over time. The average value of landings per year estimated for each site or area is therefore assumed to be the same in each of the 20 years covered by the quantification of impacts. In reality, it is likely that the value of landings would fluctuate over time, depending on regulations, quotas, markets and environmental influences. Fishing patterns may have changed compared to the period used for the assessment (2016–2022 excluding 2020 and 2021). This means that where fishing effort has been recently displaced from other locations (e.g. due to management measures or other developments), this may not be fully captured. Changes to quota shares as a result of Brexit (from 1 January 2021) will only be partially reflected in the baseline data.

5.11 GVA and employment impacts

Impacts on direct GVA are calculated using fleet segment-specific multipliers from Seafish economic data. This is based on GVA as a proportion of fishing turnover. This gives a reasonable approximation of direct GVA that is specific to the fishing sector and to different vessel sizes and gear types, however, the impact on individual vessels may differ from the fleet segment averages.

Impacts on employment and on the downstream processing sector are considered in relation to the registered home port district and the landings port, respectively, of the affected vessels. This may overestimate or underestimate impacts on specific ports. The multipliers used to estimate the indirect GVA impacts and the direct plus indirect employment effect, relate to ‘Marine Fishing and Freshwater Fishing’ at national level and not the specific gear types or regions affected. Local and regional multipliers are not available. The national multipliers may, therefore, underestimate or overestimate the size and geographical distribution of impacts. Finally, application of the multipliers also assumes that a reduction in output is similar to a change in final demand and that there is no rise in the price of fish to offset the reductions in the value of landings.

5.12 Ecosystem services impacts

For the range of sites, areas and features covered, the assessment has considered groups of ecosystem services (provisioning, regulating, supporting and cultural) across regions and sites or area type. For the majority of NCMPAs, SACs, SPAs, and all proposed PMF management areas, proposed fisheries management measures protect features that support overall ecosystem health. Therefore, their protection is expected to maintain and potentially increase many ecosystem services. Examples of notable ecosystem service benefits include maintaining and potentially enhancing:

• Provisioning services: healthy stocks of commercial fish species;
• Regulating services: sequestration of carbon by some biogenic habitats, and storage of carbon in habitats and sediments;
• Supporting services: healthy marine food webs and ecosystems; and
• Cultural services: the role of healthy ecosystems and distinctive species in recreation and the visitor economy.

The Scottish marine environment supports extensive recreation and tourism activity. Office for National Statistics (ONS) data^[16] identify £2.53 billion of expenditure in Scotland each year that is motivated by ecosystems. Of that, £729 million of expenditure per year is attributed to marine habitats, and a further £927 million to coastal habitats (2019 prices). The marine environment and biodiversity are one important component of what attracts this visitor expenditure. The protection and enhancement of marine ecosystems should help to maintain, and potentially increase, spending. However, this effect depends on many factors in addition to marine ecosystems, and it is difficult to quantify whether any increase in visitor activity at one location has occurred due to a genuine increase in activity, or a displacement of activity from other locations. Therefore, valuation estimates from specific locations cannot reliably be scaled up to marine region or national level.

The proposed fisheries management options would provide significant protection to a wide range of marine features and therefore protect and enhance their role in food webs. This could result in improved ecosystem health, and provide benefits by supporting commercial fish stocks, and for regulating services (e.g. carbon storage in seabed sediments) and supporting services. While available information suggests there will be positive impacts on many ecosystem services, evidence on the size and value of changes is generally not available, resulting in a largely qualitative analysis.

5.13 Cumulative benefits

The estimated impacts on the commercial fisheries sector shown above assume fishers will have to displace or reduce/lose some amount of their catch, which may have further impacts on their income and livelihoods, which may have a knock on effect to consumers. In addition, changes to fishing grounds, gear types, and other adaptations or diversifications borne as a result of the proposed fisheries management measures can lead to additional impacts on the fisheries and processing sectors. Note that displacement of fishing activities can lead to increased pressure on the marine environment in surrounding areas.

These impacts on commercial fisheries will be offset by the long-term protection of the fishing industry that MPAs will provide. These benefits are both for the marine environment itself and for the fishing sector reliant on healthy and abundant fish stocks. There are a number of studies that show the economic benefits of well-managed fish stocks, and further benefits from how MPAs support managing the effects of climate change. Research shows that protecting fish species through MPAs can increase the yield and revenues from fishing activities, and lead to better protection of fishing gear by reducing gear conflict.^[17]

The potential impacts to the marine environment are likely to include:

• benefits to marine features protected within sites and proposed PMF management areas;
• changes in the level of ecosystem services as a result of increased protection of feature and spillover benefits; greater certainty of long-term protection;
• costs of degradation of marine features when fishing activity is displaced to locations outside of designated sites and proposed PMF management areas.

The proposed fisheries management measures are designed to protect a wide range of marine features (species, habitats and other features) from current and/or potential future pressures. The baseline condition of the different features is not always known, and their response to any removal of pressures is also uncertain. Removal of pressures is expected to halt declines, and enable recovery of features in unfavourable condition, but the extent and speed of these changes is uncertain, not always possible to quantify and will vary from feature to feature.

Marine tourism and recreation, and other cultural ecosystem services, can be very significant in inshore locations. These services are assessed for individual sites and management areas, but significant potential network effects should be noted, including in relation to distinctive mobile fauna (e.g. seabirds, cetaceans) which may use several protected areas or management areas in offshore and inshore waters. When in inshore waters, these species can attract significant recreation and tourism activity.

The sites and areas could contribute to an increase in abundance of fish species, which as well as supporting commercial fisheries (discussed above) are also targeted by recreational anglers (from shore or boats, usually in inshore areas). They could therefore help maintain, and potentially enhance, the value of recreational sea angling in Scotland.

The ecosystem service benefits from the proposed fisheries management options were not quantified at a site or area level because of a lack of site- or area-specific data. However, they are considered relevant to the sites and areas as a network. This results in benefits from the health of marine ecosystems, which the fisheries management measures would contribute to. The impact of individual sites or areas cannot be distinguished within the overall potential benefit. Some ecosystem services (e.g. genetic resources; cultural benefits stemming from spirituality, health and wellbeing, and creativity and art; and tourism and recreation) are potentially significantly more valuable at a network level than an individual site or area level. More information on cumulative benefits can be found in the SEIA section 8.4.

5.14 Scottish firms’ international competitiveness

It is not envisaged that the introduction of the proposed fisheries management measures will result in an impact on businesses’ ability to compete internationally.

Any feedback on this section will be considered after completion of the consultation.

5.15 Small business impacts

The sector most likely to be directly impacted by proposed fisheries management measures is the commercial fishing industry. Both proposed management options would place spatial and gear-specific restrictions across the specified protected sites and proposed management areas. However, given that as an activity more is likely to be displaced instead of lost, particularly under Option 1, these impacts are expected to be minimal^[18] for the sector as a whole. The distribution of additional costs and benefits should be uniform for all suppliers, however, this means that as a percentage, it’s likely that small business will incur a slightly larger impact.

The Scottish Sea Fisheries Statistics 2023 (SG 2024; corrected Mar 2025) shows that there were 1,658 active Scottish fishing vessels under-12 metres in length in 2023. Under-12 metre vessels accounted for 83% of the total Scottish fishing fleet vessels in 2023. Smaller vessels are more likely to be classed as small businesses, and any impacts, costs, or benefits assessed in Section 3 in this BRIA, for under-12 metre vessels in particular can be seen as potential impacts on small businesses. Note that the size of the crew may not correspond to the size of the (regular) annual employee headcount, and that standard small and medium-sized enterprises (SME) definitions may not fully reflect this sector.

The number of active licensed vessels and vessels’ crew numbers will also change year-on-year, with more recent management data showing that there were 1,818 licenced Scottish fishing vessels as of March 2025. Of these vessels, 1,366 were under 10 metres – which are more likely to be classed as small businesses than larger vessels.

This section already notes the limitations around using small vessels as an (imperfect) proxy for small businesses. For further context, according to Businesses in Scotland: 2024, 99.5% of registered businesses in Division 03: Fishing and Aquaculture had fewer than 50 employees. While this classification covers more than just the inshore fishing fleet, it does suggest the majority of affected small vessels are likely part of small businesses.

More granular detail on the assessment methodology can be found in Section 3 of the SEIA. More granular detail on costs, impacts and benefits can be found in sections 4 to 8 of the SEIA as well as the annexes that accompany that assessment.

5.16 Investment

It is unlikely that the proposal will substantially impact domestic and foreign investment activity in Scotland at a national level. However, overall the proposal is likely to have competing effects. The aim of the fisheries management measures is to enable conservation objectives to be achieved. If this is achieved, it’s likely that there could be additional investment within the marine tourism industry. This could include the potential for increased foreign investment into Scotland by making it a more attractive place for investors and developers interested in marine tourism, conservation and/or restoration activities.

On the other hand, if the fishing industry is adversely affected by the management measures, it could disincentivise investment in certain localities and for the vessels that operate there. It is unlikely that investment activity in the fishing industry will be impacted over the long-term given that activity is more likely to be displaced instead of lost, particularly under Option 1.

The proposal incorporates the following characteristics from the First Minister’s Investor Panel to make Scotland a globally competitive investment destination, namely:

• there are clearly articulated, credible, long-term policies encompassing net-zero targets and sector priorities.

5.17 Workforce and Fair Work

The proposed fisheries management measures are not expected to directly affect Fair Work First principles, however there is potential for indirect impacts. While overall employment effects are relatively small (see Table 3), displacement of fishing effort could increase operational costs for some businesses. For example, vessels may need to travel further to access alternative fishing grounds, leading to higher fuel costs, longer travel times and reduced productivity. This could potentially affect some businesses' ability to pay the Real Living Wage or maintain flexible working arrangements, however such impacts have not been quantified.

5.18 Climate change/Circular Economy

It is not envisaged that the introduction of the proposed fisheries management measures will result in an impact on businesses’ ability to contribute to climate and circular economy targets or contribute to the reduction, reuse, or recycling of resources by businesses.

5.19 Competition Assessment

In addition to looking at the impact on individual firms, it is important to consider the impact that a regulation or policy might have on competition between firms. The overall aim of the competition assessment is to find a policy approach which encourages competition within the market, subject to achieving the wider policy objectives.

The sector most likely to be directly impacted by proposed fisheries management measures is the commercial fishing industry. Both proposed management options would place spatial and gear-specific restrictions across the specified protected sites and proposed management areas. The introduction of fisheries management measures may lead to competitive disadvantage for commercial fisheries actively operating within a given spatial area, potentially restricting the output capacity of the sector. However, given that as an activity it is more likely to be displaced instead of lost, these impacts are likely to be negligible. It is not expected that the distribution of additional costs will be skewed towards smaller entrants relative to larger existing suppliers. All firms will be equally affected by the impacts of the management measures for any specific closures and gear type.

Will the measure directly or indirectly limit the number or range of suppliers?

No. It is unlikely that the introduction of the fisheries management measures outlined will limit the number or range of suppliers at a Scottish level. However there may be an impact on individual suppliers.

Will the measure limit the ability of suppliers to compete?

Limited/No Impact. The introduction of fisheries management measures could affect the spatial location of commercial fisheries activity and may restrict the output capacity of this sector. However, restrictions on fishing locations may well be negated by displacement i.e. vessels fishing elsewhere. It is not expected that the distribution of additional costs will be skewed towards smaller entrants relative to larger existing suppliers.

Will the measure limit suppliers' incentives to compete vigorously?

No. The introduction of fisheries management measures is not expected to reduce suppliers’ incentives to compete vigorously.

Will the measure affect consumers’ ability to engage with the market and make choices that align with their preferences?

No. There will be no discernible impact on the average consumer.

Will the measure affect suppliers’ ability and/or incentive to introduce new technologies, products or business models?

No. It is highly unlikely that the measure will affect suppliers’ ability and / or incentive to introduce new technologies, products or business models.

5.20 Consumer Duty

Potential impacts on consumers have been carefully considered at a strategic level. Due to restrictions on fisheries proposed under this policy, there is potential for a reduction in landings, but it is not anticipated this will impact the availability of goods for an average consumer.

The lower end of the range for Option 1 is estimated to have minor impacts on fisheries, with Option 2 having potentially significant impacts. This could lead to upward pressure on prices for consumers. However, it is not possible to quantify this potential effect. The measures are estimated to reduce the average annual value of output landed by the commercial fisheries sector by between £0.6 million - £1.4 million (Option 1) and £9.7 million - £10.3 million (Option 2). Further information can be found in section 3 of this BRIA and section 4 of the SEIA.

Due to the potential loss of landings, there is the potential to indirectly reduce the output of the sector. The reduction in output and GVA has potential to have knock-on impacts on the upstream supply chain that the catching sector buys from (e.g. gear and equipment suppliers, fuel, boat maintenance and repair services, insurance and financial services). The reduction in landings can also affect the downstream supply chain, involving processing and onward distribution and supply. Any relevant supply chain impacts are expected to arise primarily in relation to small businesses within these supply chains, consistent with the definition of consumers under the Consumer Scotland Act 2020.