Navigating Conditions of Certification in MSC Fisheries Audits

What the requirement is, and why it exists

Under Section 7.16 of MSC Fisheries Certification Process v2.3 and v3.0, a Conformity Assessment Body must set one or more auditable conditions of certification if a Unit of Assessment scores between 60 and 79 on any individual Performance Indicator. Clause 7.16.1.1 mandates that every Performance Indicator receiving a score below 80 requires its own distinct condition. Clause 7.16.2 dictates that conditions must be drafted to follow the narrative or metric form of the Performance Indicator Scoring Guideposts used in the default assessment tree.

Conditions exist to drive measurable, outcome-oriented performance improvements against the MSC Fisheries Standard during the certification cycle. Under clause 7.16.3, each condition must be structured to raise fishery performance to at least the SG80 level within a period specified by the assessor, not exceeding the five-year term of certification. These requirements apply directly to fishery certificate holders, compliance leads, quality managers, and internal auditors who oversee certification maintenance. Establishing structured conditions ensures target stock sustainability, minimizes marine ecosystem impacts, and reinforces management system accountability.

Designing compliant Client Action Plans and securing third-party support

Developing a robust Client Action Plan represents the fishery client's central obligation for addressing certification conditions. Under clause 7.19.6, the Conformity Assessment Body allows 60 days after receipt of the Client and Peer Review Draft Report for the client group to formulate its action plan. Although utilizing the official MSC Client Action Plan Template is optional, clause 7.19.7 establishes that every action plan must fulfill mandatory content requirements to gain assessor approval.

• Review the narrative condition statement and annual milestones established by the assessment team in the draft assessment report.
• Formulate specific operational, management, or scientific actions designed to achieve each milestone within defined timeframes.
• Assign clear organizational roles and responsibilities for executing each planned activity across participating client group entities.
• Define the concrete outputs, technical reports, or objective data that will be submitted to auditors at each surveillance audit.
• Secure formal written commitments from any external authorities or research institutes whose resources or regulatory powers are required to implement planned actions.

Where condition closure relies upon external entities such as government fisheries departments, scientific research agencies, or enforcement bodies, stringent verification rules apply. Under clause 7.19.8, the Conformity Assessment Body must not accept a Client Action Plan that relies on third-party involvement without verifying whether condition closure requires financial investment, regulatory amendments, or altered research priorities. Clause 7.19.9 mandates that if the assessor cannot verify that necessary external funding or resources are committed, the Unit of Assessment shall not be certified.

Surveillance auditing, behind-target findings, and remedial action plans

Annual surveillance audits evaluate whether the certified fishery maintains standard compliance and achieves scheduled condition milestones. Under clause 7.29.16.1, the assessment team evaluates progress against conditions using the narrative or metric form of the original condition. The team must formally document whether progress is on target, ahead of target, or behind target, providing clear written justification for its judgment in the surveillance audit report.

If operational activities or expected results fall behind the schedule defined when setting the condition, Guidance G7.29.16.1.b requires the team to classify progress as behind target. Under clause 7.29.16.1.b.i, when a behind-target finding occurs, the Conformity Assessment Body may specify remedial action and revised interim milestones. The remedial plan must bring progress back on target within 12 months without extending the original condition deadline or overall certification term.

Example

A purse seine fishery holding certification under MSC Fisheries Standard v2.01 receives a condition on Indicator 2.3.1 due to insufficient quantitative data on sea turtle interactions. The Client Action Plan specifies that by Year 2, the client group will deploy an electronic vessel logbook system and achieve 20 percent independent observer coverage across the fleet. At the Year 2 surveillance audit, the assessment team notes that electronic logbooks were deployed, but observer coverage reached only 8 percent due to vessel scheduling delays.

The assessment team formally designates condition progress as behind target under clause 7.29.16.1.b. Applying clause 7.29.16.1.b.i, the Conformity Assessment Body specifies a remedial action plan requiring the client to contract supplementary observers to achieve 30 percent coverage during Year 3. This revised milestone ensures that cumulative observer data catches up to original targets, bringing the condition back on target within 12 months without altering the Year 4 final closeout deadline.

Certificate suspension, withdrawal, and re-entry prohibitions

Failing to correct a behind-target finding triggers severe contractual and certification consequences. Under clause 7.29.16.2, if the Conformity Assessment Body determines that progress is not back on target within 12 months of falling behind, progress is considered inadequate. Inadequate progress mandates immediate application of certificate suspension or withdrawal procedures set out in Section 7.4 of the MSC General Certification Requirements v2.7.

Under General Certification Requirements clause 7.4.3.b, the Conformity Assessment Body shall suspend a fishery certificate when adequate progress towards conditions is absent. Clause 7.4.4 establishes that the effective suspension date takes effect 30 days after the decision, requiring the client to submit an acceptable corrective action plan within 90 days. Under clause 7.4.4.h, if the client fails to submit an acceptable plan within 90 days, the assessor must withdraw the certificate permanently.

Crucially, clause 7.29.16.2.c and Guidance G7.29.16.2.c establish a strict re-entry prohibition following condition-related suspensions. A fishery client whose certificate is suspended or withdrawn due to inadequate condition progress cannot enter the same Unit of Certification, or any participating entity, into full assessment under the same or an alternative name. This rule prevents clients from circumventing expired condition deadlines by attempting to restart assessment cycles afresh.

Before your audit

• Review all Performance Indicator scores below 80 and verify that each has a distinct condition assigned.
• Confirm that the Client Action Plan contains detailed activity descriptions, assigned roles, and measurable outputs.
• Obtain signed letters of commitment from any government bodies or research institutes supporting condition closure.
• Conduct an internal pre-surveillance audit to verify progress against scheduled interim milestones.
• Assemble all technical reports, observer logs, and regulatory filings required as milestone evidence.
• Check whether any open condition was marked behind target at the previous audit and verify remedial action status.
• Confirm that product segregation protocols are maintained in case of potential audit escalation.

Questions people ask

What score triggers a condition of certification in an MSC fishery assessment?

Under clause 7.16.1 of MSC Fisheries Certification Process v2.3 and v3.0, a Conformity Assessment Body must set a condition for any individual Performance Indicator that achieves a score between 60 and 79. Every indicator scoring below 80 requires its own distinct condition to raise performance to the SG80 level.

How much time does a fishery client have to prepare a Client Action Plan?

Under clause 7.19.6, the Conformity Assessment Body should allow 60 days following receipt of the Client and Peer Review Draft Report for the client to formulate its Client Action Plan. If additional conditions are added following peer review, clause 7.19.11 allows up to an extra 30 days to update the plan.

What happens if progress on an MSC condition is marked as behind target?

Under clause 7.29.16.1.b.i, if progress is judged behind target, the Conformity Assessment Body may specify remedial action and revised milestones to bring progress back on target within 12 months. The remedial plan must ensure the original condition is fully achieved by its original deadline.

Can a fishery certificate be suspended for failing to make progress on conditions?

Yes, under clause 7.29.16.2 and General Certification Requirements clause 7.4.3.b, if a fishery fails to bring a condition back on target within 12 months, progress is considered inadequate. The Conformity Assessment Body must suspend the certificate, taking effect 30 days after the decision.

Can a fishery re-enter assessment if its certificate is withdrawn due to open conditions?

Under clause 7.29.16.2.c, a fishery client whose certificate is suspended or withdrawn for inadequate condition progress cannot enter the same Unit of Certification, or any entity within it, into full assessment under either the same or an alternative name unless the cause for suspension is fully addressed.

Reference documents

• MSC Fisheries Standard v2.01
• MSC Fisheries Standard v3.0
• MSC Fisheries Certification Process v2.3
• MSC Fisheries Certification Process v3.0
• MSC General Certification Requirements v2.7