Standards to Inform an Ecosystem Approach to Deep-sea Bottom Fisheries Management in the High Seas: Examples from the South Pacific Ocean

Introduction

Until the early-to-mid 2000s, deep-sea fisheries across the South Pacific Ocean were mainly regulated by the domestic provisions imposed on fishing operators by flag States. In 2006, Australia, Chile and New Zealand initiated consultations among relevant States to address key gaps in the international conservation and management of fisheries resources, as well as the protection of the broader marine environment in the South Pacific high seas. Shortly after, the United Nations General Assembly (UNGA) adopted Resolution 61/105, which called upon the Regional Fisheries Management Organisation (RFMO) bodies to:

“83 (a) To assess, on the basis of the best available scientific information, whether individual bottom fishing activities would have significant adverse impacts on vulnerable marine ecosystems, and to ensure that if it is assessed that these activities would have significant adverse impacts, they are managed to prevent such impacts, or not authorized to proceed;”

Key elements of Resolution 61/105 included undertaking bottom fishing impact assessments to determine whether bottom fishing would risk exposing vulnerable marine ecosystems (VMEs) to significant adverse impacts (SAIs), identifying VME locations, establishing move-on rules and protocols, ensuring the sustainable management of deep-sea fish stocks, and establishing effective monitoring, control and surveillance of fishing operations and their environmental impacts.

In 2009, the FAO published the International Guidelines for the Management of Deep-Sea Fisheries in the High Seas (FAO, 2009), hereafter referred to as the Deep-Sea Fisheries Guidelines. These guidelines provided recommendations on governance and management frameworks of deep-sea fisheries aimed at ensuring long-term conservation and sustainable use of marine living resources in the deep-sea, while preventing SAIs on VMEs. These guidelines provided specific advice on the characteristics which should be used to identify VMEs, and a definition of SAIs (both of which were not provided by previous UNGA Resolution 61/105). The Deep-Sea Fisheries Guidelines have been a transformational document widely used by Regional Fisheries Management Organisations (RFMOs) engaging with demersal fisheries to the current day. Shortly after, in 2011, the UNGA adopted Resolution 66/68, reaffirming earlier Resolutions on sustainable fisheries and calling on States and RFMOs to apply a precautionary approach and to implement the Deep-Sea Fisheries Guidelines.

The Deep-Sea Fisheries Guidelines and relevant UNGA Resolutions informed the development of interim measures during international consultations on the establishment of the South Pacific Regional Fisheries Management Organisation (SPRFMO). These measures included early drafts of the Bottom Fishery Impact Assessment Standard (BFIAS) and the Standards for the Collection, Reporting, Verification and exchange of Data (e.g., SPRFMO, 2009b), hereafter referred to as Data Standards. The initial BFIAS developed for SPRFMO aimed to establish a minimum standard for assessing the potential impacts of proposed bottom fishing activities on VMEs and deep-sea fish stocks. Complementing this, the Data Standards set out requirements for Member States to submit fishing effort and catch data, including the mandatory reporting of accidental catches of any sensitive benthic species, particularly vulnerable or habitat-forming species such as sponges, sea-fans or corals. To the present day, there is no universal benthic impact assessment standard being followed across international resource management and conservation bodies (including RFMOs), but SPRFMO and the Commission for the Conservation of Antarctic Marine Living Resources (CCAMLR) (Sharp et al, 2009) were among the first such bodies to develop their own benthic impact assessment standards (DOSI, 2022; Kaikkonen et al., 2024).

SPRFMO was officially established in 2012. Australia and New Zealand were the only Members engaging in established bottom fisheries at that time. Based on early international agreements, UNGA Resolution 61/105 and the Deep-Sea Fisheries Guidelines, these two Members drove the implementation of the management arrangements that would satisfy the varied international obligations and objectives as manifested through the SPRFMO Convention and related non-binding instruments. This work led to the first Conservation and Management Measure (CMM) for the Management of Bottom Fishing in the SPRFMO Convention Area (Fig. 1) being in force in 2014 (SPRFMO, 2014).

In 2016, the UNGA adopted Resolution 71/123, which emphasised the importance of strengthening procedures for carrying out, reviewing and evaluating impact assessments, taking into account individual collective and cumulative impacts, and ensuring that any measures are based on best available scientific information, and adopt an ecosystem approach (Garcia and Cochrane, 2005). The 2016 Resolution also highlighted inconsistencies in implementation of the earlier Resolutions on sustainable fisheries across RFMOs. Recognising that implementation of SPRFMO bottom fishing measures by Members was sub-optimal, the SPRFMO Commission supported efforts led by Australia and New Zealand to initiate discussions aimed at revising the bottom fishing measure. The objective was to establish consistent management arrangements for all Members engaged in established bottom fisheries in the SPRFMO Convention Area. As a result of further work led by Australia and New Zealand and supported by other Members including the Cook Islands, the European Union (EU) and the United States (US), a comprehensive package of measures designed to assess, monitor and control bottom fisheries were developed and compiled into an updated CMM for the Management of Bottom Fishing in the SPRFMO Convention Area, hereafter referred to as CMM03 (SPRFMO, 2019b). Key measures provided by CMM03 included the designation of three different types of Management Areas to allow for bottom fisheries (based on fishing gear: bottom line; midwater trawl; and bottom trawl), the design of areas in which bottom fishing could be conducted using a spatial prioritisation approach (Cryer et al., 2018; Grantham et al., 2024; Rowden et al., 2026), and a VME encounter protocol and move-on rule to be consistently implemented across Members engaging in midwater (targeting bentho-pelagic species) and bottom trawling (Geange et al., 2020; Penney, 2014; Rowden et al., 2025). No bottom fishing (other than exploratory fisheries which are covered under other SPRFMO CMMs) is allowed outside of the Fishery Management Areas (FMAs), except for standalone Bottom Line Management Areas “Capel Bank” and “Gascoyne” (Fig. S11), which do not have an assigned FMA.

Since 2019, CMM03 has been regularly updated to reflect best available information (SPRFMO, 2025a), including the development of the recently adopted Encounter Review Standard (ERS), the first such standard among deep-sea RFMOs (SPRFMO, 2024). The ERS describes Member or Cooperating Non-Contracting Party (CNCP) and Scientific Committee responsibilities when reviewing encounters with potential VMEs, which occur when bycatch of VME indicator taxa (e.g., stony corals) in any trawl tow exceed predefined encounter thresholds, resulting in temporary suspension of fishing in the encounter area. Both the BFIAS and the ERS are periodically updated through a participatory process to reflect best practice, alignment with the Deep-Sea Fisheries Guidelines, and account for the best available scientific information. In combination with the Data Standards (SPRFMO, 2025b), these Standards are at the core of an ecosystem approach to deep-sea fisheries management in the SPRFMO Convention Area.

Standards can be fundamental to effective fisheries management, providing a structured and scientifically grounded basis for decision-making. Standards enable consistent application of methodologies across jurisdictions, facilitate the collection and exchange of comparable data, and support transparent evaluation of management outcomes (Anderson et al., 2015; Kirby and Ward, 2014). By incorporating best available science, standards help assess ecological risks, guide sustainable exploitation of marine resources, and ensure the protection of vulnerable marine ecosystems (Ardron et al., 2014; Cooke et al., 2023). Moreover, standards underpin adaptive management by allowing for systematic updates in response to emerging evidence and changing environmental conditions, thereby enhancing the resilience and accountability of fisheries governance frameworks (Free et al., 2020).

Here, we detail the structure and function of the BFIAS and ERS, their periodic updates to reflect best practice and scientific knowledge, and their role in operationalising an ecosystem approach to fisheries management. We also discuss gaps, uncertainties, and potential future improvements for these standards, including the better integration of cumulative impacts (such as climate change and cross-sectoral pressures), and discuss the need for universal impact assessment frameworks for RFMOs. Through the examples from SPRFMO, we illustrate the importance and role standards can play in achieving sustainable, science-based management of deep-sea fisheries in areas beyond national jurisdiction.

Bottom Fishery Impact Assessment Standard

The first BFIAS was adopted prior to the formalisation of SPRFMO in 2012, and since then, SPRFMO has progressively developed and implemented a fully formed package of CMMs which are key to achieving the objectives set in the Convention. Prior to the adoption of the BFIAS, bottom fishing impact assessments undertaken by Australia and New Zealand generally met the requirement to consider the impacts of fishing on VMEs, despite limited data on their distribution. However, the assessments did not adequately address the impacts on deep-sea target fish stocks (e.g., Williams, 2011; SPRFMO, 2008). Both Members focussed their analysis of potential impacts on VMEs on the spatial footprint of fishing activities in relation to the likely distribution of VMEs to make inferences about the likelihood of SAIs on VMEs. Most importantly, the assessments failed to consider cumulative impacts from the combined effort footprints and/or catches of the two Members together as well as those impacts caused by other parties that had engaged in deep-sea fisheries in the past. Furthermore, several components of the initial BFIAS were subsequently superseded by the implementation of multiple CMMs, rendering them redundant.

In response to these issues, Australia and New Zealand agreed to review the initial BFIAS, recognising that it did not fully meet the key requirement of implementing an ecosystem approach, as mandated by the SPRFMO Convention. Assessing bottom fishing impacts on non-targeted fish species (quantification of discards) and non-fish species such as seabirds, marine mammals and reptiles was one of the key additions to help fill the ecosystem approach gap (Georgeson et al., 2018). An intersessional working group formed by the Members of Australia, New Zealand, the EU, the US, the SPRFMO Secretariat and the New Zealand High Seas Fishing Group (a body representing fishing industry interests) supported a comprehensive review of the BFIAS (Georgeson and Cryer, 2019). As a result, the BFIAS (SPRFMO, 2019a), was re-structured around the following key components: a) description of fishing activities, b) mapping and description of fishing areas and c) a risk and impact assessment framework. While the description of fishing activities and areas did not substantially change, the inclusion of an assessment framework was key to align the BFIAS with an ecosystem approach as required by the overarching SPRFMO Convention.

Risk and impact assessment framework

To support an ecosystem approach to fisheries management, the risk and impact assessment framework contained in the BFIAS is based on the methodology of Hobday et al. (2011) (Fig. 2). The first step of the framework includes defining the objectives, which are set in the SPRFMO Convention (SPRFMO, 2022):

“…through the application of the precautionary approach and an ecosystem approach to fisheries management, to ensure the long-term conservation and sustainable use of fishery resources and, in so doing, to safeguard the marine ecosystems in which these resources occur.”

The first step also includes identifying the assets (e.g., target species and other ecosystem components) and the hazards these may face (e.g., the fishing activity). The second step is the identification and assessment of risks, based on the previously identified assets and hazards. The third step is the identification of monitoring and mitigation measures, which should be iteratively evaluated to assess their performance. The framework is iterative and adaptive in that risks and impacts are periodically reassessed (hierarchically; individually and in combination) and management and monitoring plans are updated accordingly (Fig. 2).

Revision of the BFIAS is currently scheduled to occur at least every five years (earlier if needed), and this typically involves at least one Member that engages in bottom fisheries (e.g., New Zealand) to run a participatory process with other Members who may have interests in bottom fisheries, independent scientists, fishing industry representatives, and environmental organisations. This type of approach, which is used by some Members in the management of fisheries within their national jurisdictions (McCay and Jentoft, 1996), allows for the identification of potential improvements from diverse perspectives. These suggestions are then reconciled by the leading Member and further presented to the SPRFMO Scientific Committee for consideration. Finally, the Scientific Committee provides advice to the SPRFMO Commission, which may adopt the BFIAS revision along with other scientific recommendations tabled by the Scientific Committee for that year.

Risk assessment for target species

Risk assessments for target fisheries species within the SPRFMO framework are undertaken following a structured, science-based process designed to evaluate the cumulative impacts of bottom fishing activities on principal target stocks, such as orange roughy (Hoplostethus atlanticus) and other target deep-sea species. The initial phase involves compiling detailed catch and effort datasets, encompassing both spatial and temporal distributions of fishing activities. These data inform assessments of the current status of target populations. Biological parameters—including growth rates, longevity, productivity, and stock structure—are incorporated to evaluate the resilience and vulnerability of these populations to fishing pressure.

The assessment approach combines both qualitative and quantitative methodologies, including formal stock assessments, biomass indices, and the establishment of reference points to guide sustainable exploitation. In circumstances where data are limited, the application of precautionary principles is emphasised, with uncertainties explicitly recognised throughout the process. The assessment of cumulative impacts accounts for fishing activities across multiple fleets and jurisdictions, ensuring that management decisions are underpinned by the best available science and reflect the ecosystem approach mandated by the SPRFMO Convention. This risk assessment process is adaptive, with periodic updates in response to new data and scientific advancements and is subject to review by the SPRFMO Scientific Committee to ensure transparency and accountability.

Risk assessment for marine mammals, seabirds, reptiles and other species of concern

Risk assessments for non-target species—including marine mammals, seabirds, reptiles, and other species of concern—within the SPRFMO framework are undertaken using a structured blend of qualitative and quantitative methodologies. The process is initiated with the identification of potentially impacted species, utilising observer data, bycatch records, and available species distribution information. For each taxonomic group, assessments consider the likelihood of interaction with fishing gear, the frequency and severity of observed bycatch events, and biological characteristics influencing vulnerability, such as population size, reproductive capacity, and migratory behaviour.

Where sufficient data are available, formal ecological risk assessment tools—such as Productivity-Susceptibility Analysis (PSA) (Hobday et al., 2007, 2011) or Sustainability Assessment for Fishing Effects (SAFE) (Zhou and Griffiths, 2008)—are employed to evaluate the relative risks faced by different species. For example, a SAFE assessment for teleost and chondrichthyan species in the SPRFMO Convention Area was completed in 2025 (Keller et al., 2025). The SAFE methodology derives a proxy for fishing mortality based on four susceptibility components (availability of the species to the fishing fleet, encounterability of the gear given the species’ vertical distribution, gear selectivity, and post-capture survival) and compares this to F-based (sustainability) reference points (e.g. Fmsy, Flim, and Fcrash) derived from basic life-history parameters. Keller et al. (2025) concluded that from all the assessed taxa, deepwater sharks are the taxonomic group at the highest risk for bottom fishing and the SPRFMO Scientific Committee has recommended several management measures to mitigate this risk (SPRFMO, 2025c).

In instances where data are limited, expert judgement and precautionary principles are applied, with uncertainties explicitly acknowledged. The assessment of cumulative impacts integrates information across fleets and years, ensuring that management measures address both direct and indirect effects of fishing activities. Outcomes from these assessments inform the development and refinement of mitigation measures, including gear modifications, spatial closures, and reporting requirements, which are subsequently reviewed by the SPRFMO Scientific Committee. This process ensures that management actions are evidence-based, transparent, and consistent with the broader ecosystem approach mandated by the SPRFMO Convention.

Risk assessment for benthic habitats and VMEs

When assessing risks to benthic habitats and VMEs under the BFIAS, criteria such as bottom fishing intensity, duration, spatial extent, and cumulative impacts are systematically evaluated. In combination, these factors provide a comprehensive assessment of the overall risk posed by fishing activities to benthic environments and VMEs. The BFIAS provides examples of qualitative and quantitative methodologies to help assess risks and impacts of bottom fishing on VMEs, with the most recent iteration of the Bottom Fishery Impact Assessment (BFIA) for New Zealand and Australian bottom fisheries (Anderson et al., 2024) including a benthic quantitative impact assessment based on the dynamic relative benthic status (dRBS), a fully quantitative methodology to estimate the benthic status of a species, species group, or habitat (Pitcher et al., 2017). The dRBS as applied in the BFIA makes use of historical fishing effort annual data (as swept area ratio; SAR), habitat suitability data layers for VME indicator taxa (transformed to better reflect the presence of a VME, and account for model uncertainty) (Stephenson et al., 2021), and VME indicator taxon-specific depletion and recovery rates (Anderson et al., 2024). The BFIAS indicates that benthic impact assessments should be conducted at spatial scales that are ecologically relevant; however, it acknowledges that data limitations may necessitate the use of alternative spatial units, such as undersea features or management areas. The current focus of the application of the dRBS status assessment is for Fishery Management Areas (FMAs), which include areas open (Bottom Trawl, Midwater trawl and Bottom Line Management Areas) and closed (the remainder of the FMA) to bottom fishing. Estimates of the dRBS for each assessed VME indicator taxon are used to determine whether predicted suitable habitats in FMAs are adequately protected from SAIs. Consistent with the Marine Stewardship Standard (MSC, 2024), dRBS values averaged over the FMA below 80% are interpreted “as reductions in habitat structure and function below 80% of the unimpacted state” that signal “serious or irreversible harm” (i.e., SAIs) for these “more sensitive” habitats, such as VMEs. This approach therefore assumes that a certain level of impact (due to fishing) can be compatible with avoiding SAIs on VMEs. It is important to note that such thresholds are inherently scale-dependent, and their interpretation may vary with the spatial resolution of the assessment.

Mitigation, management and monitoring measures

Under CMM03, most of the SPRFMO Convention Area remains closed to bottom fishing (excluding exploratory fisheries), with the exception of designated FMAs that allow bottom long lining, bottom trawling and midwater trawling (targeting bentho-pelagic species such as alfonsinos) within clearly defined boundaries (with the exception of the Capel Bank and the Gascoyne Bottom Line Management Areas, see Fig. S11) (Table 1). This spatial management approach was designed to ensure that a large percentage of the model-predicted suitable habitat for VME indicator taxa remains outside areas open to bottom fishing, thereby providing for the long-term conservation and sustainable use of deep-sea fishery resources. The design of this measure aims to provide an assurance that bottom fishing would not have SAIs on VMEs, considering the spatial extent of the impact of fishing activities relative to the availability of predicted habitat for VME indicator taxa within the broader SPRFMO area. As of 2026, approximately 12.2% and 12.7% of the SPRFMO Convention Area within fishable depths remain open to bottom and midwater trawling, respectively (Table 1).

To account for the residual risk associated with the spatial management approach (see subheading - Key gaps and uncertainties), a VME encounter protocol was established as the main complementary management measure. The protocol includes the temporary closure of an area if specified weights of VME indicator taxa are exceeded in a trawl. This protocol provides a mechanism for the rapid curtailment of bottom fishing in an area where the bycatch of VME indicator taxa is unexpectedly high relative to taxon-specific cumulative distributions of historical VME indicator taxa bycatch from within the SPRFMO Convention Area (> than the 99th percentile of historic catches) (Geange et al., 2020; Rowden et al., 2025). Following the triggering of an encounter, the encounter is reviewed by the Member state and then by the Scientific Committee following the requirements provided by the Encounter Review Standard (see heading - Encounter Review Standard), with appropriate management recommendations put forward to the SPRFMO Commission. The BFIAS mandates the reporting of these existing management measures, and the inclusion of other complementary monitoring measures (such as fine-resolution mapping of benthic bycatch; Tablada et al., 2022; 2023), providing for a continuous evaluation based on best available information.

Key gaps and uncertainties

The BFIAS requires that uncertainties within the risk and impact assessment framework be explicitly stated. This statement includes identifying areas where future research or additional data collection may be necessary to reduce or resolve these uncertainties. Current uncertainties for key fish stock assessments include poor knowledge of the stock structure for target species (i.e., orange roughy), gaps in key biological information (growth, longevity, productivity) and indices of biomass and/or fishing mortality for key target stocks and SPRFMO‐specific management targets and limits for key targets and other stocks. Due to the inherently low productivity of deep-sea fisheries and the life history traits of the main target species such as orange roughy, as well as the characteristics of the ecosystems that support them, significant ecological changes in these systems are likely to develop, and recover, over much longer timescales compared with more productive shallower systems. As a result, the full extent of the impacts from existing orange roughy fisheries in the high seas of the South Pacific may not yet be fully apparent and, therefore, inherently hard to estimate (Tingley and Dunn, 2018). Uncertainties in the assessment of impacts on marine mammals, seabirds, reptiles and other species of concern arise from several sources, including inaccurate identification of caught specimens by fishers and observers, limited knowledge of the distribution of certain at-risk species, and insufficient estimates of population size and productivity for species with broad ranges and/or poorly understood biology. As an example, the most recent SAFE assessment for teleost and chondrichthyan species (Keller et al., 2025) highlighted the lack of information about the distribution of these species in the SPRFMO Convention Area (and significant divergences between the different data sources) and the biological productivity attributes of some of the species assessed. For deep sea chondrichthyans, inaccurate species identification remains an issue.

Regarding assessment of benthic habitats and VMEs, a considerable degree of uncertainty is associated with the modelling of the habitat suitability of VME indicator taxa across the western part of the SPRFMO Convention Area (Stephenson et al., 2021). These models underpin the quantitative assessment of benthic impacts due to the impracticality of undertaking benthic surveys across such a large, deep and remote area. Recognising the limitations of habitat suitability index models, especially those based on presence-only data (Stephenson et al., 2021), recent efforts have focused on the development of abundance models for VME indicator taxa (Bennion et al., 2025a), which are based on observation data from sampled areas (seafloor video imagery) and represent an important step forward given the current lack of understanding between abundance and predictions of suitable habitat. However, data paucity regarding distribution of benthic taxa remains the biggest hurdle, with most of the survey data used in modelling efforts collected in areas adjacent to the western part of the SPRFMO Convention Area, mainly New Zealand’s Exclusive Economic Zone (EEZ) (Bennion et al., 2024, 2025a).

Future improvements

Despite the BFIAS having performed relatively well against an independent evaluation of impact assessments across deep-sea fisheries RFMOs (DOSI, 2022; Kaikkonen et al., 2024), it can be improved in many respects. The most recent review of the BFIAS led by New Zealand acknowledges missing components to further progress the ecosystem approach to fisheries management, such as estimation of impacts across ecosystem levels (e.g., through trophic modelling) and missing linkages between the assessed components of the ecosystem (Arkhipkin and Tablada, 2025). To be able to include and meaningfully inform such changes to the BFIAS, efforts must be made to collect more environmental and ecological data that would allow, among other things, improved environmental baseline information and better mapping and identification of VMEs and other important benthic habitats (DOSI, 2022; Kaikkonen et al., 2024). VME indicator taxa such as corals and sponges can form significant habitats known to support a variety of biodiversity, including commercially important fish species (De Clippele et al., 2025) and fulfil ecosystem functions such as bentho-pelagic coupling and nutrient and carbon cycling (e.g., Maier at al., 2020; De Clippele et al., 2021). The limited availability of data on the composition and size structure of communities dominated by VME indicator taxa make it difficult to quantify their functional attributes. While ecosystem functions provided by VMEs are influenced by factors such as spatial extent, body size and age structure, accurately determining these effects requires abundance data collected at fine spatial scales (Susini et al., 2025; Vad et al., 2025).

The BFIAS provides for the use of alternative sources of information to direct observations from the seafloor to identify areas known or likely to support VMEs. These sources include benthic bycatch records, predictive models for VME indicator taxa and known distribution of underwater topographic features (particularly seamounts) that may support VME indicator taxa (i.e., Clark et al., 2022). However, the BFIAS does not provide a multi-criteria framework for integrating these diverse sources of information (including data collected by seabed biodiversity surveys) to support identification of VMEs (Morato et al., 2018). Although data collected directly from areas of interest is generally considered the best way to map areas likely to host VMEs, there is currently no consensus among experts on how to identify VMEs using imagery data (although progress towards developing a consensus is being made; see Baco et al., 2023). Furthermore, the operational and logistical costs associated with such direct surveys are extremely high. The BFIAS would benefit from including a reference to a robust methodology to cost-effectively identify or estimate VMEs (Bennion et al., 2025a; Stephenson et al., 2025), which could subsequently be used to support an assessment of the likelihood of SAIs on VMEs due to fishing impacts. The Deep-Sea Fisheries Guidelines provide guidance for identifying VMEs and assessing SAIs; however, they offer limited practical direction for evaluating and operationalising what constitutes a SAI in practice (Rowden et al., 2024). An important management part of this gap is the absence of a pragmatic and practical threshold that can help differentiate between an acceptable and unacceptable impacted state (Hiddink et al., 2023). Without defined ecologically relevant thresholds to distinguish what constitutes a SAI, and without a systematic process for identifying areas that qualify as VMEs, the BFIAS is currently unable to fully operationalise the requirements of multiple UNGA Resolutions that call for the prevention of SAIs on VMEs in the high seas.

While the BFIAS provides for consideration of cumulative impacts from fishing, it currently does not require the inclusion of other impacts such as those derived from climate change resulting from increased water temperatures, ocean acidification and deoxygenation, or any other human activities other than fishing. The lack of this requirement is significant given the SPRFMO Convention’s focus on an ecosystem-based approach to fisheries management. Climate change is already having impacts on marine ecosystems, which in the future may be exacerbated, including on water column productivity, on habitats of importance to commercial fish species and on fisheries (Pinkerton, 2017; Datta et al., 2024). Therefore, these other actual or potential impacts should be assessed as cumulative impacts alongside present and historical fishing activity (FAO, 2019). Although information on how climate change affects deep-sea communities remains limited, environmental shifts driven by climate change will increase uncertainty in assessing the impacts of bottom fishing, adding another degree of complexity to risk assessment and related management decisions (Cummings et al., 2021; Pentz, 2018). The exclusion of non-fishing impacts from the BFIAS reflects the current limited understanding of benthic ecosystems within areas open to bottom fishing in the SPRFMO Convention Area, rather a deliberate omission, noting that RFMOs are mandated to adopt rules for managing fisheries exclusively. For other RFMO areas, information about impacts from non-fishing activities may be available and can be included directly in impact assessments. For example, NAFO has started exploring the inclusion of impacts such as oil spills, noise and seabed litter (Durán Muñoz et al., 2022). In the South Pacific there are ongoing research efforts aimed at addressing the knowledge gaps around assessing cumulative impacts (e.g., Gammon et al., 2018; Hitt et al., 2020; Tracey et al., 2024). Of particular relevance is the recent work exploring the implications for the management of deep-sea corals facing multiple human-driven impacts within New Zealand’s national waters (Stephenson et al., 2023), which could be applied to the western part of the SPRFMO Convention Area. Characterising climate-driven changes in taxa occurrence, abundance and distributions is fundamental to any climate change strategy. In the context of SPRFMO bottom fisheries, key taxa include VME indicator taxa, vulnerable non-target species (e.g., deep-water sharks, rays and chimaeras) and commercially valuable species. Extensive work undertaken by New Zealand within its jurisdictional waters has modelled the future distribution of suitable habitat for deep-water corals and demersal fish species, including orange roughy, under projected seafloor environmental conditions (Anderson et al., 2022; Brough et al., 2025) using climate models tailored to the South Pacific (Behrens et al., 2020). These approaches could be extended to the western part of SPRFMO Convention Area, where most of bottom fishing occurs, and incorporated into the BFIA to assess likely shifts in future fishing effort. This would enable forward looking risk assessments that account for future spatial overlap between fisheries species of interest and fisheries, identify potential climate refugia for VME indicator taxa, and support initial evaluation of cumulative impacts, including those arising by cross-sectoral activities (Judah et al., 2025; Zelli et al., 2025). Climate change vulnerability assessments (e.g., Cerutti‐Pereyra et al. 2024), which use species’ life history traits to assess their capacity to persist under future environmental conditions, could also be adapted to the SPRFMO Convention Area and incorporated into future iterations of the BFIA, complementing existing risk assessments for chondrichthyans and other vulnerable taxa (e.g., Keller et al. (2025), see subheading - Risk assessment for marine mammals, seabirds, reptiles and other species of concern).

Encounter Review Standard

As already noted above, SPRFMO operates a VME encounter protocol as a complementary management measure to the spatial management which is the primary means by which SAIs to VMEs are prevented. As such, this standard is important for supporting the overall management measures that are put in place to implement an ecosystem approach to fisheries management. Specifically, CMM03 requires that “where VME indicator taxa are encountered in any one tow at or above the weight threshold in Annex 6A, or three or more different VME indicator taxa at or above the weight thresholds in Annex 6B, Members and CNCPs shall require any vessel flying their flag to cease bottom fishing immediately within an encounter area of one (1) nautical mile either side of the trawl track extended by one (1) nautical mile at each end” (hereafter referred to as the encounter area). Vessels are then required to report the encounter immediately to the Member or CNCP whose flag the vessel is flying and to the Secretariat, in accordance with the Guidelines for the preparation and submission of notifications of encounters with potential VMEs, contained in Annex 7 of CMM03.

Since the implementation of the encounter protocol in 2019, SPRFMO has progressively developed guidance to assess encounters with potential VMEs, which has been consolidated in the Encounter Review Standard (ERS). The ERS aligns with the Deep-sea Fisheries Guidelines, considers biologically relevant scales for assessing SAIs on VMEs (i.e., bioregions, see Bennion et al., 2025b), and provides a streamlined, time-efficient method that accommodates the different capacities of Member States to participate and undertake encounter reviews. New Zealand developed the ERS based on existing materials (Milardi and Geange, 2021) through a participatory process that included representatives from both fishing industry and environmental organisations. The ERS is structured around the steps that the Member (or CNCP) and the Scientific Committee must follow after an encounter has been notified (Fig. 3).

Ultimately, the outcome of the application of the ERS is to provide advice to the SPRFMO Commission, which then can determine appropriate management actions for each encounter to prevent SAIs on VMEs, which may include: the closing of areas to some or all bottom fishing gear; temporal restrictions; spatial restrictions; and reopening areas.

Member review

Encounter detailed description

A Member needs to provide a detailed description of each encounter for the consideration by the Scientific Committee. This description should contain date and location, gear and vessel specifications, a detailed composition of the benthic bycatch associated to the encounter, including a characterisation of the ecology and biology of each VME indicator taxon encountered and the best available information related to its catchability (Stephenson et al., 2022). Location of historical bottom trawl tows (and associated benthic bycatch data) within the encounter area (and surrounding areas, ideally up to the entire Bottom Trawl Management Area within which the encounter took place) as well as spatial predictions of VME indicator taxa (habitat suitability index models, abundance models) need to be provided as well. Information regarding the oceanography, topography and geomorphology for the area of interest, where available, must be included. The ERS provides technical requirements for figures (maps) that the Member may develop to include some of these data and allows for the data confidentiality considerations. Where data is subject to internal regulations regarding the protection of private and commercially sensitive information, the Member can choose to either establish a formal data confidentiality agreement with the Scientific Committee or to withhold the data (while providing a clear description of the nature of the data being withheld along with its limitations).

VME assessment

The ERS does not provide a formalised mechanism to assess whether a VME is known or likely to occur within the encounter area but allows Members to use two complementary approaches. The first is a direct assessment, based on data collected from the encounter area (i.e., seafloor imagery), and the second is an indirect assessment, based on best available information collated by the Member. While the ERS acknowledges that the direct assessment method is likely to provide the most robust information for identifying VMEs and should be preferred, evidence from a direct assessment can be further strengthened by integrating information from indirect assessments (Baco et al., 2023). However, there are often challenges related to the spatial scale of surveys and the resourcing required to undertake surveys of areas likely to host VMEs, and only a very limited number of sites within the western part of the SPRFMO Convention Area have been surveyed in the past (Clark et al., 2015; Clark and Roberts, 2008).

The ERS also supports the use of multi-criteria analysis methods as a robust approach for evaluating different “lines of evidence” and the “weight” of these lines of evidence against sections of the Deep-Sea Fisheries Guidelines and determining whether an encounter constitutes evidence of a VME. Such a multi-criteria approach for assessments is widely used in environmental decision-making processes (e.g., Turschwell et al., 2023, Vanegas-Cantarero et al., 2022) and is included in the Northwest Atlantic Fisheries Organization (NAFO) and International Council for the Exploration of the Sea (ICES) ‘benchmark’ processes for identifying VMEs and assessing SAIs (NAFO, 2020; ICES, 2022). Multi-criteria assessments following the ERS should integrate as much relevant information as possible into the process of identifying the known or likely occurrence of a VME. This assessment includes a variety of data sources, from direct observational methods such as video, echo-sounder and multi-beam surveys, to indirect methods such as evaluation of historical benthic bycatch, thresholding of predictive modelling for VME indicator taxa distribution, and assessment of the presence of topographical, hydro-physical or geomorphological features which may support VMEs. Other RFMOs have opted to start the process to formalise similar multi-criteria approaches to the one provided in the ERS to identify VMEs (e.g., Curtis et al., 2020; Kenny et al., 2025; Warawa et al., 2025), but due to a lack of an explicit framework in SPRFMO to identify VMEs, the ERS currently provides flexibility to Members undertaking encounter reviews.

SAI assessment

The ERS requires an evaluation of whether reopening the encounter area will expose any VMEs to SAIs, noting that the range of relevant ecological spatial scales at which VMEs can be identified remains an open question. That determination should be made on a case-by-case basis through the application of relevant provisions in the Deep-sea Fisheries Guidelines, particularly Section 3.3 and Article 47. Like the multi-criteria approach in the VME assessment, the ERS provides flexibility to how Members can assess likelihood of SAIs on VMEs (if VMEs are deemed to be, or likely to be, in the encounter area). In the ERS, a minimum of an “expert judgement” approach is provided for, although semi-quantitative and fully quantitative impact assessment methods are recommended, subject to data availability and Member’s capacity (Peixoto et al., 2025; Pitcher et al., 2017).

Management actions

The ERS requires Members undertaking encounter reviews to identify management actions they consider necessary to prevent SAIs on VMEs based on the results of their application of the ERS. The ERS offers a variety of actions Members can choose from (i.e., maintaining a closure, re-opening an area) but also offers flexibility to allow Members to suggest other actions that may be deemed appropriate to the specific context of an encounter.

As of October 2025, the ERS has been put into practice once since its formal adoption, with New Zealand providing a review based on an indirect approach that makes use of the best available information, including information on the geomorphology and biogeography of the encounter area, historical VME indicator taxa bycatch data, habitat suitability index models and abundance models for VME indicator taxa, historical benthic invertebrates records and a quantitative benthic impact assessment using the dRBS approach (New Zealand, 2025).

Scientific Committee review

At its annual meeting, the SPRFMO Scientific Committee must review all encounter reviews tabled by Members or CNCPs. In reviewing the assessments provided by Members, for each encounter, the Scientific Committee is required to consider the detailed analyses while applying the Deep-sea Fisheries Guidelines, and to determine the adequacy of the review, including the suggested management actions. The ERS suggests that the Scientific Committee develops management actions and advice to the SPRFMO Commission based on the Member’s recommendations but provides flexibility in allowing the Scientific Committee to determine any action or advice it may consider appropriate for each encounter area and, as appropriate, all encounter areas combined. Ultimately, final decisions on management actions for each encounter are decided by the SPRFMO Commission.

Key gaps and uncertainties

Like the BFIAS, the ERS requires Members to explicitly refer to known limitations and uncertainties of their analysis, including how these are reflected in their suggested management actions. The ERS acknowledges that almost every source of information regarding the identification and location of VMEs in the South Pacific high seas, as well as the definition of what constitutes a SAI, is embedded in a significant degree of uncertainty. For example, with respect to identifying VMEs, there is a lack of specific understanding about the trawl catchability of VME indicator taxa, which is likely to be variable across the SPRFMO Convention Area depending on the geomorphological attributes of each area and be taxon-specific (Rowden et al., 2024; Stephenson et al., 2022). Using historical fishing effort and benthic bycatch data carries other limitations other than catchability of VME indicator taxa, such as limited geolocation accuracy, particularly for the early years of the orange roughy fisheries in the high seas, when no specific regulatory measures and associated data reporting standards were in place (Tingley and Dunn, 2018). Modelled predictions of the distribution of VME indicator taxa are constrained by coarse-level taxonomic data, integration of data from multiple sources and multiple points in time (e.g., fisheries bycatch, research surveys), limited coverage of data across geographical and environmental spaces, which combined are impeding the development of highly-accurate, fine-scale, species-specific predictions (Stephenson et al., 2021).

Despite the assumed uncertainties, the ERS requires consideration of the Deep-sea Fisheries Guidelines and the precautionary approach, meaning that not being in possession of highly certain and accurate information regarding location and extent of VMEs is not an impediment to implementing management actions (van Denderen et al., 2023).

Future improvements

The relationship between the biomass of benthic bycatch recorded on the surface and the biomass on the seafloor is poorly understood. Generally, bottom trawl gear is relatively inefficient at catching benthic invertebrates, including VME indicator taxa, so the amount of bycatch material landed on deck is unlikely to represent the scale of impact on the seafloor because some of the catch may be broken into small fragments and lost from the net before it is recovered to the surface for further examination (Stephenson et al., 2022). In SPRFMO bottom fisheries, it has been acknowledged that existing data on the catch efficiency of trawl gears for VME indicator taxa is broadly consistent and indicates that catchabilities are generally very low, meaning only a small fraction of VME indicator taxa on the seafloor are caught and retained by demersal fish trawls (Geange et al., 2019; Stephenson et al., 2022). Lack of data from the SPRFMO fishing grounds is a known impediment for determining density/biomass estimates of VME indicator taxa and the development of area-based and taxon-specific catchability estimates, both of which are ideally important inputs for determining thresholds for the VME encounter protocol and the ERS. To date, a pragmatic but data-informed approach has been used to develop candidate threshold weights (Geange et al., 2020), and the possibility of a research programme to allow the determination of more robust taxon-specific estimates of catchability has been explored (Stephenson et al., 2022), although its cost has been deemed too high and its benefits uncertain. The North Pacific Fisheries Commission (NPFC) has recently undertaken work (Rooper et al., 2025) that builds on the approach adopted by SPRFMO and outlined in Geange et al. (2020). Subject to the availability of suitable data from within the SPRFMO Convention Area or adjacent fishing grounds (e.g., parts of the New Zealand’s EEZ), the approach developed by Rooper et al. (2025) could be trialled for a certain subset of VME indicator taxa. More robust thresholds would likely improve determination of likelihood of SAI on a VME and enhance the overall applicability of the ERS. While it is widely accepted that encounter thresholds should be data-informed and scientifically-driven, RFMO-specific bottom fisheries management considerations, such as spatial management arrangements, gear-specific restrictions, levels of observer coverage and move-on distances, may also inform the setting of thresholds (Reid, 2023). As of 2026, SPRFMO is the only deep-sea RFMO that has used context-specific bycatch data to develop a distinct set of threshold weights for VME indicator taxa designed to inform the biodiversity component of the encounter protocol. This component is triggered when the bycatch weight of at least three VME indicator taxa in one given tow reach or exceed the values set in Annex 6B of CMM03, as an indication that diverse seabed fauna may represent the presence of a VME (Watling and Auster, 2021).

Other potential improvements that have been identified but not addressed yet refer to the application of the dRBS, which is relevant to the BFIAS and the ERS, to determine likelihood of SAIs on VMEs. The lack of status thresholds to determine if a SAI on a VME has occurred (or likely occurred), and at which spatial scales these thresholds can be applied, are outstanding issues that remain to be addressed (Arkhipkin and Tablada, 2025). Progress is being made in the development of approaches to define SAIs quantitatively using the ‘range of natural variation’ approach (Hiddink et al., 2023). This approach defines a good state of an indicator, such as VME abundance or biomass, as an indicator value that falls within the long-term natural variation of that indicator in time-series from minimally impacted locations. Although very few time-series are likely to exist for VME indicator taxa, fitting general relationships between the threshold for good state and environmental (e.g. depth) and life-history (e.g. longevity) parameters is likely to allow the extrapolation of thresholds for VMEs in the SPRFMO Convention Area. These thresholds (relative to carrying capacity / long-term mean abundance in minimally impacted locations) are likely to be much higher for VME indicator taxa than those applicable to shallower water benthic communities (Hiddink et al., 2023).

Both the BFIAS and the ERS would benefit from having reference points in terms of relative benthic status and spatial scales that are of ecological relevance to VMEs, even more so if they were to be tailored for each VME indicator taxon.

While the ERS offers a degree of flexibility to accommodate each Member’s capacity and resources to undertake encounter reviews, a comprehensive application of the ERS may require significant effort and time (New Zealand, 2025). All the possible enhancements to the ERS discussed above would likely result in efficiencies when reviewing potential encounters with VMEs. A more streamlined ERS would be desirable if SPRFMO bottom fisheries were to significantly expand (in terms of effort and/or spatially), as this could increase the number of encounters triggered in a fishing year.

Looking ahead

Detected deficiencies and limitations across the different RFMOs that require impact assessments of deep-sea fisheries on the ecosystem are due, at least in part, to elements and criteria that are missing from the Deep-sea Fisheries Guidelines (DOSI, 2022; Kaikkonen et al., 2024). Having a structured universal bottom fishing impact assessment standard could solve these deficiencies and allow for inter-comparability among RFMOs. Differences between RFMOs, such as data availability, scientific capacity, and the value of the fishery, should be considered, ensuring that a degree of flexibility is incorporated when designing such a standard. For example, data paucity on actual VMEs including connectivity, community composition and ecosystem function is the most critical impeding factor across RFMOs to provide appropriate baseline information in their respective benthic impact assessments (DOSI, 2022; Kaikkonen et al., 2024). While most RFMOs have opted to model predicted habitat suitability for VME indicator taxa as a proxy for VME occurrence (which misses the aforementioned aspects of connectivity, community composition and function), this is not evenly applied across RFMOs, due to the different RFMO-specific lists of VME indicator taxa (Baco et al., 2023). Some RFMOs have developed more comprehensive lists of VME indicator taxa than others (and often using different levels of taxonomic resolution), in part due to the topographic and morphological characteristics of each geographical area (Baco et al., 2023; Reid, 2023). Another critical difference to consider when designing an across-RFMO standard relates to fishery-independent surveys. While such surveys are routinely carried out in the NAFO Regulatory Area and the collected data is used in the multi-criteria approach designed to identify VMEs (Kenchington et al., 2026), other deep-sea RFMOs may not have the means to fund such surveys and lack the capacity to support such a time and data-consuming scientific process.

Recent independent reviews on the implementation of the ecosystem approach (Fletcher, 2020) and the Deep-sea Fisheries Guidelines (Thompson and Reid, 2024) by RFMOs have identified important achievements but also gaps. Specifically, Fletcher (2020) identified that the major gaps relate to ecological wellbeing (notably the lack of inclusion of climate change considerations, see subheading - Future improvements) and human wellbeing (missing economic and/or social aspects). Importantly, Fletcher (2020) noted that many of the assessed RFMOs engaging in deep-sea fisheries have tasked progressing the implementation of an ecosystem approach to a subsidiary scientific body (e.g., SPRFMO Scientific Committee). However, the implementation of the ecosystem approach should be guided by an overarching strategy (FAO, 2012) and include long-term management plans with appropriate tracking and monitoring systems in place to assess progress, something that NAFO has begun to implement (Mariano Koen-Alonso et al., 2019) and, we believe, SPRFMO should consider. Fletcher et al. (2020) also noted that despite SPRFMO being one of the most recently established RFMOs, it has managed to consider half of the key components regarding implementation of an ecosystem approach to fisheries (FAO, 2012). Furthermore, it must be acknowledged that SPRFMO manages three fishery resources (jack mackerel, flying jumbo squid and orange roughy) that are ecologically and geographically distinct, and with a varying degree of involvement across membership, adding an extra layer of complexity and influencing the implementation of an ecosystem approach, which is variable across each fishery. In this regard, SPRFMO could consider diverse ways to implement an ecosystem approach based on the uniqueness of its fisheries, including the diverse requirements for assessments, capacity of engaged Members, availability of data and scientific knowledge and objectives (ICES, 2024).

Arguably the most comprehensive independent performance evaluation of RFMOs to date has identified that despite its recent establishment, SPRFMO (out of the 16 assessed RFMOs) ranked above average (Carmine et al., 2025). While Carmine et al. (2025) acknowledged the relative appropriateness of existing measures across SPRFMO managed fisheries (which by definition include the standards being discussed here, but also other aspects such as governance tools), this does not necessarily translate to achieving demonstrable results in terms of implementing the ecosystem approach (interpreted as management success). Significantly, none of the 16 assessed RFMOs reviewed by Carmine et al. (2025) achieved results deemed as best-practise, indicating that performance gaps are not unique but rather common, even among higher-performing RFMOs. Carmine et al. (2025) and similar publications understandably analyse RFMOs in their entirety and typically do not provide individual evaluations for each fishery, which may differ significantly.

Within the SPRFMO context of bottom fisheries, the BFIAS and the ERS acknowledge that there are important aspects that remain unresolved, including the lack of practical and operational definitions for VMEs and SAIs. However, many of these unresolved issues are common to other RFMOs and addressing them would improve the likelihood of generating universal standards for implementing ecosystem-based fisheries management in the high seas. For example, the spatial scales at which to identify, map, and assess impacts on VMEs (following the Deep-sea Fisheries Guidelines reference to “species groups, communities, habitats and features”) need to be ecologically relevant. Providing clarity on SAIs and VMEs would have consequences for both the BFIAS and the ERS, as it could facilitate the development and adoption of operational thresholds to be included in quantitative assessments. The development and establishment of a data-driven, pragmatic approach to identify VMEs across the SPRFMO Convention Area would allow the population of the VME register (Annex 9 of CMM03), where locations of known VMEs within the SPRFMO Convention Area are listed, which as of 2026 remains empty. The empty register can be partly justified by the fact that, as already mentioned, SPRFMO relies on excluding a significant amount of the predicted suitable habitat for each VME indicator taxon within FMAs as a way to avoid SAIs on VMEs (SPRFMO, 2023), therefore postponing the issue of VME identification across large spatial scales (e.g., FMAs) until availability of relevant data improves (Ardron et al., 2014). However, the application of the ERS may require undertaking identification of potential VMEs at relatively small spatial scales (i.e., the area that results temporarily closed to fishing). These ad-hoc applications of the ERS may lead to the VME register being progressively populated, subject to the management outcomes of each assessed encounter as determined by the SPRFMO Commission.

The Agreement under the United Nations Convention on the Law of the Sea on the Conservation and Sustainable Use of Marine Biological Diversity of Areas beyond National Jurisdiction (BBNJ Agreement) adopted in 2023 entered into force in January 2026. The BBNJ Agreement is likely to have consequences for RFMOs, particularly regarding the inclusion of impacts across multiple sectors in impact assessments for areas beyond national jurisdiction (Johnson et al., 2025). Sectors identified as being a priority for immediate inclusion in cumulative impacts assessment include biodiversity conservation, climate change, oil and gas, and deep-sea mining and renewable energy (Johnson et al., 2025). The BBNJ Agreement sets out the procedures for proposals for area-based management tools (e.g., marine protected areas, fishery closures), which are expected to be formally assessed. These proposals are likely to include criteria for identifying areas of ecological significance and consideration of fishing impacts, alongside other anthropogenic pressures. Such criteria are likely to relate directly to VMEs and assessment of SAIs, respectively. Therefore, future impact assessments would benefit from a standardised framework (similar to, or based on the BFIAS, for example) and build on the significant progress SPRFMO has made in developing and implementing Standards and Conservation and Management Measures intended to safeguard the marine ecosystems in which the fishing resources it manages occur. In this context, promoting increased cooperation at regional scales between established RFMOs such as SPRFMO and other inter-governmental organisations appears to be critical to achieve broader conservation and sustainability goals (Carmine et al., 2025; FAO, 2026; Johnson et al., 2025; Tian and Guo, 2025; Weiand et al., 2021).

Acknowledgements

We thank Riki Mules from the New Zealand Ministry for Primary Industries for providing us with his geospatial expertise and support.

We thank the New Zealand Ministry for Primary Industries (including its fisheries business unit, Fisheries New Zealand), the Ministry of Foreign Affairs and Trade and the Department of Conservation for their involvement in the inception and on-going work of SPRFMO.

We thank the many people who along the way have been involved in the development of the science and the measures that inform an ecosystem approach to deep-sea fisheries management in the SPRFMO Convention Area, including all participants (past and present) of the SPRFMO Deepwater Working Group and of the New Zealand South Pacific Working Group (SPACWG), former chair of the Scientific Committee James Ianelli, and former chair of the International Consultations and Preparatory Conference, Bill Mansfield.

We thank NAFO, ICES and the Food and Agriculture Organization (FAO) of the United Nations for co-organising and hosting the Symposium on applying the Ecosystem Approach to Fisheries Management in ABNJ, 11–13 March 2025 at the FAO Headquarters in Rome. We thank Anthony Thompson, Eszter Hidas and Keith Reid for their continuous support of the FAO Deep-sea Fisheries Project and its on-going engagement with SPRFMO.

Finally, we thank Andie Perreault (General Editor, JNAFS) and the anonymous reviewers for providing constructive comments that improved our manuscript.

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