Brexit trade deal: Who really owns UK fishing quotas?
Foreign companies own the rights to catch more than 130,000 tonnes of fish every year that are part of England's fishing quota, BBC research has revealed.
More than £160m worth of the English quota is in the hands of vessels owned by companies based in Iceland, Spain and the Netherlands, thanks to a practice known as "quota-hopping".
That amounts to 55% of the quota's annual value in 2019.
Taking back control of UK fishing waters was a key issue for many Brexit supporters.
But with fishing still an obstacle in the UK's trade talks with the European Union, the figures raise questions about what taking back control will actually mean.
Quotas play crucial role
Quotas are at the heart of heated debates about fishing on both sides of the English Channel.
Many countries use them to manage shared fish stocks. They determine how many fish of each species each country's fleets are allowed to catch.
The EU's Common Fisheries Policy (CFP) sets quotas among EU member states, and similar deals are negotiated with neighbouring countries.
The UK government says becoming an independent coastal state after Brexit will give it the right to decide "who fishes in our waters and on what terms".
But, as this research confirms, a significant portion of the existing UK quota is already in foreign hands.
Scotland, Wales and Northern Ireland all have their own quotas, each with different degrees of foreign ownership.
'More UK economic benefit'
Under plans outlined in the Fisheries Bill, which is currently going through Parliament, the government does not intend to return the foreign-owned quota to UK fishermen.
It has said only that it is "reviewing…with a view to strengthening the rules" surrounding foreign ownership of UK-flagged boats.
Current rules say even if vessels are 100% foreign-owned, they must have an "economic link" to the UK. That means they must meet one of five conditions, which include landing more than half their catch at UK ports or having majority British crews.
In March, Environment Secretary George Eustice said planned changes under the Fisheries Bill will ensure foreign-owned boats "are required to land more of their catch in UK ports, and return more economic benefit to the UK".
He added: "In future any foreign company that wanted to buy vessels in the UK might well be able to, but it would be subject to that new condition."
For many in the fishing industry that does not go far enough.
"I'm alarmed at how bad the level of foreign ownership really is - it far exceeds my worst expectations," said Paul Lines, from Fishing for Leave, a pro-Brexit group within the British fishing industry.
"I fear government action will change nothing, and we're still going to be dominated by a foreign presence."
Fishing for Leave wants to change the rules so all British fishing vessels must be "60% British-owned; 60% British-crewed; (and must) land, process and sell 60% of their catches in Britain".
But Dr Emma Cardwell, from the University of Glasgow, told the BBC that an enforced change in ownership would be "legally tricky" for the government.
Many parts of the quota were sold by English fishermen in the 1990s when fishing rights were cut dramatically. Cod fishing, for instance, was almost entirely stopped for several years.
Foreign companies then bought it up as a long-term investment, and experts say the quota market has been allowed to develop in an unregulated way ever since.
"There's a lack of clarity on the legal status of fishing rights," Dr Cardwell said, "meaning the government is very vulnerable to litigation if it tries to reallocate quota.
"Any foreign fishing companies that purchased UK quota in good faith would be very likely to sue if this was now taken away from them."
Devolution makes a difference
As fishing is a devolved policy, the way the quota is managed differs around the UK.
England and Wales, where a majority voted for Brexit, have both allowed foreign ownership of more than half their fishing quota.
In Wales, which is allocated a tiny share of the UK quota, the figure is as high as 85% of the annual value - most of it held by one big industrial trawler.
But in Scotland, which is responsible for about 60% of the UK quota, only 4% of the annual value in 2019 was in foreign hands. In Northern Ireland the figure was 2%.
"The Scottish fishing industry is largely made up of family-owned businesses," said Elspeth MacDonald, from the Scottish Fishermen's Federation.
"These businesses have developed the industry during the good times and have had the desire and resolve to hold on through difficult times, when others have not."
The figures obtained by the BBC, in collaboration with the New Economics Foundation (NEF), reveal that a fifth of the annual value of the UK's overall quota is held by foreign-owned companies. The total annual value is just over £900m.
And there will be nothing to stop those foreign-owned companies acquiring more in the future.
"Even if the UK government is able to negotiate a bigger share of the quota for UK vessels, companies based in EU countries could simply buy more of them if they wanted to," explained Griffin Carpenter, fisheries expert at NEF.
Elsewhere in Europe the level of foreign ownership varies.
In Belgium, the figure is just over a quarter, but other EU countries have much stricter rules.
There is very little foreign ownership in France and Ireland for example, and in two countries outside the EU that have big fishing fleets - Iceland and Norway - there is no foreign ownership at all.
Fishermen who want similarly strict restrictions in the UK after Brexit could be disappointed.
"The government really needs to sharpen up on what they want to achieve in these negotiations," said Mr Lines.
"If nothing's going to change, the whole Brexit scenario is a lie. If English fisherman don't benefit from this, it's been a pointless exercise for us."
Our research suggests that taking back much greater control could mean buying back fishing quota.
That would come at quite a cost, which the government doesn't currently seem prepared to pay.
The alternative is, at best, a halfway house.
"Forcing UK vessels to land more here, only for it to be trucked out of the country, provides us with landing dues and truck pollution," argued Terri Portmann, a marine consultant based in Plymouth.
"Ministers need to be more ambitious," she said, "supporting ports and businesses to build the facilities we need not just to land fish, but to process and sell it here."
In response to the findings, a spokesperson for the Department for Environment, Food and Rural Affairs said "after the transition period we will have the right to decide who fishes in our waters and on what terms.
"Any decisions about giving access to fish for vessels from the EU, or any other coastal states will be a matter for the UK to decide. During the transition period, we will abide by the existing rules.
"As a responsible independent coastal state, we want our fisheries managed in a way that the rest of the world will want to follow - one that protects our precious marine and coastal areas while enabling our seafood sector to thrive."