A New Seafood “Duties” Framework—What It Gets Right, and Where We Need to Pause

Seafood Ninja

March 22, 2026

A new document was introduced by the Fisheries Governance Project during SENA this year: “Defining Corporate Duties in Seafood Supply Chains to Prevent IUU Fishing & Labor Rights Abuse on Industrial Fishing Vessels.”

It brings together environmental and labor expectations into a consolidated framework—something our industry could find helpful. There is real value in this document, but there are also some important considerations around how this document may be interpreted and used in practice.

Key Considerations

1. When “guidance” starts reading like a standard

The document uses language such as “duties” and “must,” which makes it read less like guidance and more like a defined standard of care.

That distinction matters.

In today’s landscape, documents like this don’t just guide—they can shape expectations from:

NGOs
Customers
And increasingly, legal actors

There is a real risk that this could be used to argue what companies “should have known” or implemented.

This concern is heightened by the involvement of organizations currently engaged in litigation in the seafood sector—such as Corporate Accountability Lab (CAL) in the case against Aqua Star—which may impact how the document is perceived and the level of trust needed for industry engagement.

Blurring the line between guidance and enforceable expectations

While positioned as a framework, the level of specificity—particularly around:

contractual requirements
co-governance models
outcome-based expectations

—makes it difficult to distinguish what is aspirational versus what may be interpreted as required.

That creates uncertainty and potential exposure for companies trying to navigate evolving expectations responsibly.

Not all fisheries are equal

Seafood supply chains are not uniform.

They vary widely across:

geographies
governance systems
infrastructure
access to technology and resources

Some recommendations in the document—such as continuous AIS/VMS coverage, guaranteed Wi-Fi at sea, strict limits on time at sea, and full vessel disclosure—may not be feasible across all contexts today.

Without acknowledging these differences, there is a risk of setting expectations that are not achievable in practice, which can discourage engagement rather than drive improvement.

The “how” is missing

The document clearly outlines what companies should do. But there is less clarity on:

how to implement these expectations
what resources are required
who is responsible for funding and supporting these changes

Many companies—particularly suppliers—do not have access to the same level of funding or technical support as NGOs or multi-stakeholder initiatives.

Without practical pathways, even well-intentioned frameworks can fall short in driving real change.

Transition from existing systems

The document raises important critiques of current approaches, such as social audits. However, it does not clearly outline how companies are expected to transition from existing systems to the proposed models without creating disruption or duplicative burdens.

Opportunities

Despite these challenges, this document can still play an important role—if positioned thoughtfully.

It can:

Provide a consolidated view of NGO and labor expectations, helping reduce fragmentation
Serve as a benchmarking tool for companies to assess current practices and identify gaps
Support clearer definitions of “responsible” or “ethical” sourcing
Create space for proactive industry engagement, rather than reactive compliance

A Path Forward