The aquaculture blind spot: anticipating subsidy displacement after the WTO Agreement on Fisheries Subsidies

For decades, the world's oceans have been treated as a shared pantry, where anyone with a boat could take fish until the shelves ran empty. To stop this, nations have long tried to regulate the money governments give to fishing fleets, known as subsidies, because cheap fuel or free gear can encourage boats to keep catching fish even when the populations are already too low to recover. However, a major shift has occurred in how we get our seafood. While wild fishing once dominated, fish farms now produce more than half of all the fish and shellfish humans eat. In 2024, farms yielded 103 million tonnes of aquatic animals, surpassing the 92 million tonnes caught from the wild. The rules meant to protect the oceans, however, were written with the old world in mind. A new global agreement, which came into force in September 2025, strictly limits the money governments can give to wild fishing but explicitly leaves fish farming out of the picture. This creates a strange situation where the most productive part of the seafood industry operates without the same financial guardrails as the wild catch.

A new perspective from the University of Geneva examines what happens when a global rule protects one side of an industry while ignoring the other. The author, Pierre-Jean Clausse, argues that this gap does not just leave fish farming unregulated; it actively encourages governments to move their spending from the restricted wild fisheries to the unrestricted farms. This shift, which the paper calls "subsidy displacement," means that public money intended to support seafood production might flow into farming operations that still rely heavily on wild fish for feed or that use legal loopholes to keep fishing pressure high. Because there is no global database tracking how much money governments give to fish farms, and because the new agreement does not require them to report it, no one can currently measure if this shift is happening or how much damage it causes. The paper suggests that without new rules to bring these hidden subsidies into the light, the global effort to save wild fish stocks could be quietly undermined by the very industry meant to relieve pressure on them.

The core of the problem lies in how the new World Trade Organization agreement defines its scope. The treaty was designed to stop illegal fishing, overfishing, and fishing on the high seas where no one is in charge. It successfully bans subsidies for these specific activities in the open ocean. However, the agreement contains a footnote stating that aquaculture and inland fishing are excluded. This exclusion was based on the idea that a fish farm is private property, and the owner bears the cost if they mismanage it, unlike a wild fish stock which belongs to everyone. Consequently, while the treaty successfully disciplines the wild catch, it leaves the farm sector in a legal blind spot. The paper points out that while there are estimates showing the world spent over 35 billion dollars in 2018 on subsidies for wild fishing, there is no equivalent global figure for fish farming. This lack of data makes it impossible to know if the new rules are working as intended or if they are simply pushing the problem elsewhere.

The author identifies three specific ways this displacement could occur. The first is a simple budget shift. Governments that can no longer spend money on fuel or boats for overfished wild stocks still have production targets and political pressure to keep the seafood industry growing. With wild fishing restricted, the obvious destination for that money is the farm sector. For example, China's current five-year plan aims to keep the wild catch steady while increasing total seafood output, meaning all growth must come from farms. Similarly, the European Union has allocated over one billion euros to aquaculture in its recent fisheries fund. While much of this spending might be beneficial, the paper argues that moving public money to a sector with no sustainability discipline creates a risk that the harm caused by that money will simply move from the ocean to the farm.

The second route of displacement runs through the food that farmed fish eat. Many farmed species, such as salmon and shrimp, require feed made from wild fish. About 21 million tonnes of wild fish are caught every year just to be turned into fishmeal and fish oil for these farms, and aquaculture uses nearly all of it. If a government subsidizes the cost of feed or the farms that buy it, that money indirectly supports the wild fishing fleets that catch the small fish for the feed. The new agreement bans subsidies for fishing overfished stocks, but it does not cover the factories on land that process the fish or the farms that buy the resulting meal. A country could technically follow every rule in the agreement while still financing the demand that keeps a poorly managed wild fishery running.

The third route involves legal definitions. Some farming practices, known as capture-based aquaculture, involve catching young wild fish, such as tuna or eels, and fattening them in pens. The act of catching the fish is considered wild fishing and is covered by the new rules, but the fattening process is not. This creates a blurry line where a subsidy could be designed to pay for the fattening phase while avoiding the cost of the catch, effectively slipping through the legal cracks. Similarly, a grant for processing fish at sea is covered by the agreement, but the same grant for processing in a port is not. The paper notes that wherever a treaty draws a line through a production chain, support tends to be designed to fall on the cheaper, uncovered side.

The paper emphasizes that this displacement is currently a hypothesis because the data to prove it does not exist. There is no global estimate of aquaculture subsidies, and the few regional studies available show a fragmented picture. For instance, a study of the European Union found that while billions were spent on the sector, production had stagnated, and there were no indicators to measure the environmental sustainability of that spending. The World Trade Organization requires countries to report their subsidies, but compliance is poor, and the reporting framework is often incomplete. The author warns that if aquaculture follows the same slow path as wild fishing, where evidence was gathered for two decades before rules were made, meaningful discipline for the farm sector might not arrive until the 2040s, by which time the sector will be even larger and harder to regulate.

To address this, the paper proposes four modest steps that could be taken within existing institutions without needing a new global treaty. First, countries should be encouraged to voluntarily report their aquaculture subsidies to a new committee, using a standard list of categories to make the data comparable. Second, the next round of negotiations, which must conclude by 2029 to keep the agreement alive, should include a clause requiring a review of how farm subsidies affect wild fishing. Third, countries could change their own domestic rules to make their aid to fish farms conditional on the feed not coming from overfished or illegal stocks, effectively extending the ban on harmful fishing down the supply chain. Finally, the committee should clarify the definitions so that any support tied to the quantity of wild fish caught or bought is treated as a fishing subsidy, regardless of what the scheme is called.

The paper concludes that the new agreement was negotiated for a world where wild fishing was the primary source of seafood, but it entered into force in a world where farms supply the majority. A treaty that disciplines the catching of wild fish while ignoring the sector that turns a large part of that catch into feed is open to circumvention that no one will be able to measure. Bringing the farm sector into view through better reporting and review is a necessary step to ensure that the global effort to protect the oceans is not undone by the very industry meant to help it. The author argues that fixing this blind spot now is far cheaper and easier than waiting until the subsidies are deeply embedded in farm businesses and the political groups that defend them have become too powerful to change.