In 2024, we launched the Worker-Driven Social Responsibility Pilot in fishing in the UK, to meaningfully improve the protection of rights and working conditions of migrant workers in fishing. Moving into 2026, we mark the conclusion of this pilot, looking at the challenges it has faced, the learnings from this work, and what comes next for migrant fishers’ advocacy in the UK.

The Challenges 

The UK fishing context presents unique challenges to efforts to build migrant worker orientated social responsibility projects. For one, the UK has a specifically and notorious hostile environment, with almost complete anti-migrant political consensus. This has grown in recent years, with the future looking only more grave. The UN and other international bodies have consistently raised concerns and criticisms about the UK’s compliance with international law regarding the wellbeing of migrant workers. There are, therefore, structural factors that make centring migrant workers an exceptionally steep uphill battle in the UK, even by the anti-migrant standards seen across much of the global north.

Migrant fishers face a particular and exacerbated form of this generalised hostile environment. UK fishing vessels that operate outside of UK territorial waters do not have to comply with work visa rules to employ migrant fishers. Instead they can rely on an exemption, where fishers are given a Code 7 (contract seamen) stamp which permits them to enter the UK to join a ship which will leave the UK in a ‘reasonable amount of time’. This stamp, effectively a transit loophole, is intended for seafarers to pass through the UK to join their ship. The Code 7 stamp does not provide seafarers with the right to stay or work in the UK itself, meaning that migrant fishers on a Code 7 stamp who fish inside UK waters are in breach of the immigration rules. The use of Code 7 in this context therefore excludes migrant fishers from even the most basic of employment law protections in practice, such as the national minimum wage.

What’s more, there is no UK labour market enforcement at all for these workers, even if they are employed by UK companies, working on a UK flagged vessel and selling into the UK supply chain. 

These challenges could be surmounted through public, private and third sector cooperation. However, the fishing industry and retailers have not taken sufficient action. In practice the stated interest to address these problems has yet to be realised. As industry recognises themselves, they are reliant on such labour, and that without migrant workers the boats don’t leave ports for months. In other words, regardless of any intentions, the cheap precarious migrant labour that the Code 7 loophole facilitates is keeping the industry afloat. The fishing industry is facing major challenges; for as long as Code 7 facilitates cheap, unregulated labour, employers will be compelled to utilise it or face being squeezed out. 

The changes workers need remain impossible without systemic change. Those changes must include addressing how Code 7 is instrumentalised in the sector; no corporate-driven social responsibility project will be effective whilst the loophole remains misused to drive up profit margins at the cost of workers’ rights and safety. Regardless of any ongoing initiatives to bring migrant workers’ rights to the forefront in fishing, this widespread dependency of industry on Code 7 can only be interrupted in the policy environment, through governmental action.

It is also clear that no matter what policy changes happen, industry needs an independent, worker-driven mechanism in order to have something that is safe, effective, and trusted thereafter. Having such a mechanism would also protect the industry from reputational risk, by facilitating meaningful change for workers.

This pilot has therefore uniquely demonstrated the essential need to address the  loophole and raise the baseline of rights for migrant fishers, and allow consistent organising and communicating with them to become feasible. 

Without meaningful industry cooperation, the strain placed on the organisations within the partnership were exacerbated, contributing to its conclusion. This one-sided engagement placed significant capacity burdens on our organisations. Worker-Driven Social Responsibility projects are ambitious by any international standard, and the demands on partners were high in a landscape of increasingly limited resources, alongside widening and deepening fronts of worker struggle and advocacy. An organisation like ITF, responsible for the worker-facing side of the pilot, has only less resources and more demands placed on it in the current context, including facing a restructure across the whole organisation that shows the problem goes further than fishing. 

What next? 

The pilot generated essential, valuable learning that will strengthen future worker-driven initiatives. We are moving forward, building on the relationships and analyses the pilot has gifted to us, and using them to hone our focus in the months and years to come. 

We know for a fact that the Code 7 loophole must be closed in order to raise the baseline standard of migrant workers’ rights and conditions in UK fishing. Fishers should not be punished for their employers’ improper use of this transit loophole to employ them. To end the misuse of the transit loophole, fishers inside the UK need a visa which recognises them as workers and enables them to access their rights in practice. We will continue to expose the problems of the misuse of the Code 7 loophole to policy-makers, with a view to replacing it with a better alternative as a matter of urgency. 

This presents an opportunity; with this single government action, the wellbeing of migrant fishers could be drastically improved. What’s more, the political consensus that this loophole must be closed is only growing, as attention is driven towards the issue. The pilot has played no small part in brightening this spotlight.

As we move forward, our partnership remains committed to fighting for migrant fishers in the UK. FLEX and partners will continue to drive for systemic change, producing reports analysing the state of the industry, the risks faced by migrant fishers every day, and findings from the pilot, whilst engaging policy-makers directly to push for vital change in policy. ITF is developing a buyers and regulators Code of Conduct with and for migrant fishers.The Fair Food Program will continue to implement Worker-Driven Social Responsibility programmes internationally, and continue to prove that meaningful change for workers is possible through new, innovative models.

Co-written by Focus on Labour Exploitation (FLEX) and International Transport Workers’ Federation (ITF).