EU Study Exposes Risks from Open Registers and FOCs

A New EU Study Warns of Alarming Gaps in Global Fisheries Oversight

A major European Commission study has exposed how open registers and flags of convenience continue to undermine the fight against Illegal, Unreported and Unregulated (IUU) fishing, enabling opaque ownership, regulatory evasion and widespread fisheries abuses.

The report presents one of the most comprehensive examinations to date of how global vessel registration systems are being exploited to hide beneficial ownership, circumvent conservation rules and mask criminality at sea.

The study concludes that the modern registry landscape has evolved into what it calls a “global market of demand and supply of ship registers,” driven by commercial incentives rather than governance responsibility. It highlights how open registers operated by private firms offer minimal oversight, fast paperwork and layers of anonymity that allow vessel owners to obscure their identities, evade accountability and continue operating despite repeated violations.

This is a direct threat to the integrity of global fisheries management and to coastal communities reliant on healthy marine ecosystems.

Open Registers and the Erosion of Accountability

In its analysis of the structural weaknesses embedded in open registries, the study explains that many of these systems are specifically designed to attract foreign shipowners by lowering barriers and relaxing scrutiny. It notes that “shipowners choose a registration service and a jurisdiction that will minimise costs and risks,” with decisions often guided by the ability to avoid enforcement and operate beyond the reach of stringent national regulations.

A central concern lies in the fact that many open registers are run by private companies on behalf of small or economically vulnerable States. These companies market rapid, low‑cost registration and 24/7 document issuance to vessel operators, providing what the study characterises as a “privacy shield” that obscures ownership, management structures and operational conduct.

For vessels involved in IUU fishing, this anonymity is a valuable asset. Through rapid “flag hopping”, operators are able to re‑register vessels in new jurisdictions whenever their activities attract scrutiny, sanctions or enforcement attention. The study documents how this practice allows illegal operators to sever their compliance histories and re‑enter global markets unchallenged.

Fisheries in the Fog: The DWF Problem

The study devotes significant focus to the global distant‑water fishing (DWF) fleet, which has become one of the fastest‑expanding and least regulated maritime sectors in the world. These vessels often operate thousands of miles from their home ports, far beyond effective oversight. As the report notes, they “often operate on the high seas, where the flag State’s capacity to exercise effective control is limited.”

This is the environment in which open registers thrive. The combination of weak jurisdictional oversight, active concealment of ownership and the physical remoteness of DWF fleets creates an ideal climate for illegal activities. The study links open‑register fishing vessels to a wide array of offences, including misreporting catch, illegal transhipment, forced labour, unauthorised fishing in restricted zones and the dumping of processing waste.

The report highlights that global fishing effort has increased dramatically. Fishing hours jumped more than six‑fold between 2012 and 2019, indicating not only an intensification of activities but a growing strain on monitoring systems. At the same time, although the number of vessels worldwide has fallen sharply, the average size and fishing capacity of the remaining fleet has risen, amplifying the potential for ecological damage.

Opaque Ownership and Concealed Identities

The core of the study’s concern revolves around ownership secrecy. Opaque corporate structures, shell companies, nominee directors and lax disclosure regimes allow vessel owners to hide behind layers of legality while continuing harmful or illegal practices at sea.

The report emphasises that open registers routinely fail to require adequate information on beneficial ownership, noting widespread inconsistencies in documentation, variable enforcement capacity, and in some cases, deliberate gaps in national law. The result is a global system in which the true operator of a vessel is frequently invisible to authorities, fishery managers and coastal States.

As the study explains, cases of IUU fishing often involve vessels that move repeatedly from one permissive registry to another. Without transparency on beneficial ownership, even identifying the responsible party becomes difficult, making sanctions, prosecutions and monitoring nearly impossible.

End‑of‑Life Re‑Flagging: The Disappearing Act

One of the study’s most revealing insights is its analysis of “last voyage” re‑flagging—where a vessel changes to a permissive flag just before demolition. The practice is widespread in the cargo and tanker sectors, but the study notes that many fishing vessels also employ this strategy to evade scrutiny as their regulatory histories come to an end.

By shifting to a laissez‑faire flag State before dismantling, operators obscure their identities and escape accountability for unpaid wages, environmental violations or IUU infringements. Open registers such as Comoros, Palau, Panama and St Kitts and Nevis dominate this end‑of‑life market, absorbing vessels with the most problematic compliance records.

For fisheries management, this practice wipes critical data from the system and undermines the traceability essential for understanding fleet behaviour and prosecuting long‑term offenders.

A Safety and Labour Crisis Behind the Flags

The study provides EU Port State Control data showing that open‑register vessels record significantly higher safety and labour deficiencies than vessels flying national flags with rigorous oversight. In some cases, the results are extreme. For example, Cameroon‑flagged vessels were found to have deficiencies in 80% of EU port calls. Comoros and Palau also recorded high levels.

These findings extend into the fishing sector, where forced labour, abusive working conditions, unpaid wages and hazardous environments routinely accompany IUU operations. The study connects these patterns with the lack of flag State enforcement, describing a global system where exploitation flourishes under regulatory blind spots.

Shadow Fleet Connections and Illicit Trade

Although primarily focused on fishing and general maritime governance, the study also examines how open registers are used in sanctions evasion, oil smuggling and illicit trade. It identifies a growing “shadow fleet” comprising “grey” and “dark” vessels that operate covertly, disable tracking systems and conceal cargo origins.

These same concealment tactics, networks and registration practices show strong overlap with those used by illegal fishing operators. The study outlines how vessels involved in sanctions evasion often also engage in illicit fisheries activities, taking advantage of the same opacity and the same permissive flag States.

Case Studies: Five Flags at the Heart of the Problem

The Commission’s study includes case studies of Comoros, Liberia, the Marshall Islands, Panama and Vanuatu—five open registers heavily implicated in compliance failures, IUU fishing links and opacity.

Comoros is highlighted for extensive last‑voyage re‑flagging and a concentration of older, high‑risk vessels.
Liberia and the Marshall Islands, despite strong commercial presence, show enforcement and oversight gaps.
Panama, the world’s largest register, remains deeply embedded in fisheries governance issues.
Vanuatu carries a disproportionately large number of fishing vessels relative to its national capacity.

Across these cases, the report identifies recurring themes: weak legislation, insufficient enforcement, archaic or absent beneficial ownership requirements, and heavy reliance on foreign private operators.