North Korea’s fisheries law and cross-border fisheries governance: a doctrinal assessment of domestic control and regional transparency

Abstract

Large-scale illegal, unreported, and unregulated (IUU) fishing in waters claimed by the Democratic People’s Republic of Korea (DPRK) has been documented mainly through satellite analysis and sanctions-enforcement studies. However, these approaches reveal little about how the DPRK’s own law structures authority, access, inspection, and legal responsibility. This article uses doctrinal legal analysis to examine the DPRK Fisheries Law using the accessible 2015 and 2022 consolidated texts, the 20 May 2025 amendment—used as a confirmatory and contextual extension—and the broader amendment history reflected in earlier legal materials. The statute is assessed across four governance pillars—conservation and sustainable use; monitoring, control, and surveillance; access authorization and foreign-vessel control; and sanctions and deterrence—against differentiated benchmarks drawn from the United Nations Convention on the Law of the Sea, the Port State Measures Agreement, the FAO Code of Conduct for Responsible Fisheries, and fisheries-related UN sanctions. The 2015 and 2022 texts show partial alignment in conservation planning, protected-resource management, and formal authorization, but persistent gaps remain in monitoring infrastructure, inspection traceability, foreign-access transparency, and cooperative information sharing. While the 2025 amendment confirms a further move toward denser domestic legal responsibility, including direct stoppage measures, steeper fines, and a more differentiated sanction ladder, it lacks a parallel advance in monitoring or transparency. The DPRK framework therefore operates more as an instrument of domestic administrative control than as an integrated component of regional fisheries governance. By grounding this conclusion in the statute’s own internal evolution rather than in vessel-behavior evidence alone, the article provides a more comprehensive legal baseline for future research on fisheries governance in sanctioned, low-transparency settings.

1 Introduction

Recent satellite-based studies have identified large-scale illegal, unreported, and unregulated (IUU) fishing by vessels of Chinese origin within the maritime zones claimed by the Democratic People’s Republic of Korea (DPRK) (Park et al., 2020). Those operations have been linked to squid depletion, large-scale unauthorized catch, and the displacement of DPRK small-scale fishers into Russian and Japanese waters, situating the issue at the critical intersection of fisheries governance, sanctions enforcement, maritime security, and food supply (Park et al., 2020; Hastings and Song, 2022).

This empirical literature is important, but it leaves a fundamental question underdeveloped. Satellite observations can reveal vessel behavior, and sanctions analysis can identify external prohibitions, yet neither can by itself explain how the DPRK’s own Fisheries Law allocates authority, structures fishing permissions, organizes inspections, or articulates legal responsibility. In a low-transparency system, domestic law serves as one of the few stable primary sources through which the internal design of governance can be reconstructed with some precision.

This analytical omission matters because cross-border fisheries governance is not built only on vessel detection. It also depends on legally visible rules about who may fish, under what authorization chain, with what monitoring requirements, and subject to what documentation and follow-up. Where domestic law remains opaque on those points, regional oversight becomes harder even as foreign surveillance, sanctions, or port-side scrutiny intensify. The legal visibility of domestic authorization, monitoring, and export control is therefore a marine policy question rather than merely an internal administrative matter.

The existing Korean-language scholarship provides valuable context but has not yet carried the doctrinal analysis this far. Cha (2010) outlined the basic structure of the DPRK Fisheries Law. Jin and Yoon (2019) examined fisheries policy under Kim Jong-un through an analysis of Rodong Sinmun. Chae (2021) traced administrative and budgetary directions in the fisheries sector. Cho and Jeong (2025) compared South and North Korean fisheries laws in the context of future inter-Korean cooperation. These studies effectively clarify policy directions, institutional changes, and comparative contexts, but they do not reconstruct the statute in sustained, provision-level detail as a framework for cross-border fisheries governance. Beyond this Korean-language scholarship, no prior English-language work, to the author’s knowledge, has systematically surveyed the DPRK’s full fisheries legal architecture as of 2026, a gap that reflects in part the well-documented difficulty of accessing DPRK statutory texts.

Accessible DPRK legal materials are uneven in form and reliability, and the source set, including translation choices and archival labels, is itself part of the analysis. The corpus and the specific sourcing problems associated with it are set out in Section 2.1. All translations from Korean are by the author unless otherwise indicated.

Much of the commentary on DPRK fisheries therefore oscillates between two key perspectives: dark-fleet activity and sanctions evasion on the one hand, and developmental or resource-administrative policy on the other. A close reading of the statute suggests why neither framing is sufficient. The same law that speaks of protection, resource creation, and scientific survey also speaks of permits, departure approval, inspection, and liability. Doctrinal analysis is needed to reveal how these elements are integrated and where this integration remains institutionally incomplete.

This doctrinal reconstruction is even more important in the post-2017 sanctions environment. United Nations Security Council Resolutions 2371 and 2397 prohibit seafood exports, and Resolution 2397 clarifies that the full sectoral ban on seafood in paragraph 9 of Resolution 2371 already prohibits the transfer of fishing rights. At the same time, China became a party to the Port State Measures Agreement (PSMA) on 16 April 2025, formally altering the regional compliance landscape (United Nations Security Council, 2017a, b; FAO, 2025). In this context, the interplay between domestic authorization, foreign-vessel control, inspection, and legal responsibility becomes central to any assessment of fisheries governance in Northeast Asia.

This article, therefore, asks three interrelated questions. First, how do the 2015 and 2022 consolidated texts, read against the broader amendment history and the 2025 amendment, organize fisheries governance across conservation, monitoring, access authorization, and sanctions? Second, to what extent do these provisions align, partially align, or reveal gaps when assessed against differentiated benchmark standards drawn from the United Nations Convention on the Law of the Sea (UNCLOS), the PSMA, the FAO Code of Conduct for Responsible Fisheries, and fisheries-related UN sanctions (United Nations, 1982; FAO, 1995, 2009; United Nations Security Council, 2017a, b)? Third, what do those alignments and gaps imply for cross-border IUU governance in Northeast Asian waters?

The core argument is that later DPRK texts reveal a denser domestic administrative chain than sanctions-focused accounts usually acknowledge. However, this internal thickening does not translate into the traceability, foreign-access transparency, and cooperative verification needed for regional fisheries governance. The law has become more specific about plans, permissions, checkpoint inspections, and legal responsibilities yet remains thin precisely where contemporary cross-border control relies on vessel monitoring, auditable records, and structured information sharing. The DPRK Fisheries Law is therefore analytically significant not because it resolves empirical questions about compliance at sea, but because it highlights how domestic legal opacity contributes to persistent cross-border governance challenges. In this respect the DPRK is analytically useful beyond its own borders. It illustrates a wider class of governance problems found in contested or politically sensitive maritime spaces—including parts of the South China Sea—where unresolved sovereign-rights disputes, security tensions, and weak cooperative enforcement make fishing activity difficult to govern even where domestic law is comparatively elaborate (Chen et al., 2023).

That also explains why the present article is framed as a legal baseline rather than a policy prescription. Before cooperative options, sanctions reform proposals, or enforcement recommendations can be evaluated, the content and structure of the governing statute itself must be clearly established. In the case of the DPRK, this preliminary step has been missing. The problem is not simply insufficient data but insufficiently reconstructed legal architecture.

The remainder of the article is organized as follows. Section 2 sets out the primary legal sources, the four-pillar analytical framework, and the coding rules, and explains how the benchmark instruments are used. Section 3 presents the results in two stages: it first reconstructs the statute’s legislative trajectory and internal design, and then assesses the 2015 and 2022 texts pillar by pillar against the benchmark standards, using the 2025 amendment to test whether the identified trajectory continues. Section 4 discusses what the resulting pattern implies for cross-border fisheries governance in Northeast Asia and sets out the limitations of the analysis. Section 5 concludes.

2 Materials and methods

2.1 Primary legal sources and temporal scope

This study employs doctrinal legal analysis—the systematic reconstruction and internal evaluation of legal texts—to reconstruct which fisheries-governance functions the DPRK Fisheries Law expressly regulates and which remain structurally unaddressed or opaque (van Hoecke, 2013; Hutchinson and Duncan, 2012; Smits, 2017). The approach is closely related to the systematic content analysis method developed for judicial opinions by Hall and Wright (2008) and to qualitative document analysis (Bowen, 2009), and it follows an established line of work that assesses a single jurisdiction’s fisheries legislation against international fisheries-governance instruments (Sodik, 2009; Islam and Hasan, 2024; Lina and Butt, 2025). The primary comparative corpus consists of the consolidated Fisheries Law texts amended on 23 September 2015 and 15 March 2022, supplemented for confirmatory purposes by the text amended on 20 May 2025 (Presidium Decree No. 1921; effective 1 June 2025) (DPRK Fisheries Law, 2015, 2022, 2025). The 2022 consolidated text is reproduced in the North Korean Law Compendium (National Intelligence Service, 2024). The 2015 and 2022 texts form the principal comparative baseline; the 2025 amendment is used only to test whether the identified trajectory continues.

This design allows the analysis to assess whether the trend toward denser domestic control observed between 2015 and 2022 continued in the most recent amendment, without requiring the entire argument to be rebuilt around a single later revision.

The statute’s longer legislative trajectory is reconstructed using three kinds of material. First, the consolidated 2015 and 2022 texts, together with the 2025 text, contain their own amendment histories. Second, earlier accessible legal materials—including the 1999 and 2007 consolidated texts and amendment materials from 2013 and 2014—were consulted to cross-check the statute’s earlier structural trajectory. Third, in cases of terminological uncertainty in English translations, the operative Korean text was treated as authoritative. This is especially important for recurring terms such as authorization, agreement, supervision, stoppage, confiscation, and legal responsibility, each of which carries analytic weight in the four-pillar assessment.

A clarification regarding sources is required here. The English translation preserved in FAOLEX under the archival title ‘Marine Products Law of the Democratic People’s Republic of Korea (2015)’ (FAOLEX, LEX-FAOC221538) reproduces the 2015 Fisheries Law rather than a distinct downstream-products statute (DPRK Fisheries Law, 2015). Because this archival label could mislead future researchers, the present article cites the translation as a 2015 Fisheries Law source while identifying the archival title in the reference list and data-availability statement. Doing so keeps the source trail transparent without reproducing the misclassification in the substantive analysis.

The analytical corpus extends beyond the Fisheries Law itself. To reconstruct the broader sanctions architecture surrounding DPRK fisheries governance, this study also draws on two adjacent bodies of statute: the Administrative Penalty Law (seven versions: 2004, 2008, 2011, 2015, 2016, 2020, and 2022, with the 2020 annotated edition used to verify constituent-element commentary; DPRK Administrative Penalty Law, 2004, 2008, 2011, 2015, 2016, 2020, 2022) and the Criminal Code (eleven accessible versions: 1950, 1974, 1987, 1999, 2004, 2007, 2009, 2012, 2015, 2022, and 2023; DPRK Criminal Code, 1950, 1974, 1987, 1999, 2004, 2007, 2009, 2012, 2015, 2022, 2023). These adjacent materials are consulted only where they contain fisheries-, vessel-, or marine-related provisions that bear directly on IUU-relevant conduct; their treatment is consolidated in Supplementary Tables 3A–C. The Aquaculture Law (yangŏbŏp, adopted 18 December 1998 and amended in 2001, 2014, and 2022; DPRK Aquaculture Law, 1998, 2001, 2014, 2022) is excluded from the principal analysis because its operative scope under Article 8 is confined to inland waters such as rivers, lakes, and reservoirs. Although the 1998 original text retained a limited coastal linkage in Article 24, which contemplated drawing fish from adjacent territorial waters into inland aquaculture zones via fish ladders (DPRK Aquaculture Law, 1998), the later amendments more clearly consolidated the statute as an inland-water regime. The accessible corpus assembled for this study reflects several years of accumulation from sources in the Republic of Korea, the United States, and international legal databases, and represents a substantial body of DPRK fisheries legal materials. The analysis draws directly on primary statutory texts rather than secondary English-language commentary.

2.2 Analytical framework and coding rules

The analytical status of the benchmark instruments requires clarification at the outset, because the DPRK’s relationship to them is uneven. The DPRK signed UNCLOS on 10 December 1982 but has not ratified it (United Nations Treaty Collection, 2026); is not a party to the PSMA (FAO, 2026); and is not a member of the regional fisheries management organizations (RFMOs) operating in adjacent waters, including the North Pacific Fisheries Commission and the Western and Central Pacific Fisheries Commission (NPFC, 2026; WCPFC, 2026). These instruments are therefore used here as differentiated comparative governance benchmarks: reference points for assessing which functions a fisheries statute makes legally visible, rather than a checklist of binding treaty obligations against which the DPRK is scored for compliance. The DPRK’s status as a UNCLOS signatory carries only limited interpretive relevance, since a signatory is under a qualified obligation not to defeat a treaty’s object and purpose pending a decision on ratification (Vienna Convention on the Law of Treaties, 1969, Art. 18), although the precise legal character of that obligation is itself contested (Gragl and Fitzmaurice, 2019); the present analysis does not rest on it. The one binding instrument in this set is the fisheries-related UN sanctions framework, which applies to the DPRK irrespective of its treaty position. Treating the instruments in this differentiated way keeps the comparison analytically defensible for a non-party state while still allowing the statute to be read against contemporary governance expectations. Within that comparative use, one dimension recurs across the benchmark instruments and shapes the present assessment: transparency—the legal visibility of authorization, vessel records, inspection outcomes, and foreign-access arrangements—which has come to be treated as a distinct organizing requirement of contemporary fisheries governance (Davis and Hanich, 2022).

The comparative framework draws on four normative source types: UNCLOS-based fisheries-governance baselines; PSMA-based benchmarks for documentation, inspection, denial, and follow-up measures; the FAO Code of Conduct for Responsible Fisheries as voluntary soft law; and the binding sanctions framework established by United Nations Security Council Resolutions 2371 and 2397 (United Nations, 1982; FAO, 1995, 2009; and United Nations Security Council, 2017a, b). Within this set, the FAO Code of Conduct is treated as voluntary guidance.

The statute is assessed across four governance pillars: (1) conservation and sustainable use; (2) monitoring, control, and surveillance (MCS); (3) access authorization and foreign-vessel control; and (4) sanctions and deterrence. The unit of analysis is provision or issue-cluster-level correspondence rather than the statute as a whole. This allows the analysis to distinguish, for example, between a law that contains a recognizable authorization chain and one that also makes that chain auditable to external actors.

The coding rules are deliberately conservative. Alignment denotes a provision that establishes a functionally comparable rule or authority, while partial alignment denotes a provision that addresses the same concern only in fragmentary, indirect, domestically confined, or institutionally incomplete form. A gap represents the absence of a relevant provision, the omission of a mechanism central to contemporary fisheries control, or the presence of a highly abstract clause that does not create a workable governance chain. Ambiguous provisions were coded conservatively as partial alignment unless the text expressly established a functionally comparable institutional mechanism. To support replication, the procedure was applied in fixed steps. For each pillar, a set of benchmark functions was derived from the instruments identified above; for every benchmark function, the corresponding DPRK provision or issue-cluster was located, assigned one of the three codes, and recorded together with the textual basis for the assignment and its governance implication. The complete provision-by-benchmark assessments are reported in Tables 1–4, so that each coding decision can be traced to the underlying statutory text.

2.3 Law on the books, sanctions context, and interpretive limits

The analysis proceeds in two stages. It first reconstructs the statute’s internal design, including resource planning, fishing-ground allocation, producer obligations, vessel registration, checkpoint inspection, foreign-vessel prohibition, and sanctions. It then maps these provisions onto the four governance pillars listed above. External materials such as satellite-based studies and sanctions-monitoring reports are used only to situate why specific legal functions matter; they are not used to translate doctrinal findings into empirical claims about actual implementation.

This distinction is especially important in the DPRK context. The article does not infer routine enforcement from the mere existence of statutory clauses, nor does it treat legal silence as conclusive evidence that no administrative practice exists. Instead, the objective is narrower and more defensible: to identify what the statute itself renders legally visible. Where the text uses terms such as ‘economic waters,’ they are treated as domestic legal terms unless the context specifically requires comparison with international law concepts, such as the exclusive economic zone. The aim is to assess functional comparability, not to overstate treaty breach or empirical certainty.

3 Results

3.1 Legislative trajectory and restructuring of the statute

3.1.1 From a 1995 framework law to post-2025 consolidation

The accessible legal record reveals a long-running statute rather than a recent enactment. The consolidated 2015 and 2022 texts, together with the 2025 text, indicate that the Fisheries Law was adopted on 18 January 1995 and later amended in 1999, 2007, 2013, 2014, 2015, 2017, 2022, 2024, and 2025, depending on the version consulted (see Supplementary Table 2 for a full cross-version comparison). Not every intermediate amendment is available as a complete, standalone consolidated text, but the amendment histories are themselves legally significant, as they reveal a process of sustained revision rather than one-off codification.

Two longer-term trends are visible across this reconstructed trajectory. The first is the expansion of the documentary and administrative chain through which resource use is planned, approved, and supervised. The second is a reworking of legal responsibility from a compressed endpoint of general control into a more differentiated sanction architecture. The later consolidated texts are best understood in relation to these two developments rather than as isolated textual revisions.

The statute’s overall structure remains consistent over time. By 2015, it consisted of five chapters ending at Article 49. Its core architecture already linked resource creation, production planning, conservation, export approval, vessel registration, and end-stage sanctions in a single framework statute (DPRK Fisheries Law, 2015). The 2022 text maintains this broad chapter order but expands the law to Article 54, substantially thickening the planning, registration, inspection, and sanctions clusters (DPRK Fisheries Law, 2022; see Supplementary Table 1). The 2025 text extends the statute to Article 57 and is structurally important for an additional reason: it reorganizes the final sections of the law so that Chapter 5 becomes a dedicated chapter on legal responsibility, while several guidance and control functions are relocated into earlier chapters (DPRK Fisheries Law, 2025).

This longer trajectory is crucial for interpretation. The later DPRK texts do not simply add harsher penalties to an otherwise unchanged regulatory scheme. Instead, they show a statute that has become progressively more administratively articulated over time: resource planning moves closer to central technical and guidance organs, authorization chains become more document-intensive, checkpoint inspections become legally visible, and sanctions become more differentiated. Consequently, the 2025 amendment should be read not as an isolated punitive spike but as the latest stage in a broader evolution from a relatively compact framework law toward a denser domestic control instrument.

3.1.2 Planning, authorization, and the internal chain of fisheries control

The most visible structural change appears in the chain linking planning, permission, and production. In the 2015 text, Article 8 still frames marine-resource creation mainly as a state-planning task, in which planning institutions adopt the resource-creation plan and distribute it to relevant institutions, enterprises, and organizations (DPRK Fisheries Law, 2015). By 2022, Article 8 assigns a more active upstream role to the central fisheries guidance institution. This institution must set indicators and standards based on resource survey materials and production unit data, formulate a resource creation plan, and integrate it into the wider planning chain while also notifying the central land-environment authority (DPRK Fisheries Law, 2022). The shift is subtle but important, as resource planning becomes less a one-step allocation exercise and more a multi-institutional administrative sequence.

The same thickening is visible in production and export planning. In 2015, Article 19 tied production and export plans to resource capacity and execution of the resource-creation plan, explicitly prohibiting the production or export of marine products without a plan. Article 20 further provides that the Non-Standing Resource Development Review Committee (NSRDRC) allocates fishing grounds and grants fishing permission to units that have already received a production and export plan (DPRK Fisheries Law, 2015). By 2022, Articles 19 and 20 became much more documentary. Producer units must now draft plans based on vessel numbers, gear holdings, and species-specific production capacity, submit them for review by the central fisheries-guidance organ, and then move fishing-ground and permit applications through provincial fisheries-guidance and local land-environment channels before final deliberation. The 2022 law therefore makes visible a longer bureaucratic pathway between anticipated catch and permission to fish (DPRK Fisheries Law, 2022).

The 2025 amendment further confirms and sharpens this pattern. It redistributes earlier administrative provisions throughout the statute rather than concentrating them at the back end. Article 8 now places guidance over the fisheries sector explicitly in the central fisheries-guidance institution; Article 10 formalizes annual resource-creation indicators and plans; Articles 22 and 23 preserve the production/export-plan and fishing-ground/permit sequence; and Article 41 links actual departure approval to multiple documentary checks, including production plans, aquaculture or fishing-ground approvals, gear-use approval, and the issuance or extension of resource-use certificates. The result is a denser internal chain: resource information informs planning, planning conditions authorization, and authorization conditions departure.

This planning architecture is central to the article’s subsequent argument, showing that the DPRK Fisheries Law is not indifferent to order, paperwork, or institutional sequencing. Its principal limitation lies elsewhere. The chain is internally articulated but difficult to verify externally. The law does not pair its increasingly dense approval logic with transparent publication, auditable permit records, or cross-border disclosure of foreign-linked access. The internal chain therefore grows more legible within the state without becoming comparably legible beyond its borders.

3.1.3 Production management, logs, vessels, and inspection

Provisions regarding production management reveal a similar combination of administrative density and external opacity. The 2015 law already mandates the keeping of fishing and production logs. Article 24 directs fisheries-guidance organs and producer units to maintain these logs and accurately record production volumes. Central bodies are then required to submit unit-level production data to the central statistics institution (DPRK Fisheries Law, 2015). Later texts retain this obligation and broaden its reporting ecology. For example, in the 2025 text, Article 27 still requires fishing and production logs but also routes production information not only to the central statistics authority but also to the central fisheries-guidance and land-environment bodies. Logbooks therefore become more tightly connected to a broader administrative information chain.

Vessel governance becomes denser as well. In 2015, Article 25 focused on planned construction and repair of fishing boats, requiring the installation of navigational and communications equipment, including radar, and the timely maintenance of boats and gear (DPRK Fisheries Law, 2015). By 2022, Article 25 added central approval requirements for vessel construction, allocation, transfer, acceptance, and decommissioning. Furthermore, it specified requirements for navigational, communications, and fish-finding equipment and linked these requirements more directly to standard fishing activities (DPRK Fisheries Law, 2022). The 2025 text preserves this broader governance of boats, equipment, and registration through Article 28 and the registration provisions that follow. This does not represent a modern electronic MCS regime, but it is not a legal vacuum either.

The Administrative Penalty Law shows a parallel trend toward specialization. From the 2016 version onwards, vessel registration and safety are regulated by an independent article (Article 275 in 2016 and Article 289 in 2020), separate from the article governing sea access and navigation. These are accompanied by dedicated articles on maritime supervision (Article 274 in 2016) and the duty of sea rescue (Article 277 in 2016) (DPRK Administrative Penalty Law, 2016, 2020). This structural separation within administrative law parallels the Fisheries Law’s own densification of vessel provisions, even though substantive thresholds for registration and inspection remain underspecified in the APL as well.

Checkpoint inspection becomes legally visible only in the later versions. The 2022 law introduced Article 48, which requires institutions, enterprises, and organizations entering the sea for fishery production to undergo inspection of their gear and the marine products they harvest by the land-environment authority, which may establish fisheries enforcement checkpoints for this purpose. The same requirement appears in Article 42 of the 2025 text, which states even more plainly that sea entry for fishery production cannot occur without such inspection (DPRK Fisheries Law, 2022, 2025). Once again, the statute identifies a recognizable control point, but not one that is externally auditable. There is no visible requirement for digital inspection records, public disclosure, or inter-state information exchange about what these checkpoints find.

The production chapter also incorporates technical language that is easy to overlook but important for interpretation. The 2022 and 2025 texts refer to scientific fishing methods, satellite-supported forecasting of fishing seasons and grounds, and the modernization and multipurpose use of fishing boats (DPRK Fisheries Law, 2022, 2025). Formally, the statute does not reject science or information systems. What it does is internalize them. Their outputs are integrated into planning and guidance rather than translated into transparent monitoring or cooperative regional data-sharing.

3.1.4 Resource protection, special protection zones, and the limits of conservation visibility

The resource-protection chapter is one of the more developed sections of the statute across all modern versions, but it also shows how the DPRK Fisheries Law combines recognizable conservation tools with limited public visibility. In the 2015 text, Articles 31 to 40 already established the familiar elements of a command-and-control conservation regime: designated resource-protection months, protection measures for specific species, periods and sizes, restrictions on prohibited gears and methods, management of protected areas, and pollution controls (DPRK Fisheries Law, 2015).

The 2022 law expanded this chapter to Articles 31 through 41, sharpening several internal management functions. It made special protected zones more explicit, deepened planning duties around protection measures, and tied allowable production more closely to resource-based limitations (DPRK Fisheries Law, 2022). The 2025 amendment retains and redistributes these functions through Articles 37 to 49. Article 20 requires an investigation and review of the marine ecological environment. Article 21 requires annual assessments of resource volumes and production capacity. Article 24 refers to a satellite-based information support system for fish-school detection and fishing-ground forecasting. Article 39 elaborates on the management of special protected zones. Article 41 ties departure approval to production plans and resource-use permissions consistent with planned management. Overall, these provisions make conservation not a marginal slogan but a recurrent organizing principle of the statute.

The Administrative Penalty Law provides a corresponding enforcement anchor. The annotated 2020 APL, Article 143 (violation of the order on fisheries resources creation and protection), expressly invokes the concept of a ‘Special Fisheries Resources Protection Zone’ (susanjawŏn t’ŭkpyŏl poho-gu) and lists violations of protected-zone management and angling order among its constituent elements (DPRK Administrative Penalty Law, 2020). This confirms that the Fisheries Law’s special-zone language is mirrored in a parallel administrative-sanction provision that sets out concrete enforcement elements.

Nevertheless, the conservation chapter also highlights the limits of the law’s visibility. The statute invokes surveys, scientific research, ecological investigation, and resource-capacity calculations, but it fails to make the evidentiary basis for these decisions publicly available. It does not establish a transparent stock-assessment process, a public scientific review mechanism, or a legally visible path for neighboring states or regional bodies to verify the assumptions underlying protection measures. Conservation is therefore real within the text, but it remains administratively enclosed.

3.1.5 Foreign-access control and the economic-waters clause

Foreign access is addressed through a compact but legally consequential clause. The 2015 text states in Article 45 that other countries or foreign nationals may not conduct marine resource investigations or produce marine products within the DPRK’s economic zone without an arrangement with the DPRK. The 2022 and 2025 texts retain this fundamental rule in Articles 46 and 49, respectively: foreigners are prohibited from conducting fisheries resource investigations and engaging in fishery production in the DPRK’s economic waters, but an agreement-based exception remains (DPRK Fisheries Law, 2015, 2022, 2025).

This clause is central to cross-border governance analysis because it is both strong and incomplete. It is strong in that it formally asserts domestic jurisdiction over foreign fishing and resource investigation. It is incomplete because the agreement-based exception lacks a transparent register of access arrangements, publication requirements, disclosure of permits or quotas, or a monitoring chain that would make foreign-linked activities visible to outside actors. Consequently, the law recognizes foreign access as a regulated legal possibility while leaving the documentary dimension of that possibility largely opaque.

A similar tension appears in the export provisions. The 2025 amendment retains export planning and approval under Article 36, even though the international sanctions environment after 2017 has sharply narrowed what may be exported as seafood under international law (United Nations Security Council, 2017a, b). The point is not that the domestic law overrides sanctions; it clearly does not. Instead, the statute continues to organize export and foreign-access issues through an internal approval logic that remains only weakly connected to externally verifiable governance mechanisms.

3.1.6 From guidance and control to legal responsibility

The sanctions cluster exhibits the statute’s sharpest evolution. In the 2015 text, sanctions were consolidated into Articles 48 and 49. The statute allowed for the suspension of production or export, the compensation of damages, and the confiscation of products, income, vessels, gear, and facilities used in illegal conduct; serious violations could attract administrative or criminal responsibility (DPRK Fisheries Law, 2015). This constituted a genuine sanction structure, but it remained relatively compact.

The 2022 amendment differentiated this back-end response. Articles 50 to 54 separate fines, stoppage or closure, confiscation, disciplinary and labor-related measures, and criminal responsibility (DPRK Fisheries Law, 2022). This differentiation reflects an effort to turn general responsibility into a more articulated sanction ladder. The law no longer treats fisheries illegality as a single, undifferentiated enforcement endpoint; instead, it disaggregates monetary penalties, operational suspension, confiscatory consequences, dismissal-like disciplinary measures, and criminal referral.

The penalty architecture is not confined within the Fisheries Law itself. Rather, a three-tier regulatory structure—comprising the Fisheries Law, the Administrative Penalty Law (APL), and the Criminal Code—distributes the regulation of IUU-relevant conduct across primary regulation, administrative sanctions, and criminal sanctions. Within the APL, fisheries-related provisions evolved from a single consolidated article (Article 54 in the 2004 and 2008 versions) to a five-track structure in the 2011 version, and further to a nine-article system in the 2016 version that separated maritime supervision (Art. 274), vessel registration and safety (Art. 275), navigation markers (Art. 276), and duty of sea rescue (Art. 277) into specialized, independent provisions (DPRK Administrative Penalty Law, 2004, 2008, 2011, 2016). The 2020 APL incorporated ‘capture fishing’ (ŏro) into the title of Article 70 for the first time; its official commentary lists improper division of fishing grounds, improper issuance of fishing licenses, fishing without a license, and deployment of unregistered vessels for fisheries’ production among the constituent elements. Consequently, unlicensed fishing and unregistered-vessel deployment—both core categories in international IUU discussions—have become identifiable objects of administrative sanction. Article 144 of the same version (addressing violation of the flora-and-fauna resources protection order) governs illegal fishing proper. The 2020 commentary precludes legal concurrence with Article 70, indicating that the drafters distinguish between ‘production order’ and ‘resource-protection order’ as separate categories of administrative offense (DPRK Administrative Penalty Law, 2020; see Supplementary Table 3A).

The 1999 amendment to the Criminal Code had already penalized unauthorized or prohibited fishing (Article 88), pollution harming fisheries resources (Article 89), and unauthorized departure from designated navigation or fishing zones (Article 119) (DPRK Criminal Code, 1999). Therefore, most subsequent fisheries-related criminal provisions should be read as a progressive differentiation of an existing criminal baseline rather than as entirely new categories. By contrast, specialized offenses for aquaculture and mariculture were added only in 2004 (Articles 154 and 155) (DPRK Criminal Code, 2004). As a result, the strengthening of vessel-management regulation discussed below coincides with a genuine expansion of the criminalized subject matter.

The restructuring of criminal law has not been uniform across all subfields. For example, the 2015 amendment reduced statutory penalties for aquaculture, mariculture, and illegal fishing from two years to one year of short-term labor (rodong tallyŏnhyŏng) and repealed the crime of ‘departure from designated navigation and fishing zones’ (former Article 235) (DPRK Criminal Code, 2015). The 2022 and 2023 amendments retained only two specialized aquaculture provisions (Articles 147 and 148) and consolidated illegal fishing into a single general clause on ‘illegal taking or gathering of flora and fauna’ (Article 198) (DPRK Criminal Code, 2022, 2023). The result element shifted from the open-textured ‘serious consequences’ to the quantifiable ‘large-scale/especially large-scale property loss,’ with up to three years of reform through labor (rodong kyohwahyŏng) reintroduced for the more severe tier. By contrast, criminal provisions relating to maritime supervision and vessel registration have been strengthened. Article 159 of the 2015 Criminal Code punished failures in vessel design review, vessel registration and inspection, and seafarer registration and qualification with up to one year of short-term labor. Article 141 of the 2022 and 2023 versions (renamed ‘neglect of maritime supervision’) raises the ceiling to five to ten years of reform through labor in aggravated cases (DPRK Criminal Code, 2015, 2022, 2023). The sea-rescue provision (Article 160 in 2015; Article 304 in 2022 and 2023) similarly introduced an aggravating clause that imposes up to five years of reform through labor. The consolidation of illegal-fishing provisions thus runs alongside a selective escalation of criminal sanctions in the vessel-management subfield, which remains central to international IUU governance instruments such as port-state measures (see Supplementary Table 3B).

The 2025 amendment pushes this redesign further and makes its structural direction easier to specify. First, Chapter 5 is retitled ‘Legal Responsibility’ rather than ‘Guidance and Control of Fisheries Activities.’ Second, several guidance and control functions that previously appeared near the end of the law are redistributed to earlier chapters, allowing Chapter 5 to serve mainly as a sanctions chapter. Third, Article 50 introduces a direct stoppage provision addressing eight scenarios: illegal operation of aquaculture sites, use of prohibited gear and methods, failure to register fishing performance on time, interference with the introduction of a resource-information management system, failure to cooperate with aquaculture surveys, failure to implement juvenile-release plans, departure without approval, and refusal of legitimate inspection or investigation.

Article 51 further raises and differentiates fines in a much more granular manner. It covers violations such as catching protected species during protected periods, taking undersized resources, using prohibited gear and methods, operating unregistered boats, producing without fishing or production logs, leaving port without gear inspection, failing to meet resource-creation plans, polluting fishery waters, and illegally exporting fisheries resources. The fine for illegal exports is especially notable because it is set at ten times the value of the illegally exported amount, giving the provision a distinctly punitive rather than merely administrative character. Articles 52 to 56 continue this ladder by distinguishing between confiscation and compensation, warnings and severe warnings, unpaid labor or labor-correction sanctions, dismissal-related measures, and criminal responsibility.

3.2 Four-pillar alignment assessment

Table 5 sets out the analytical framework and Tables 1–4 report the pillar-by-pillar results. The pattern is uneven: the DPRK statute is textually stronger in conservation planning, authorization, and sanctions than in modern monitoring infrastructure, traceability, and cooperative verification. The four pillars do not contribute equally to cross-border fisheries control. A state can conserve resources internally and punish domestically yet still fail to generate the documentary chain needed to make foreign-linked fisheries activity visible regionally.

3.2.1 Conservation and sustainable use

As Table 1 indicates, the conservation pillar is one of the statute’s comparatively stronger areas. The law contains identifiable tools such as protected-resource categories, protected periods, size restrictions, prohibited gears and methods, special protected zones, resource-creation plans, and pollution controls. The later texts also invoke scientific investigation, ecological review, and resource-capacity calculations. These are not trivial clauses. They demonstrate that conservation and resource replenishment are embedded within the law’s administrative architecture rather than appended rhetorically.

Even so, the conservation pillar is coded as partial alignment rather than full alignment. The statute does not provide for a transparent stock assessment process, a public scientific review structure, or a clearly visible adaptive management loop. Conservation is therefore more than symbolic but falls short of an externally verifiable, science-based regime. It is strongest as an inward-facing planning and control system.

3.2.2 Monitoring, control, and surveillance

The MCS pillar is where the law’s limitations become most visible. Vessel registration, fishing and production logs, supervisory authority, checkpoint inspection, and departure approval all appear in the later texts. These clauses indicate awareness that fisheries activity must be monitored, documented, and subject to administrative review. For this reason, the statute cannot be characterized as silent on monitoring or control.

What remains missing, however, are the elements that make modern MCS systems relevant to cross-border governance: real-time vessel monitoring systems, AIS-based traceability, electronic logbooks, standardized inspection records, public or inter-agency vessel lists, and legally visible pathways for information-sharing with other states or regional bodies. The later DPRK texts move closer to a paper-based internal oversight chain, but they do not cross the threshold into auditable contemporary MCS capacity. The monitoring pillar is therefore not empty but structurally incomplete.

3.2.3 Access authorization and foreign-vessel control

The access pillar shows a similar pattern. The statute explicitly provides for resource-based planning, fishing-ground allocation, permit issuance, export approval, departure approval, and a formal prohibition on foreign fishing in the absence of an agreement. This clearly shows that foreign-linked fisheries activity is not outside the law’s purview. The DPRK statute treats access as something that must be legally ordered, not something left wholly informal.

At the same time, the law does not make agreement-based foreign access transparent. It does not require the publication of agreements, the maintenance of a visible licensing register, or the linking of access approval to a traceable monitoring chain. The access pillar is therefore stronger as a mechanism for internal authorization than as a means of public control. This is precisely the point at which domestic legal density and needs for regional governance begin to diverge.

3.2.4 Sanctions and deterrence

The sanctions pillar represents the most evident area of formal strengthening of statute. By 2022, and even more so by 2025, the law differentiates fines, stoppage, confiscation, compensation, warning, labor-correction measures, dismissal-style sanctions, and criminal responsibility. The 2025 amendment also turns Chapter 5 itself into a chapter dedicated to legal responsibility and substantially increases several penalties, including one set at ten times the value of the illegally exported goods.

This strengthening of the Fisheries Law’s internal sanctions chain does not offer a full picture. When read alongside the Administrative Penalty Law and the Criminal Code, the DPRK has established formal legal bases for responding to the principal categories of IUU-relevant conduct through overlapping administrative and criminal channels. For instance, the 2020 APL commentary to Article 70 identifies unlicensed fishing and deployment of unregistered vessels as administrative wrongs (DPRK Administrative Penalty Law, 2020). Similarly, Article 141 of the 2022–2023 Criminal Code (neglect of maritime supervision) increases penalties for failures in vessel and seafarer registration to between five and ten years of reform through labor in aggravated cases (DPRK Criminal Code, 2022, 2023). These observations refine, rather than overturn, the coding of the sanctions pillar as partial alignment: the limitation lies not in the absence of formal legal bases but in the unresolved opacity of their implementation and the absence of externally verifiable enforcement records (see Supplementary Tables 3A, B).

Nevertheless, the sanctions pillar is still coded as partial alignment. Stronger penalties alone do not create stronger deterrence if the evidentiary chain needed to detect, record, verify, and communicate violations remains underdeveloped. In the case of DPRK, punitive provisions have become more explicit at a faster rate than monitoring mechanisms have become traceable. The law is therefore stronger in its internal deterrent rhetoric and sanction design than in the procedural architecture needed to make those sanctions predictably operational in a cross-border setting.

Taken together, the four-pillar assessment shows a consistent pattern. The DPRK Fisheries Law has progressed toward denser domestic planning, broader checkpoint and departure controls, and a steeper sanction ladder. However, it has not moved at the same pace toward transparent vessel traceability, public foreign-access records, or structured cooperative verification. The overall statutory trajectory is therefore best described as domestic administrative thickening without a corresponding shift toward regional transparency.

4 Discussion

4.1 Domestic legal thickening without regional transparency

The doctrinal findings point to an asymmetric legal architecture rather than a simple absence of fisheries regulation. The DPRK statute is more developed in planning, authorization, checkpoint inspection, and punitive language than a sanctions-only reading would suggest. Policy analysis built exclusively around dark fleets or sanctions evasion can easily miss how the state formally organizes control over its fisheries activity.

The asymmetry has a specific shape. The areas of strongest textual development are those most useful for internal ordering, such as plan formation, permit review, departure approval, and legal responsibility. On the other hand, the areas of weakest development are the ones most important for cross-border fisheries governance: transparent foreign-access records, auditable inspection chains, real-time vessel monitoring, and cooperative information-sharing. The result is not a legal vacuum but a legal misfit. The law becomes denser where the state governs inwardly and thinner where regional governance requires outward visibility.

As a result, the article’s central conclusion is not simply that the DPRK has a weak fisheries law. A better description is that it has an internally articulated fisheries law where the strongest capacities remain domestically enclosed. This distinction is important analytically, as it helps explain why greater statutory density does not necessarily translate into greater regional governability and why sanctions pressure or outside surveillance cannot easily compensate for opacity within the domestic legal chain.

4.2 Sanctions, law, and the problem of foreign-linked fisheries activity

The post-2017 sanctions environment exacerbates this mismatch. While domestic law continues to preserve a formal chain for production planning, export approval, agreement-based foreign access, and sanctioning of illegal conduct, the external legal environment prohibits seafood exports and fishing rights transfers under United Nations Security Council Resolutions 2371 and 2397 (United Nations Security Council, 2017a, b). Consequently, the domestic statute does not operate in a vacuum. It functions alongside a sanctions framework that constrains what may lawfully occur, even as domestic law continues to treat these activities as matters of internal authorization and control.

Changes in criminal law are relevant to this mismatch in a specific way. Although these changes do not displace the Fisheries Law as the article’s principal focus, they show that the DPRK’s broader punitive environment has become more differentiated and, in the vessel-management subfield, sharper over time (the detailed trajectory is set out in the discussion of vessel-management evolution above and in Supplementary Table 3B). The rationale for coding the sanctions pillar as only partially aligned is outlined in the sanctions-and-deterrence subsection above. What the preceding sanctions discussion adds is a distinct point: the sharpening of punitive instruments has not been accompanied by any corresponding opening of the domestic approval layer to external scrutiny. Thus, the friction between domestic approval logic and externally prohibited activity is where the asymmetry becomes policy-relevant.

This does not justify reading domestic export or agreement provisions as proof that post-2017 seafood exports remained lawful. Rather, it means something narrower and more useful: the DPRK Fisheries Law has preserved an internal approval framework even after the external legal environment turned significantly more restrictive. The tension between these two layers helps explain why fisheries governance in the case of the DPRK cannot be understood simply as either internal administration or international prohibition. It is the interaction between the two that generates the central policy problem.

The 2025 amendment aligns with this interpretation. Its steeper penalties, direct stoppage provision, and reclassification of the final chapter as ‘Legal Responsibility’ are consistent with a state concerned not only with fisheries production but also with non-compliance, unauthorized export, incomplete reporting, and resistance to inspection. This pattern does not establish a single causal factor. The amendment could reflect sanctions-era pressure, domestic governance concerns, resource stress, or a combination of these factors. The redesign is consistent with a state response that views legally disordered fisheries activity as a persistent problem requiring sharper coercive tools.

The implications are regional. Where foreign-linked industrial fishing pressure is high and small DPRK vessels are vulnerable to displacement, opacity in domestic authorization and monitoring may spill over into adjacent waters, especially when cooperative verification remains weak. Park et al. (2020) and Hastings and Song (2022) link unauthorized industrial fishing in DPRK-claimed waters to stock depletion and the displacement of North Korean fishers into Russian and Japanese waters. The present analysis does not claim that these outcomes can be inferred directly from the statute alone. It does, however, demonstrate that the domestic legal framework remains weak precisely where transparent attribution, traceability, and cooperative verification are needed to manage such spillovers effectively.

4.3 Regional comparison and legal isolation

A regional comparison clarifies why the DPRK’s domestic legal development does not amount to regional integration. The DPRK signed UNCLOS on 10 December 1982 but has not ratified it, is not a party to the PSMA, and is not a member of the North Pacific Fisheries Commission (NPFC) or the Western and Central Pacific Fisheries Commission (WCPFC) (United Nations Treaty Collection, 2026; FAO, 2026; NPFC, 2026; WCPFC, 2026). In contrast, the surrounding regional governance environment increasingly operates through these multilateral arrangements.

The contrast is particularly sharp in Northeast Asia. China, Japan, the Republic of Korea, and Russia all participate in the NPFC, while China, Japan, and the Republic of Korea are also members of the WCPFC framework (NPFC, 2026; WCPFC, 2026). China became a party to the PSMA on 16 April 2025 (FAO, 2025). China’s accession does not create direct PSMA obligations for the DPRK, but it changes the port-state compliance environment surrounding Northeast Asian fisheries. In spite of the practical limitations, these institutions establish at least some legally visible pathways for authorized vessel lists, reporting, compliance reviews, and port-side scrutiny. The DPRK statute does not create a comparable link between domestic approval and regional verification.

The significance of this isolation is functional, not merely formal. RFMO and port-state frameworks are critical because they embed fishing activity within recurring processes of authorization, reporting, compliance review, port inspection, and information exchange. Even when functioning is imperfect, these systems create documentary pathways through which questionable fishing activity can be checked against vessel lists, catch rules, and member obligations. The DPRK law offers no comparably visible bridge from domestic approval to these regional oversight mechanisms.

This does not make the DPRK normatively irrelevant to regional fisheries governance. On the contrary, the statute is important because it shows where regional governance encounters a domestic transparency ceiling. The law is capable of effectively organizing plans, permits, departures, and penalties within the state. However, it is far less capable, or at least much less visibly capable, of generating the documentary continuity through which neighbors, regional bodies, or port-state authorities can verify foreign-linked fishing activity. Thus, the DPRK remains legally isolated not because it lacks a fisheries statute, but because the statute’s strongest functions remain inward-facing.

4.4 The significance of the 2025 restructuring

The 2025 amendment deserves separate emphasis because it alters the statute’s presentation as well as its sanction content. Earlier versions concluded with a chapter on guidance and control in which responsibility, confiscation, and suspension appeared as part of a broader administrative cluster. In contrast, the 2025 law redistributes these functions into earlier chapters and reserves Chapter 5 for legal responsibility. That represents a doctrinally meaningful shift in framing. It tells readers that liability is no longer merely the endpoint of sectoral oversight; it is a named and foregrounded chapter of governance in its own right.

Nevertheless, the 2025 restructuring does not overturn the article’s main conclusion. The law becomes clearer about when boats may be stopped, when fines apply, how confiscation and compensation operate, and how warning, labor, dismissal, and criminal measures are layered. What it does not do is add a transparent vessel-tracking regime, a public foreign-access register, or an auditable information-sharing chain. The amendment therefore intensifies domestic control more than it advances regional transparency.

4.5 Study limitations and future research

Several limitations constrain the claims advanced in the study. First, the available legal record is uneven. Although the consolidated 2015, 2022, and 2025 texts provide a strong basis for doctrinal comparison, not every earlier amendment survives in equally accessible consolidated form. The statute’s broader trajectory can therefore be reconstructed with confidence at the level of amendment history and major structural changes, but not always with the same article-by-article precision for every intermediate year.

Second, this is a study of law on the books rather than law in action. The statute may overstate actual administrative capacity, while available external evidence may understate informal or unpublished practices. The objective is not to verify implementation, but to identify what the state has made legally visible. In a low-transparency environment, this is already a significant analytic step.

Third, the comparability of the assessment requires note. The benchmark instruments used here reflect governance expectations that developed largely among states with substantially greater administrative, technical, and fiscal capacity than the DPRK, and that operate outside the DPRK’s particular sanctions environment. The assessment is therefore not a like-for-like compliance score that places the DPRK on the same scale as well-resourced maritime administrations; it is a reconstruction of the governance functions that the DPRK’s own statutory texts make legally visible. Differences in economic development and in political and administrative capacity shape both what the law provides and what it can plausibly deliver, and they should be kept in view whenever the patterns identified here are set alongside those of other states.

A separate terminological observation, set out here only to clarify cross-statute usage rather than as a substantive limitation of the analysis, concerns aquaculture vocabulary. The Fisheries Law, across its 1999, 2007, 2015, and 2022 versions, uses the general expressions yangŏ, yangsik for aquaculture, whereas the Criminal Code employs three distinct terms for the same activity - ch’ŏnhae yangsik (2004), ch’inhae yangsik (2015), and padaga yangsik (2022, 2023). This terminological divergence between two statutes regulating the same subject constitutes a minor constraint for doctrinal interpretation and is cataloged in the glossary in Supplementary Table 3.

Fourth, the evidentiary environment following the conclusion of the United Nations Panel of Experts is uneven across issue areas. Although satellite-based research remains valuable for assessing fisheries activity, sanctions reporting has increasingly focused on military transfers and cyber or information technology issues rather than fisheries-specific details (United Nations Security Council, 2024; Multilateral Sanctions Monitoring Team, 2025a, b). Future research could therefore usefully link the statutory clauses identified here to vessel-tracking data, port-state inspection practices, sanctions-monitoring materials, and any accessible subordinate regulations or bilateral arrangements. The present article does not close that inquiry. Rather, it establishes the doctrinal baseline against which future empirical investigations can be anchored.

More specifically, future research could proceed clause by clause from the statute outward. Article 41 (departure approval), Article 42 (checkpoint inspection), the logbook obligations carried forward into later texts, and the agreement-based exception for foreign fishing are all points where vessel-tracking data, sanctions materials, or port-state records could be linked back to domestic law. That is where empirical work could most directly assess whether the statute’s increasingly dense internal design corresponds to practice or remains largely declaratory.

Two testable propositions emerge from this doctrinal baseline. First, if the 2025 restructuring of Chapter 5 from guidance and control to legal responsibility reflects a genuine enforcement priority rather than symbolic legal tightening, observable enforcement signals should cluster around the violations newly emphasized in Articles 50 and 51, especially those concerning departure approval, logbook, inspection, and export-related non-compliance. Second, if the foreign-access opacity identified here is a meaningful governance variable, periods or zones with stronger evidence of foreign-linked fishing should also exhibit the widest gap between domestically authorized activity, as reconstructed from the statute, and externally verifiable vessel behavior. Testing this second proposition would require integrating satellite-based vessel-identification evidence with port-state, sanctions, or inspection records, as foreign-linked fishing cannot be adequately measured by any single dataset. These propositions cannot be tested on the basis of texts alone, but they provide a falsifiable agenda for linking doctrinal analysis to satellite tracking, sanctions monitoring, port-state records, and any subsequently accessible administrative materials.

5 Conclusion

The DPRK Fisheries Law, read through the consolidated 2015 and 2022 texts and the 2025 amendment, is a more structured and dynamic statute than sanctions-centered accounts usually suggest. It organizes resource creation, production planning, fishing-ground allocation, departure approval, checkpoint inspection, foreign-vessel prohibition, and a progressively steeper ladder of legal responsibility within a single framework of domestic administrative control.

At the same time, the law remains least developed in domains where cross-border fisheries governance depends on legal visibility. It does not establish a modern traceability chain linking vessel registration, inspection, catch documentation, foreign-access approval, and cooperative information-sharing. While the 2025 amendment strengthens legal responsibility and sharpens the punitive architecture, it does not alter this fundamental asymmetry. Domestic control has become denser, while regional transparency has not. This asymmetry has a direct regional implication. External surveillance, port-state measures, and sanctions monitoring can detect vessels and movements, but they cannot substitute for the domestic legal chain through which authorization, vessel records, and access arrangements would become externally legible. Strengthening cross-border fisheries governance in this setting therefore depends less on additional outside observation than on whether that domestic chain itself becomes outwardly visible (Davis and Hanich, 2022).

The article, therefore, makes two interconnected contributions. Substantively, it shows that the DPRK’s fisheries law contains a more comprehensive internal governance design than accounts that focus exclusively on sanctions or dark fleets usually acknowledge. Analytically, it demonstrates why this design still falls short of the monitoring, disclosure, and verification functions needed for cross-border fisheries governance in Northeast Asia. The DPRK case is not best understood as the absence of law. It is better understood as the presence of a law whose most developed functions remain inward-facing, even as regional control increasingly depends on outward visibility.

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