Hidden at sea: why UK seafood must not come at the cost of migrant fishers’ rights

The UK seafood industry depends heavily on migrant labour. Yet, shamefully, the workers catching the fish and shellfish that ends up on supermarket shelves are excluded from basic UK employment protections. 

A long‑standing immigration loophole – the misuse of seafarers’ transit stamps – has created the conditions for serious exploitation. And while government reform is essential, businesses in the seafood supply chain also have an immediate role to play.

For ETI members and companies committed to responsible sourcing, the situation in UK fishing is a clear test of how human rights due diligence must extend all the way to the deck of fishing vessels.

The Employment Rights Act will be setting up the Fair Work Agency, a once in a generation opportunity to ensure that labour is regulated in the fishing sector and that the risks of modern slavery are reduced for what is widely considered to be a high-risk sector. 

The problem: a loophole driving exploitation

Many migrant fishers working on UK-flagged vessels enter the country on a transit permission known as the Code 7 Stamp, designed for seafarers passing through the UK to join ships travelling onward. In practice, it is widely used to crew fishing vessels fishing outside UK territorial waters (which extend 12 nautical miles – roughly 14 miles - from shore), leaving workers outside core UK labour protections, despite working for UK companies on UK flagged vessels. 

As a result of ITF’s sustained engagement with the Home Office, skilled worker visas (with UK employment protection and minimum wage compliance contracts) were introduced for those working inside UK territorial waters. But this only affects a minority of migrant fishers in the UK. 

As a result, people doing the same job as UK or EU crew can be:

• Paid far below the UK minimum wage – without being paid a share of the catch, as UK or EU crew are.
• Working extreme hours with little or no guaranteed rest, with work or rest hours not recorded despite the ratified Work in Fishing Convention requiring 10 hours rest in every 24 hours worked, or 77 hours in seven days.
• Living and working on vessels without access to medical care or support, unless it is the result of an emergency.
• Unable to report abuse for fear of immigration enforcement, due to a lack of immigration status for Code 7 workers. 

Independent research documents the pay disparity, debt bondage and overwork faced by these fishers, as well as commonplace harassment and physical violence.

Labour market enforcement in fishing is fragmented, inspections are limited and the result is a system where exploitation becomes systemic but remains largely unseen.

Why this matters for companies and the seafood supply chain

Seafood buyers, retailers, brands and food service companies are directly connected to this labour through their sourcing. Even where products are certified or marketed as ‘sustainable’, labour conditions on vessels can remain largely invisible.

Waiting for legislation is not enough – and does not match up to what is expected of any truly responsible business. Under international standards on business and human rights, companies have a clear responsibility to identify, prevent and address labour exploitation in their supply chains, including at sea.

Before policy reform takes full effect, companies must take action on their supply chains. By acting collectively, buyers can help shift incentives away from the lowest cost, highest risk labour models and towards fairer employment practices.

They can and should:

1. Strengthen human rights due diligence
   Map supply chains down to vessel level and assess risks linked to migrant labour, recruitment practices and pay systems.
2. Set clear labour expectations for suppliers
   Require that all crew on supplying vessels are paid at least the equivalent of the UK minimum wage for hours worked, have sufficient rest, and are protected from recruitment fees and debt.
3. Support independent and worker-centred monitoring
   Go beyond paper audits by working with trade unions and labour inspectors.
4. Use commercial leverage to ensure UK fishing sector recruitment agencies are licensed and regulated 
   Clearly signal that exploitative crewing models are not acceptable and that long-term sourcing relationships depend on improving labour standards and following the recently adopted International Labour Organization guidelines.‑term sourcing relationships depend on improving labour standards

The policy changes needed

Business action is vital, but it cannot substitute legal protection. Lasting change requires government-led reform so that migrant fishers are fully covered by UK employment law.

Key reforms include:

• Ending misuse of the transit (Code 7) route and ensuring all migrant fishers have an immigration pathway that gives them full labour rights.
• Applying the UK National Minimum Wage and working time protections to all crew on UK-flagged vessels
• Creating safe reporting routes and a bridging visa so exploited workers can leave abusive employers and seek justice without risking immediate removal.
• Strengthening labour market enforcement at sea, including a clear role and mandate for the Fair Work Agency to regulate this fishing industry (regardless of whether the fishing happens in UK territorial waters or not).
• Regulating recruitment agencies to prevent illegal fees and debt bondage.

These steps would not only protect workers, but they would also create a level playing field for responsible vessel owners and seafood businesses.

A moment for collective leadership

The UK fishing sector is at a crossroads. Continuing with a system that depends on loopholes and a high-risk labour model exposes workers to serious harm and companies to growing legal and reputational risk. Choosing a different path, one grounded in decent work and transparent supply chains, is both possible and necessary.

For companies, this is an opportunity to demonstrate how collaborative action between business, trade unions and civil society can tackle some of the hardest labour rights challenges, even in complex and remote sectors like fishing. Indeed, ETI’s dynamic and robust tripartite structure offers a unique platform to ensure the protection of migrant fishers in the UK seafood industry.

Now is the moment for responsible businesses to step up. Robust human rights due diligence must extend to the deck of fishing vessels, identifying risks, engaging directly with workers and their representatives, and using collective leverage to secure decent work at sea. Acting together, ETI members can help shift the sector towards fair and transparent employment practices.

No one should be catching fish for the UK market without the protection of basic employment rights. Ensuring that becomes the norm will require both policy reform and decisive action from the companies that buy and sell seafood every day.

*The International Transport Workers' Federation (ITF) is a trade union member of the Ethical Trading Initiative.