Photo by Maja R
Scotland’s Rural Affairs and Islands Committee has sharply criticised the Scottish Government for failing to deliver urgent reforms to salmon farming regulation, warning that progress since its 2025 inquiry has been “disappointing.” In a letter sent to Cabinet Secretary Mairi Gougeon on 25 March, signed by Convener Finlay Carson MSP, the Committee states: “Overall, the Committee is disappointed that across key areas of its inquiry recommendations, progress in future-proofing the salmon farming industry has not occurred with the urgency called for one year ago.”
The letter is direct about where it considers government to have fallen short. The Committee says it “does not agree with the analysis of the Scottish Government” that persistently high mortality at salmon farms does not represent a systemic issue, and warns that “without meaningful actions to enhance the performance of the industry with regards to mortality, the Scottish Government risks eroding public confidence in this important sector.”
Mortality reporting and data gaps
A central frustration for the Committee is the government’s refusal to introduce mandatory mortality reporting. The letter states that mandatory reporting “would not be overly burdensome for producers and regulators” and questions whether the government has “fully considered the potential benefit of comprehensive mandatory reporting in preventing misinterpretation and improving public confidence and trust.” The Committee notes that industry already collects this data, and that transparency could “strengthen reputation for transparency amongst consumers and the wider public.”
The inadequacy of existing data has been thrown into relief by independent research. Freedom of information data obtained by Animal Equality revealed that Scottish salmon farms reported more than 35 million unexpected fish deaths between January 2023 and October 2025, while regulators inspected just 21 of 213 active sites in the same period — with none of the 20 worst-performing sites receiving any inspection at all. Analysis by The National has identified what it describes as a “glaring flaw” in official figures, with more than 17 million deaths going uncounted. Separately, research published by The Ferret found that at least seven million cleaner fish — wrasse and lumpfish used to graze sea lice from farmed salmon — have died since 2020, a toll described by campaigners as “a colossal waste of life.”
Sea lice, wild salmon and planning
The committee letter is equally critical on the protection of wild salmon. It notes that SEPA’s revised sea lice risk framework remains subject to live legal proceedings, meaning the Committee cannot assess its effectiveness, and that “there appears to be no contingency measures in place to mitigate sea lice risk while progress on implementation is on hold.” It calls on the government to set out “as a matter of urgency, what interim measures it intends to put in place to mitigate sea lice risk to wild salmon during the period in which the framework remains subject to legal challenge.”
On planning, the letter notes there has been “little, if any, progress” on facilitating farm relocation to improve fish welfare and mitigate environmental impacts, despite the Committee having previously requested this be treated as urgent. It does, however, welcome recent regulations extending marine planning zones from 3 to 12 nautical miles, which it says should make it easier to site farms in more exposed, offshore locations.
The government’s position
Gougeon gave evidence to the Committee on 11 March, presenting preliminary research from the Scottish Government’s Marine Directorate concluding that persistent elevated mortality is “not a widespread issue” and that no new regulation was needed. She said: “We will now look at building on these foundations to continue to improve fish health and welfare and ensure the continued sustainable development of the Scottish salmon sector.”
Calls for a moratorium
Conservation organisation WildFish said the committee letter amounted to a near-moratorium recommendation in substance if not in name. Nick Underdown, Scotland Director at WildFish, said: “This is a significant milestone. The Committee has practically confirmed that the regulatory system remains dysfunctional and ineffective. When a parliamentary committee acknowledges ongoing environmental harm, progress stalled in the courts and a lack of effective controls, the logical conclusion is hard to avoid: our planning authorities should not be allowing further expansion of salmon farming. While the Committee stops short of explicitly calling for a moratorium, it has come very close to doing so in substance.”
Underdown added: “The next Scottish Parliament must take this forward with urgency. At a minimum, that means a halt on new developments. Longer term that will require planning a responsible transition away from salmon farming in Scotland’s coastal waters. In the meantime, we will continue to expose the industry’s shameful environmental record and campaign towards such a transition.”
The committee’s letter concludes by calling on the Scottish Government to set out a clear work plan at the start of the next parliamentary session to deliver its recommendations — with Scottish elections imminent, the issue looks set to feature prominently in the campaign ahead.