Policy Brief 147, 24 October 2025
Reeling Towards Termination: Assessing the WTO Agreement on Fisheries Subsidies and the Future of Fisheries Disciplines
By Vahini Naidu
The WTO Agreement on Fisheries Subsidies (AFS, “Fish 1”) entered into force on 15 September 2025, introducing new disciplines on subsidies linked to illegal, unreported and unregulated fishing, overfished stocks, and certain high seas activities. While celebrated as a landmark achievement, the Agreement is partial in scope, omitting the broader category of capacity-enhancing subsidies that drive overcapacity and fish stock depletion. Its obligations rely on national determinations and extensive notifications that may prove burdensome for developing Members while allowing major subsidisers to retain flexibility. The unprecedented termination clause in Article 12 ties the Agreement’s survival to the adoption of additional “comprehensive disciplines,” underscoring both the fragility of the current outcome and the need for continued negotiations. The experience of Fish 1 reveals significant lessons for the proposed WTO reform, including the importance of reviewable and time-bound rules, the risks of imbalanced sustainability provisions, and the institutional weaknesses of restricted negotiating processes.