The Fisheries Transparency Initiative (FiTI) took it upon itself to publish an uninvited assessment, against its own standards, of three countries that have hosted me and trusted my work over the last decades: Kiribati, the Marshall Islands, and Papua New Guinea. This publication came as a surprise, since none of the countries knew it was coming… so it feels like an ambush.
Where I stand
I have supported what FiTI stands for for many years. Transparency is important; people should know who fishes their waters, what a country earns, and whether management works.
My problem with Taking Stock isn't its principles, but its method: an uninvited, desktop grading of three young states that haven't engaged with FiTI, published without their knowledge and presenting their flags beside red crosses.
I’m happy to declare my position and alliances. I currently work as Offshore Fisheries Advisor to MIMRA, and I have worked on many aspects of RMI's documentation, which has been positively assessed, as well as many areas where information is shared through regional networks, similarly in Kiribati and PNG in prior years. So I am not neutral; these countries are full of dedicated people who care about their fisheries, work very hard, and understandably don't take it well when outsiders mould public opinion about their countries without at least asking them first. That is also why I think this move by FiTI will backfire on them.
The German Federal Ministry for Economic Cooperation and Development (BMZ) funds the report, FiTI researchers write it, and one consultant reviews it. No government official from Kiribati, RMI, or PNG appears among the researchers or reviewers, and the report says it conducted no national stakeholder verification.
Uninvited, graded and published
The report admits that none of the three countries engaged with FiTI and that it relies entirely on desktop research without national verification. Then it grades them anyway, requirement by requirement, with traffic-light icons next to national flags. A caveat in a grey box on page 3 does not undo 30 pages of red crosses.
FiTI's own model is built on national multi-stakeholder groups and country commitment, with progressive improvement as a stated principle. Here, the Standard is applied to countries that never signed up. That reverses the process FiTI asks of its members and turns a voluntary standard into an external audit.
The choice of countries also matters. Why these three and why now? The report does not say. Officials in Majuro, Tarawa, and Port Moresby will ask, and they will assume the answer won't be flattering.
A disclaimer that disclaims the report
The disclaimer on the inside cover is strange and, frankly, a bit cowardly. It demands accountability from others while the report denies it.
"Every effort has been made to verify the accuracy." Except the obvious one: asking the three governments. An email to MIMRA, MFOR or NFA would have been the cheapest verification available. Without it, "every effort" means every effort that could be made from some desk who knows where.
"FiTI did not investigate the veracity of the published information and did not make any judgement about the integrity of the information or practices disclosed." That is hard to square with the rest of the report. Rating information as "not disclosed" is a judgement about practices: it says a government chose to withhold. Saying PNG's fines "fall well below" its laws, or that RMI's shark data shows a "learning deficit", are judgements about integrity. You cannot grade governments for 30 pages and then say you made no judgements.
FiTI "cannot accept responsibility for the consequences" of others using the assessment. The consequences of publicly rating sovereign states fall on those states: on their reputations with donors, markets and the EU carding system. They were not asked, and FiTI takes no responsibility for what follows. The risk is placed entirely on those who had no say.
The views are those of "the independent external experts (i.e. Fisheries Transparency Initiative)". FiTI owns the Standard being applied. Calling itself an independent external expert on its own Standard is an odd use of the word. Meanwhile, the German BMZ, which paid for it, also steps back from the content. So, the funder doesn’t own the views, the authors don’t own the consequences, and the subjects were never consulted.
"We would like to thank all those who contributed." No one is named, and the report says no national stakeholders were involved. It is a thank-you to unnamed people for a process that, by design, excluded the people it is about.
An organisation that exists to promote transparency and accountability should be the first to stand behind its work, name who contributed, and own its judgements.
Young states, small administrations, no communication budgets
Kiribati became independent in 1979, RMI adopted its constitution in 1979, and entered the Compact Agreement in 1986; PNG became independent in 1975. These are states roughly 40 to 50 years old, with fisheries agencies still younger. Comparing their online document trails with ministries with centuries of archives and dedicated communications units is not a fair test.
In practice, the MIMRA or MFMRD "website" is often maintained by someone whose real job is data management, coding, information management systems, but also fixing printers, setting up Zoom calls, rushing to switch to Starlink when the internet (or power) shuts off…. They don’t have a budget line for a communication strategy, let alone for digitising and hosting every regulation. When a document is "not publicly available", the usual reason is that nobody has had the time, money or server space to put it up, not that someone decided to hide it.
The report also judges transparency by one channel: what national authorities post online. That is not how most Pacific citizens get fisheries information. Most people access the internet via phones, and much information comes through radio, local government councils, church and community meetings, and processes like Reimaanlok, which the report itself describes. It devotes a box to customary tenure as the "front line" of coastal management, then ignores those channels when scoring disclosure.
FiTI's "principle of progressive improvement" exists precisely for this situation. It appears on page 4 and then is never applied. No rating asks where each country was five years ago, or what it has achieved with the staff it has.
"Not disclosed" is an accusation
The report defines "not disclosed" as information the government has but chooses not to make public. That is a claim about intent. You cannot establish intent from a desktop, and nobody asked the governments concerned.
The distinction between "not disclosed" and "not available" is applied by guesswork. Coastal catch data is rated "not available" because it is "likely, though not confirmed" that none exists. Tuna catch data that appears in public WCPFC reports is rated "not disclosed", even though the same governments produced and submitted it. A country that reports to the regional body it helped build gets a red cross; one with no data gets a softer blue icon.
In the Pacific, being publicly labelled as withholding information is not a technical observation. It reads as an allegation of bad faith. Given that the conclusion itself states that the absence of information, not concealment, is the dominant finding, the red crosses send a message that the analysis does not support.
Regionalism read as a deficit
The most successful move these countries have made in fisheries is pooling sovereignty: SPC, FFA and PNA. Small administrations deliberately delegate data, science, vessel registers, and MCS to regional bodies they own and govern. The report treats this as a weakness, saying regional reporting "serves the interests of external audiences rather than citizens". I think that misreads forty years of Pacific fisheries history predating UNCLOS…. Go to a PNA meeting and see if you find “external audiences”
The report quotes the 2050 Strategy for the Blue Pacific Continent to justify its democratic framing. That same strategy is, above all, a statement of regionalism. Using it to criticise reliance on regional systems is selective reading.
Three specific examples:
VDS fee confidentiality. Bilateral day prices are kept confidential because they are commercial negotiations in which PNA members compete with, and coordinate against, very large distant-water fleets. Publishing each country's deals would weaken the collective bargaining position that turned access fees into the region's main source of fisheries revenue. The report confirms that RMI has published aggregate revenues in its annual reports for decades. This is a strategic choice, not a failure of accountability.
Vessel registers. The report rates all three as "not disclosed" because no national register is online, then notes that the WCPFC record exists (and is freely available). Authorisations to fish in member EEZs run through the FFA register of vessels in good standing and PNA systems that these countries designed. A national copy would add duplication, not accountability.
IUU baselines. The report says no country has published a baseline estimate of IUU fishing. The region did exactly that twice, through the FFA-commissioned quantification of IUU fishing in the Pacific Islands region (2016, updated 2021), which I helped with. It is regional, because the fishery is.
The report is right that regional data is often not translated back for national audiences. But the remedy is to support that synthesis, not to score countries down for having built the regional system in the first place.
Reading their own evidence
Several of the report's sharpest claims do not survive contact with its own pages. Talking to the agencies first would have helped most.
RMI shark bycatch. The conclusion presents the jump in reported silky shark catches (10 t in 2020 to 630 t in 2024) and blue shark (13 t to 408 t) as "the learning deficit in its clearest form". Yet page 33 reports that MIMRA's observer coverage rose significantly, longline electronic reporting passed 90% in 2023, and a port sampler covers nearly all longline unloadings. A rise in reported bycatch alongside a rise in monitoring first suggests monitoring works. The report lists "better reporting" as one possibility, then uses the figures as its headline example of failure anyway.
Climate and tuna. The report says all three countries expect catches to decline. Regional projections point to an eastward shift in tuna biomass. For Kiribati, with its eastern EEZs, that may mean more tuna in its waters, not less. The "production vs decline" inconsistency is less clear-cut than presented.
Internal inconsistencies. The conclusion refers to an "Observation 3" in a section with no numbered observations. Small things, but they matter in a report about the accuracy of other people's information.
The neocolonial pattern
In 2023 I wrote about ecolabels and labour certification as agents of neo-colonialism, drawing on work that compares transnational certification with colonial-era extraterritoriality. That analysis identified three shared features: subjects who need protecting, a narrative of the local state as inadequate to protect them, and an outside actor that claims the authority to judge.
Taking Stock fits that template more closely than I expected (and I suspect its authors would like). The subjects are Pacific citizens, whose right to information the report defends on their behalf.
The narrative is of deficient states: fragmented, outdated, silent. And the authority is a foreign-funded standard applied to countries that never adopted it. Like certification schemes, it does not directly challenge state sovereignty. It accepts national law and policy, then claims the right to assess whether governments live up to them, and to publish the verdict.
The report's best section asks "Whose transparency agenda?". It correctly argues that the gaps that matter are not the ones international advocates focus on. But it never turns that question on itself. A German ministry funded an organisation outside the region to rank three Pacific states that had not asked for it. Whose agenda is that?
I do not think anyone involved intended this. But in this region intentions are read through method, and the method here is the familiar one: assess from outside, publish, embarrass, then invite engagement.
Trust is the currency, and this spends it
I believe that trust is the most underrated currency in our line of work, and in the WCPO it is the one that decides whether anything happens. It is built slowly, through invitation, presence, talanoa, and by being useful before being critical. I have seen good ideas die in this region because they arrived as a verdict rather than an offer.
Taking Stock's stated purpose is to start national debates and, presumably, bring these countries toward FiTI. I fear it will do the opposite. The officials who would champion FiTI internally are the same ones whose work is now publicly marked with red crosses. The likely response is defensiveness, and the easiest decision is to keep FiTI at arm's length.
The same evidence could have built trust instead. A different method would have:
Asked first. Approached MIMRA, MFMRD and NFA, and regional bodies like FFA and PNA, before starting the assessment, and offered the study as a service.
Shared the draft for factual review, with a right of reply printed alongside the findings.
Dropped the "not disclosed" rating unless a government confirmed it holds the information and chooses not to publish it.
Credited regional reporting as a national effort, and focused the critique on translating that data back to citizens.
Applied progressive improvement: what each country has achieved, and with what staff and budget.
Offered something concrete, such as funding a part-time communications officer or a document repository, rather than only a diagnosis.
Many of the report's substantive points can be seen as positive. FiTI could have led those conversations with my Pacific colleagues in those 3 fisheries organisations before publishing a public scorecard that the people they are claiming to help… never asked for.