Unaddressed Concerns From Earlier Engagement
The signatories also highlighted that despite a Multi-AC workshop held with the Commission in February 2025, key questions raised by stakeholders remain unanswered. Following that meeting, the NWWAC, PelAC and NSAC jointly submitted detailed advice on 23 May 2025 — but as of November, the Commission has yet to provide a formal reply.
The ACs stated that “little evidence” exists that stakeholder contributions have influenced either the Delegated or Implementing Acts, suggesting that the Commission’s process has failed to reflect real-world experience from those responsible for compliance and enforcement at sea.
Technical And Practical Gaps In Regulation
Specific concerns raised include the weighing and sampling of landings, the digitisation of transport documentation, and the rollout of Remote Electronic Monitoring (REM) and engine power verification. The ACs warned that without comprehensive cost and feasibility assessments, these new requirements could result in uneven implementation across EU sea basins.
The councils emphasised that “insufficient suitable conditions to enable meaningful engagement increases the risk of regulations being introduced that lack specific input from operators and other stakeholders,” potentially leading to inefficient or impractical enforcement.
Call For A More Bottom-Up Approach
While acknowledging the importance of robust control systems to protect fish stocks and ensure sustainability, the Advisory Councils urged both the Commission and Member States to adopt a more inclusive, bottom-up approach.
They propose establishing regular regional or sectoral stakeholder workshops, involving control expert groups from Member States and active engagement from the Commission. Such a process, they argue, would ensure that measures are “cost- and resource-efficient, adapted to practical implementation at sea and in ports, and responsive to regional and sector-specific conditions.”
The letter concludes that the success of the Control Regulation depends not only on strong enforcement, but also on genuine collaboration with those most affected by its rules. As the ACs collectively warned, “effective stakeholder input is essential to make such controls workable and proportionate, in order to maximise compliance and trust with the sector.”




