Halt the gulper shark fishery: an open letter to President Muizzu

   

We have carefully reviewed the draft management plan and regulation and concluded that the proposal would provide minimal benefits to a small number of actors while causing irreversible harm to local populations of gulper sharks and to fishers who rely on a healthy ocean for their livelihoods, as well as to the tourism sector that underpins the Maldivian economy.

Gulper sharks are intrinsically vulnerable to overexploitation. Their slow growth and reproductive rates, and the restricted availability of suitable habitats in Maldivian waters create a population dynamic that cannot sustain fishing pressures. The historical record in the Maldives shows a rapid boom-and-bust for this fishery, with collapses occurring within only a few years, and there is no scientific evidence that populations have recovered from the estimated 97 percent decline caused by overfishing in the past. Given the limited habitats, any remaining stocks are likely small and unable to withstand renewed exploitation.

All three gulper shark species present in Maldivian waters are listed as Endangered on the IUCN Red List. Without a stock assessment, or at minimum a precautionary, multi-decade recovery projection, reopening this fishery is both scientifically unsound and contravenes with the Fisheries Act’s requirement to apply the precautionary approach and manage resources using the best available science.

The Fisheries Act also requires broad participation by Maldivians in decisions affecting fisheries resources and mandates participatory decision-making, good governance and transparency. It is therefore deeply troubling that the ministry appears not to have conducted meaningful consultations with key stakeholders, including local tuna fishers, tourism operators, civil society organisations and independent fisheries or shark scientists. No public records exist of who was consulted, the substance of those consultations, or any socio-economic impact assessments. Media reporting indicates that stakeholders consulted in Haa Dhaalu Kulhudhuffushi – including fishers – did not support this fishery. Independent polling by Blue Marine Foundation, Maldives Resilient Reefs and the Miyaru - Shark Programme (October 2025; n=1,000) found 77 percent of Maldivians opposed to resuming this fishery. More than 19,000 local and international signatories have added their names to petitions urging the government to abandon this proposal.

Reinitiating the gulper shark fishery also poses substantial legal and market risks. If gulper sharks are listed on CITES [Convention on International Trade in Endangered Species] Appendix II at the upcoming COP20 meeting in November- December 2025, exports of any gulper shark and their derivatives would require a scientifically grounded Non-Detriment Finding (NDF) as well as catch and trade quotas. In the absence of current stock data, and given past population collapses within only a few years, obtaining a positive NDF for sustainable international trade is highly unlikely.

Fishers who invest to reinitiate this fishery would therefore risk severe financial losses once CITES measures take effect, as resulting trade restrictions could render their operations economically unviable. Continued exports under these conditions would risk non-compliance with CITES and could trigger a Review of Significant Trade process, potentially leading to trade suspensions or export bans. This outcome would expose fishers and exporters to regulatory uncertainty and stranded investments. As Environment Minister Thoriq Ibrahim noted at the launch event of the Global Coalition to Halt the Extinction of Threatened Sharks and Rays at UNOC3 (Nice, 2025), the Maldives has committed to a comprehensive shark sanctuary – an international conservation stance that would be compromised by non-compliant trade.

The proposed management measures themselves are inadequate. They include no phased fishing effort, no vessel-level catch or effort limits, and no clear, independently verifiable system to monitor and account for bycatch, despite acknowledging that other shark species have historically been taken by longline gear. As a vertical bottom-set longline fishery using baited hooks, this fishery would inevitably cause substantial bycatch of other sharks, including silky sharks (crucial for the Maldives’ one-by-one tuna fishery) and other threatened pelagic sharks that underpin the growing dive industry. Given the Maldives’ geographical dispersion, previous management plans have proven difficult to implement and enforce, raising serious doubts about the practical feasibility of effective monitoring, control and surveillance under the proposed framework. The advisory board’s composition consisting of only a single conservation representative fails to provide the independent scientific scrutiny or stakeholder balance necessary for responsible governance.

In light of the scientific, socio-economic, and governance concerns outlined above, the undersigned organisations and experts respectfully recommend the government of the Maldives to:

The [signatory organisations and scientists] stand ready to support science-based measures that protect marine biodiversity, safeguard livelihoods, and preserve the Maldives’ tourism reputation. The nation’s well-being and the sustainability of its world-class tuna fisheries depend on healthy, biodiverse, and resilient oceans. We urge you to act now to prevent irreversible harm.