As the European Union positions itself as a global leader on ocean governance during the EU Ocean Days in Brussels and publishes its new Maritime Industrial Strategy, civil society organisations working on ocean environmental protection, labour rights, transparency, and maritime security warn that a major governance gap remains unaddressed: the widespread use of flags of convenience (FoCs).

The call follows the publication of a recent European Commission study on the use of open registries as flags of convenience, which confirms that this system allows regulatory evasion and undermines the EU’s environmental, social, fiscal and security objectives. Yet, despite a week of high-level discussions on Europe’s maritime future and the release of the EU’s strategy to strengthen the competitiveness of the maritime sector, the issue of flags of convenience and the study’s findings have so far received little political attention and no clear follow-up.

The study highlights how FoCs rely on opaque ownership structures, weak oversight, and poor enforcement of international rules, enabling harmful practices that directly contradict EU standards, global commitments, and put responsible flag States at an unfair disadvantage. Serious concerns related to how FoCs facilitate pollution and illegal dumping, the exploitation of seafarers and shipbreaking workers, and contribute to tax avoidance and illegal fishing, are raised in the report.

The co-signing organisations stress that it is not acceptable for the EU shipping and fishing sectors to continue operating under structures that directly undermine EU environmental, fisheries, fiscal and safety policies, while at the same time benefiting from access to EU markets and resources.

Oceana: “Flags of convenience are a major enabler of illegal fishing worldwide. They allow operators to hide their identity, evade sanctions and continue fishing illegally under new flags. The European Commission’s study confirms what civil society has long demanded: without full transparency on who owns, controls and profits from fishing vessels, the EU cannot credibly combat illegal fishing and protect the marine environment.”

WWF European Policy Office: “By its very nature, illegal fishing is hard to detect and monitor. Flags of convenience make that job exponentially harder, harming the fishers who follow the rules but suffer when fish stocks run low. As one of the world’s top seafood importers, the EU must lead by example and maintain a zero-tolerance approach to illegal fishing, including flags of convenience.”

Opportunity Green: "International shipping benefits from multiple gaps in international governance, allowing it to have large climate impacts without even paying the standard taxes paid by most corporations. The EU needs to look at the entire shipping industry and ensure that, instead of companies earning billions without paying taxes, they are subject to the same standard regulations as all other industries. The flag of convenience regime is an unnecessary exemption from usual rules given to a polluting industry."

NGO Shipbreaking Platform: “The study’s findings expose severe governance failures at the end of a ship’s life. Flags such as St Kitts and Nevis, Comoros, Palau and Tuvalu are widely used for last voyages to the shipbreaking beaches in South Asia, to circumvent EU regulations on the scrapping of toxic ships. The Commission has already recognised flag-swapping as the key obstacle to implementing the Ship Recycling Regulation. Yet, no further action has been taken to fix this issue and hold shipowners accountable.”

The Commission’s own findings make clear that flags of convenience are not an enforcement anomaly but a structural governance failure driven by a prioritisation of profits, which results in reduced effectiveness of regulatory frameworks and lenient oversight.

In light of the study’s evidence, the co-signing organisations call on the European Commission to:

- Close the data gap that allows the proliferation of flags of convenience by requiring comprehensive and reliable data on vessel beneficial ownership, flag history, and compliance records across all maritime sectors, including mandatory disclosure for foreign-flagged vessels owned or controlled by EU interests;

- Collaborate with EU Member States to systematically collect and regularly share relevant vessel information with international databases and monitoring platforms, including the FAO Global Record of Fishing Vessels, Refrigerated Transport Vessels and Supply Vessels and relevant Regional Fisheries Management Organisation (RFMO) vessel registries to curb illegal fishing;

- Integrate decisive measures across EU maritime and ocean governance frameworks, including the upcoming EU Ocean Act, fisheries policy, tax governance, maritime security and ship recycling rules, to discourage and prevent the use of flags of convenience.

The co-signing organisations urge the EU to act without delay to discourage, disincentivise or dismantle those structures that enable such practices and to secure the long-term sustainability, integrity, and credibility of EU maritime governance.

Benedetta Mantoan, Policy Manager, NGO Shipbreaking Platform

Irene Campmany Canes, Senior Communications Officer, Oceana in Europe

Amélie Giardini, Global Lead for Transparency, the Environmental Justice Foundation (EJF)

Aoife O’Leary, CEO, Opportunity Green

Jacob Armstrong, Policy Manager, WWF European Policy Office