Abstract
African Small Island Developing States (SIDS) face critical challenges in maritime delimitation, balancing equitable principles with sustainable marine resource governance amid climate change and geopolitical pressures. Regional mechanisms like the Western Indian Ocean Coastal States Association (WIOCSA) employ innovative approaches, including soft-law governance and blockchain technology, to strengthen sovereignty and transparency. Successful cases such as Seychelles' blue bonds and Mauritius' adaptive fisheries management demonstrate effective capacity-building through resilience, adaptation, and systemic transformation. Equitable delimitation requires integrating ecological, economic, and legal dimensions while advancing regional cooperation. Strengthening inclusive governance frameworks remains essential for realizing sustainable development under the Agenda 2063 of the African Union (AU), ensuring African SIDS can navigate complex maritime boundaries while protecting vital marine resources.
1 Introduction
Maritime delimitation is of paramount importance for African SIDS, as it directly concerns their territorial integrity, marine resource management, and sustainable development. In Okonkwo's view, the core of African states' boundary delimitation—whether terrestrial or maritime—often revolves around national security and political prestige (). African SIDS, typically characterized by limited land area but vast maritime zones, face unique challenges in establishing maritime boundaries that adhere to equitable principles while fostering sustainable resource governance. With the intensification of climate change, rising sea levels, and overexploitation of marine resources, African SIDS are facing growing challenges in maritime boundary delimitation and sustainable ocean governance (). Equitable maritime delimitation is an inherent requirement of the emerging global norm of “protecting 30% of the Earth's land and sea by 2030,” African SIDS argue that maritime delimitation cannot be separated from marine conservation, particularly during the negotiations of the BBNJ Agreement1. The eighth challenge of the United Nations Decade of Ocean Science for Sustainable Development (2021–2030), known as the “Ocean Decade,” aims to build an adaptive and dynamic digital twin of the ocean to support sustainable ocean management. This will be achieved through a global online digital atlas that provides at least 10 local application cases, prioritizing Small Island Developing States and Least Developed Countries ().
Like other States, the maritime delimitation between SIDS is governed by the United Nations Convention on the Law of the Sea (UNCLOS), which advocates for the application of equitable principles rather than a strict equidistance approach in maritime delimitation. UNCLOS establishes a fundamental framework that emphasizes the achievement of an equitable solution based on international law.2 However, achieving this objective requires striking a balance between the equitable principles of maritime delimitation and the governance strategies for marine resources. The International Court of Justice (ICJ), the International Tribunal for the Law of the Sea (ITLOS), and arbitral bodies have consistently emphasized that maritime delimitation must be founded on equitable principles, taking into account all relevant circumstances to achieve an equitable result.3 This position was reaffirmed in the judgment of the Tunisia/Libya case, in which the Court particularly underscored the importance of “relevant circumstances” for achieving an equitable delimitation.4
This paper aims to be an original policy brief based on case evidence, to ensure the systematic and scientific nature of the research, the Integrated Coastal Zone Management (ICZM) framework will be employed as the analytical tool. This framework emphasizes a holistic approach, considering the interactions and coordinated development among natural ecosystems, socio-economic factors, and relevant policies and regulations within the coastal zone and its adjacent maritime areas. Specifically, it encompasses key dimensions such as ecosystem protection, economic development, social equity, policy coordination, and public participation. This aligns well with the multi-dimensional challenges faced by African SIDS in maritime delimitation and resource governance, providing a comprehensive and structured perspective for in-depth case analysis.
2 Existing practices of African SIDS in maritime delimitation and marine resource governance
Achieving equitable maritime delimitation remains fraught with difficulties, especially when sovereignty claims involve continental States with greater geopolitical influence (). To address these vulnerabilities and in recognition of the importance of the ocean for the equitable, inclusive and sustainable development of SIDS, the SIDS Coalition for Nature and the Ocean Decade Alliance have joined forces to leverage partnerships for sustainable ocean management in SIDS (). Increasingly, disadvantaged African SIDS are turning to regional coalitions—such as the AU's “Integrated Maritime Strategy 2050”—to strengthen their leverage in maritime delimitation negotiations. Marine resource governance is a pivotal dimension of boundary-making: effective stewardship of fisheries, hydrocarbons and other marine assets is indispensable to the sustainable development of Africa's SIDS. Yet sustainable resource governance requires more than clearly defined maritime boundaries; it also demands cooperative frameworks that enable transboundary, shared-resource management. For resource-dependent African SIDS, equitable access and science-based management not only avert interstate conflict but also foster regional stability.
When engaging with continental neighbors, small island states often find themselves at a structural disadvantage due to their limited size and resources. The model proposed by Donald E. Karl, which emphasizes “equitable principles” over pure power politics, provides these states with a legal foundation to assert maritime boundaries that align with their geographical realities and survival needs (). Confronted with the complexities of maritime delimitation and marine resource governance, African SIDS are actively exploring strategies to build sustainable alliances. By fostering regional partnerships to share resources and expertise, they seek to enhance their negotiating power in maritime boundary discussions.
By shelving boundary disputes and jointly developing resources, African SIDS have made joint submissions to the Commission on the Limits of the Continental Shelf (CLCS). This model not only avoids zero-sum dynamics but also lays the groundwork for subsequent co-governance of marine resources such as fisheries and seabed minerals (). A case in point is Seychelles and Mauritius, which have enhanced equitable access to resources while promoting sustainable utilization of marine resources through joint maritime zone management. In recent judicial practice concerning maritime delimitation, the Mauritius/Maldives case (2023) adjudicated by the ITLOS has highlighted the critical role of equitable principles in resolving maritime boundary disputes involving SIDS. Meanwhile, as the “blue economy” concept gains traction, African SIDS are actively adopting Marine Spatial Planning (MSP) as an integrated management approach. This ensures that maritime delimitation both safeguards ecological resilience and promotes sustainable economic development. However, these states still face cognitive gaps in reconciling competing claims such as balancing oil exploration rights and marine biodiversity conservation through alliance mechanisms. The challenge lies in upholding sovereign integrity while advancing environmentally sustainable development.5
3 Regional marine resource governance mechanisms for African SIDS in the context of maritime delimitation
3.1 Institutional design and ocean governance framework
At the level of institutional design, the WIOCSA,6 functioning as a platform for mutual cooperation, enables several African SIDS to implement regional ocean governance under the AU's Agenda 2063.
The WIOCSA has evolved a flatter, polycentric network that sustains effective coordination while safeguarding national autonomy through a three-tier consultation mechanism: technical working groups, ministerial conferences, and the AU mediated dialogues. This innovative architecture maintains member states' autonomy while enabling effective collaboration, particularly in addressing transboundary marine governance challenges. The system's flexibility was demonstrated during the 2022 Western Indian Ocean fisheries quota negotiations, where it successfully balanced national sovereignty concerns with regional conservation targets, African SIDS including Mauritius, Seychelles, and Comoros steadfastly maintained their negotiating position, demanding that “all historical catches within Exclusive Economic Zones (EEZs) shall be exclusively attributed to coastal states regardless of vessel flag registration.”
Notably, the WIOCSA has employed a “soft-law governance” strategy, converting binding international obligations into technical standards and best-practice guidelines. This approach effectively implements the marine sustainability goals of Agenda 2063 while safeguarding the maritime rights and interests of individual states. As the central governance node, the AU Commission steers the policy agenda by controlling the allocation of the African Ocean Governance Fund. African SIDS such as Seychelles, Mauritius and Comoros occupy secondary nodes, playing a pivotal role in filling structural holes across the network through their simultaneous memberships in multiple international fisheries bodies. The AU Commission serves as the central governance node, exercising agenda-setting authority through its allocation control of the African Marine Governance Fund. Meanwhile, SIDS like Seychelles, Mauritius and Comoros occupy secondary nodal positions, crucially bridging structural holes in the governance network through their multi-platform participation in international fisheries organizations.
3.2 Resource flows and rule implementation mechanisms
The effectiveness of the regional ocean-governance network hinges on the dynamic exchange of diverse resources. In the realm of technical resources, institutions such as France's Institute for Marine Research (IFREMER) provide satellite monitoring data in exchange for fisheries access rights, creating an asymmetrical technological dependency. To overcome this bottleneck, Seychelles has pioneered a marine blockchain platform that enables cross-organizational sharing of data on fishing vessel certification, carbon-credit trading and more, markedly enhancing both the transparency and efficiency of rule enforcement ().
However, these policy networks also confront structural challenges, with resource asymmetry being particularly acute. The marine monitoring equipment used by African SIDS is highly dependent on extra-regional actors (), which in turn undermines their autonomous decision-making power. Simultaneously, institutional nesting conflicts are becoming increasingly evident. For instance, the Illegal, Unreported, and Unregulated (IUU) fishing regulations7 established by the WIOCSA overlap with the jurisdictional mandates of the Indian Ocean Tuna Commission (IOTC), creating enforcement standard inconsistencies. To tackle these challenges, the Seychelles-led “Marine Blockchain Platform” provides a concrete framework for evaluating whether distributed ledger technology genuinely reduces regulatory costs or merely shifts them, with key performance indicators including transaction verification time, observer coverage rates, and prosecution outcomes for IUU violations ().
As Panke has observed, small states seeking to “punch above their weight” in negotiations must prioritize the following conditions: when negotiations occur within institutionalized platforms employing majority voting (one country, one vote) or require unanimous decision-making; when they can selectively engage in negotiations by concentrating efforts on the most critical issues; when they maximize conceptual influence through capacity-building; when they skillfully leverage institutional opportunities such as chairmanship and agenda-setting; and when they pursue persuasion strategies individually or collectively from the early stages—under these circumstances, small states are most likely to achieve outperformance.8
3.3 External engagement and network evolution dynamics
International actors are not merely participating in, but actively reshaping the ocean-governance landscape of African SIDS—often through modes of engagement that carry nuanced geopolitical and normative implications. China's “Smart Ocean” initiative, for instance, provides essential remote-sensing and monitoring technologies. While such cooperation appears mutually beneficial on the surface, it also introduces a degree of technological dependency that may influence long-term decision-making autonomy in maritime affairs. Similarly, the European Union (EU) leverages its Sustainable Fisheries Partnership Agreements (SFPAs) to embed its own technical and sustainability standards into the governance structure of the WIOCSA. This form of “standard-setting power” allows the EU to exert normative influence far beyond its shores, raising critical questions regarding sovereignty and regulatory alignment among African SIDS. A more critical examination reveals that these partnerships, though framed as collaborative, often mask asymmetrical power dynamics—where access to technology and markets comes with tacit concessions in policy space and governance priorities.
While this pluralistic engagement expands the network's functional scope, it also brings new challenges: on the one hand, the introduction of digital-governance tools accelerates the shift from political coordination to data-driven management; on the other, great-power regulatory rivalry threatens institutional fragmentation. For African SIDS, success now rests on forging more inclusive cooperation mechanisms that internalize external support into sovereign governance capacity and turn Agenda 2063's “African-led ocean governance” from vision into practice. Critical pathways include sovereignty-centric technology transfer—mandating source-code escrow in every digital-infrastructure project and establishing regional data-sovereignty frameworks such as the SIDS Cloud Initiative; a nested governance architecture that tiers decisions from technical bodies to ministerial forums and heads-of-state summits, applying subsidiarity to resolve conflicts; and proactive norm entrepreneurship that secures the AU-endorsed certification standards for marine technologies and institutionalizes SIDS caucuses in all Regional Fisheries Management Organization (RFMO) negotiations. The future development of African SIDS therefore hinges on building more inclusive cooperation mechanisms that effectively convert external support into home-grown governance capacity, ultimately realizing the Agenda 2063 vision of “African-led ocean governance.”
4 Capacity-building pathways for African SIDS in addressing maritime delimitation and ocean governance challenges
The capacity-building pathways of African SIDS can be analyzed through the lens of resilience theory, which emphasizes a system's ability to absorb shocks, adapt to change, and achieve sustainable development. This can be examined along three dimensions: absorptive capacity, adaptive capacity, and transformative capacity.
4.1 Absorptive capacity: resilience against short-term shocks
In the realm of maritime delimitation disputes, African SIDS are reinforcing their capacity to safeguard sovereignty through legal resilience and regional cooperation. Mauritius exemplifies this with its multi-pronged campaign for the Chagos Archipelago. To reclaim that archipelago after nearly six decades of British colonial rule, Mauritius secured a landmark 2019 advisory opinion from the ICJ (UNGA Res. 73/295) and prompted the ITLOS to affirm—via a jurisdictional ruling in its case against the Maldives—its sovereignty over the archipelago, while mobilizing an AU-backed 54-state coalition and Non-Aligned Movement support. The case sets a precedent for SIDS to challenge entrenched global power structures through a coordinated mix of litigation, diplomacy and advocacy (). Seychelles, for its part, has adopted Marine Spatial Planning (MSP) to integrate disputed maritime zones into science-based governance frameworks, effectively mitigating conflict risks.
In adapting to climate change, countries like Cape Verde and São Tomé and Príncipe in the Atlantic Ocean, and Comoros, Mauritius, and Seychelles in the Indian Ocean, face distinct challenges and strategic priorities. For instance, Cape Verde and Comoros are reducing storm-surge damage through coastal-resilience works such as mangrove restoration and breakwater construction, while São Tomé and Príncipe has established an early-warning system to enable rapid response to extreme weather events. These measures, however, remain constrained by limited finance and technology, and several projects still rely on external assistance, with support from the Green Climate Fund being a notable example, leaving their autonomy in need of strengthening.
4.2 Adaptive capacity: governance strategy adjustment for long-term change resilience
Confronted with declining fisheries resources, Seychelles and Mauritius have adopted adaptive quota management systems that dynamically adjust catch limits based on scientific stock assessments. These SIDS have complemented this approach by negotiating Sustainable Fisheries Partnership Agreements (SFPAs) with the EU, India and other partners, securing critical technology transfers and preferential market access in exchange for sustainable fishing practices. Meanwhile, Comoros has pursued a distinct pathway by transforming its artisanal fisheries sector through community-based co-management systems and eco-certification programs. This multifaceted strategy, combining science-based industrial fishery regulation with grassroots-level artisanal fishery upgrading, demonstrates how African SIDS are developing context-specific solutions to marine resource challenges while balancing ecological sustainability and economic needs.
In climate-related maritime policy, African SIDS have pioneered the systematic integration of sea-level rise considerations into both judicial and state practice regarding maritime delimitation. A landmark example is the 2021 Seychelles-Kenya Maritime Boundary Agreement (UNTS Reg. No. 58941), which established the first-ever “sea-level rise trigger clause,”9 stipulating mandatory renegotiation if baselines retreat over 500 meters due to rising seas. Furthermore, Vanuatu, an island nation in the southwestern Pacific, has elevated the climate change discourse from the political and scientific spheres into the hall of international law by spearheading the initiative for an advisory opinion from the ICJ. This effort aims to establish new, legally meaningful “rules of the game” for global climate governance and to seek “climate justice” for itself and other island states facing existential threats ().
The Organization of Eastern Caribbean States (OECS) provides a promising example (), demonstrating how small island states sharing the same regional geographical configuration can, while competing with each other in other areas such as tourism promotion and foreign direct investment attraction, still integrate resources and overcome scale limitations by constructing confederal shared governance mechanisms (). This organizational architecture encompasses a common currency, a joint central bank, a regional airspace coordination policy, a regional pharmaceutical procurement service, a supreme appellate court, and a Climate Change and Disaster Risk Management Agency with primarily coordinating functions ().
4.3 Transformative capacity: systemic innovation and governance reinvention
To reduce dependence on single-resource industries, Seychelles and Mauritius have spearheaded a blue economy transition by diversifying into marine renewable energy and eco-tourism development. A pioneering example is Seychelles' innovative “blue bond” financing mechanism,10 which creatively links marine conservation with capital markets to generate sustainable funding for Marine Protected Area (MPA) management.
Yet critical scholarship on “blue finance” warns that such instruments risk elite capture and uneven benefit sharing in states with limited regulatory capacity (). While Seychelles has indeed protected 30% of its EEZ through this finance-conservation nexus, persistent technological dependence and institutional fragmentation raise questions about who ultimately captures the bond-generated rents and how fiduciary safeguards are enforced. This dual approach, combining emerging blue sectors with innovative financial instruments, demonstrates how African SIDS are building climate-resilient economies while addressing the United Nations Sustainable Development Goal 14 (Life Below Water), though a more nuanced assessment of distributional impacts and governance mechanisms would strengthen its policy relevance.
In regional collaboration, African SIDS have established a multilateral governance network through the AU's Agenda 2063 and the WIOCSA, enhancing collective management of shared marine resources. Complementing these continental frameworks, Comoros and São Tomé and Príncipe have leveraged South-South cooperation to exchange small-scale fisheries management expertise with Pacific Island nations, particularly in community-based conservation techniques and sustainable livelihood approaches. This two-tiered strategy, combining pan-African policy coordination with targeted inter-regional knowledge sharing, demonstrates how African SIDS are strengthening their governance capacity through both institutionalized partnerships and practical, peer-to-peer learning.
5 Conclusion
The challenges confronting African SIDS in maritime delimitation and ocean governance are multifaceted, requiring a systematic and phased approach. Key obstacles include unresolved maritime boundaries leading to jurisdictional ambiguity, illegal fishing depleting vital fish stocks, sea-level rise threatening maritime entitlements, and limited capacity for harnessing marine renewable energy.
Aligned with the AU's Agenda 2063 and Sustainable Development Goal 14, a structured response is proposed: during the input phase (2026–2028), the AU Commission, UN Division for Ocean Affairs and the Law of the Sea (DOALOS), and regional economic communities will provide technical and financial support to strengthen maritime data systems and negotiation capacity. In the implementation phase (2029–2032), national and regional bodies should finalize delimitation agreements based on equitable principles, adopt regional fisheries management plans, establish cross-border marine protected areas, and launch pilot projects on offshore wind, tidal, and solar energy. During 2032–2035, these efforts are expected to yield outcomes including legally secure maritime jurisdictions, sustainably managed fisheries, healthier marine ecosystems, and a meaningful transition to blue energy.
The aforementioned pathway translates the equitable principles of maritime delimitation into tangible sustainable ocean governance. Its success hinges on coordinated action among national governments, regional institutions, and international partners. African SIDS can strengthen their resilience by refining legal frameworks, enhancing cross-border governance mechanisms, and integrating climate adaptation into marine spatial planning—thus embodying the vision of “African solutions to African problems.”
We recommend prioritizing research on innovative delimitation methodologies and adaptive governance models, with particular attention to the impacts of boundary decisions on vulnerable communities and regional ecological security. Through the concerted implementation of these governance and cooperative measures, the ocean for African SIDS is thereby transformed from a passive object of jurisdictional claims into a vital, dynamic driver of their sustainable and climate-resilient futures.
Statements
Author contributions
CS: Funding acquisition, Writing – original draft, Writing – review & editing.
Funding
The author(s) declared that financial support was received for this work and/or its publication. 2025 National Social Science Fund of China Project: Indigenous Approach to African Maritime Delimitation Dispute Resolution (Project Approval No: 25BFX031) and General Project of 2025 Zhejiang Philosophy and Social Sciences Planning Convention: Research on Judicial Practice and Practical Implications of Maritime Delimitation in African Countries (25NDJC020YB).
Conflict of interest
The author(s) declared that this work was conducted in the absence of any commercial or financial relationships that could be construed as a potential conflict of interest.
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The author(s) declared that generative AI was not used in the creation of this manuscript.
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Footnotes
1.^The full name of this agreement is “the Agreement under the United Nations Convention on the Law of the Sea on the conservation and sustainable use of marine biological diversity of areas beyond national jurisdiction”, it was formally adopted on June 19, 2023, at the United Nations Headquarters.
2.^Article 74 and Article 83 of UNCLOS stipulate that the delimitation of the exclusive economic zone/the continental shelf between states with opposite or adjacent coasts shall be effected by agreement on the basis of international law, as referred to in Article 38 of the Statute of the International Court of Justice, in order to achieve an equitable solution.
3.^North Sea Continental Shelf Cases (Federal Republic of Germany v. Denmark; Federal Republic of Germany v. Netherlands), Judgment, I.C.J. Reports 1969, paras.85,91,101(c).
4.^Case Concerning the Continental Shelf (Tunisia v. Libyan Arab Jamahiriya), Judgment, I.C.J. Reports 1982, paras.70,103,133.
5.^UN, Our Ocean, Our Future: Call for Accelerated Action, https://sdgs.un.org/sites/default/files/2025-05/2506719C.pdf.
6.^The WIOCSA is a regional intergovernmental organization comprised of Comoros, Kenya, Madagascar, Mauritius, Mozambique, Seychelles, Somalia, and Tanzania. It is dedicated to aligning policies on ocean governance and facilitating cooperation among its members in key areas like marine scientific research, fisheries management, and maritime security.
7.^Illegal, unreported, and unregulated (IUU) fishing poses a severe threat to global endeavors aimed at marine ecosystem preservation and the sustainability of fisheries. It denotes a spectrum of illicit practices, which may include conducting fishing operations within restricted zones, utilizing outlawed fishing apparatus, the omission or falsification of catch data, and activities undertaken by vessels that are not duly licensed to fly the flag of a particular state.
8.^Diana Panke, Small states in multilateral negotiations. What have we learned? Cambridge Review of International Affairs, 25(3), 387–398. https://doi.org/10.1080/09557571.2012.710589.
9.^The “sea-level rise trigger clause” is an innovative legal instrument in international law of the sea. It acknowledges that sea-level rise may cause coastal baselines to shift landward, thereby affecting maritime boundaries. This clause stipulates in advance that when baseline changes reach an agreed-upon threshold, the parties are obligated to renegotiate or adjust the boundary to preserve the equitable outcome originally pursued during the delimitation.
10.^The “blue bond” issued by Seychelles in 2018 was one of the world's first financial instruments specifically designed to fund sustainable marine projects. Raised from public and private capital, it was dedicated to expanding marine protected areas, improving fisheries management, and developing blue economy projects, setting a precedent for ocean conservation through innovative financing.
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Summary
Keywords
maritime delimitation, African SIDS, equitable principle, Marine resource governance, sustainable alliance
Citation
Sun C (2025) Sustainable alliance strategies in maritime delimitation for small island developing states in Africa: balancing the equitable principles and marine resource governance. Front. Polit. Sci. 7:1670678. doi: 10.3389/fpos.2025.1670678
Received
22 July 2025
Accepted
01 December 2025
Published
19 December 2025
Volume
7 - 2025
Edited by
Clifford Collins Omondi Okwany, University of Nairobi, Kenya
Reviewed by
Mansur Juned, University of Pembangunan Nasional Veteran Jakarta, Indonesia
Jian Chen, University College London, United Kingdom
Updates
Copyright
© 2025 Sun.
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*Correspondence: Chuanxiang Sun, sunchuanxiang@zjnu.edu.cn
Disclaimer
All claims expressed in this article are solely those of the authors and do not necessarily represent those of their affiliated organizations, or those of the publisher, the editors and the reviewers. Any product that may be evaluated in this article or claim that may be made by its manufacturer is not guaranteed or endorsed by the publisher.