There was much concern expressed this week by Sussex based match anglers who have found themselves facing significant restrictions when it comes to gathering the required bait to fish their matches.
Sussex Inshore Fisheries and Conservation Authority (IFCA) have finally confirmed their hand gathering byelaw, which places the following ‘bag limits’ on any recreational collections.
- 2 lobsters
- 5 edible crabs
- 30 crabs in total of any species other than Cancer pagurus
- 5 kilogrammes of mollusc shellfish other than those defined in paragraph 3(b) (3b places an outright ban on piddocks and native oysters)
- 1 kilogramme of prawns or shrimps
- a quantity of marine worms exceeding all of the following alternative limits, specified as 1.5 kilogrammes, 1.5 litres and 150 individual animals
- 5 kilogrammes of intertidal seaweed
- 0.5 kilogrammes of glasswort; or 0.5 kilogrammes of sea-blite.
This byelaw, whilst only recently communicated in May 2025, was drafted in 2021 and signed off by the Secretary of State (SoS) on the 11 November 2024. It becomes effective as of the date the SoS signs it off, so it has been active now for 6 months. The delayed communication is interesting, as any judicial review to challenge whether the correct process was followed to introduce this byelaw should be done within 3 months of it coming into effect.
On the face of it, there are no legal challenges open to oppose this byelaw, with the time having expired for judicial review. There does, however, remain relevant case law to argue that the clock should start ticking upon full and detailed communication. While the IFCA website held a blog post upon effect of the byelaw, social media posts have only appeared in the final week of May 2025.
On this basis, and simply as an information gathering exercise to establish prospects for a judicial review, YourAnglingVoice has submitted a Freedom of Information (FOI) and Environmental Information Regulations (EIR) request to Sussex IFCA. This seeks information on the following points:
- The consultation process
- Key consultation documents
- Consultation outcomes
- Justifications for the byelaw
YourAnglingVoice, at this stage, has no reason to believe that due process has not been followed. Sussex IFCA have laid out the benefits of this byelaw, that relate to their ability to manage extractions pursuant to their section 153 duties, and their full impact assessment can be read here: https://secure.toolkitfiles.co.uk/clients/34087/sitedata/files/Regulations/HG-IA.pdf
It also appears that an appropriate consultation window was open and publicised, with the Angling Trust having submitted a response during this consultation period. The full copy of the Angling Trust’s response is published and can be viewed here: https://anglingtrust.net/2022/04/22/angling-trust-respond-to-sussex-ifca-hand-gathering-consultation
The main objection from match anglers is that the worm limits are a long way from being sufficient for their needs. Whilst the IFCA offers a permit, obtainable at £75, to extract higher volumes, they forecast demand for this at 30 permit holders per year, with a low of 15 and a high of 45. These numbers indicate that the IFCA has only been considering commercial bait diggers (those who dig for the bait sold in retail angling shops) and not match anglers as those whom will need to dig higher numbers of worm, as Sussex plays host to one of the largest shore based match fishing scenes in the country. The number of match anglers requiring higher limits and thus a permit far outstrips this forecast and offers itself up as an obvious oversight.
The issue is compounded when considering specific behaviour of bait gathering for match anglers. YourAnglingVoice rejects the notion that ‘exchange’ of baits between anglers represents a form of commercial intent, as the byelaw seems to indicate. Indeed, it is often the ‘greener’ approach for anglers to ‘pool’ bait collection opportunities, to cut down on vast miles being travelled. We are interested in why Sussex IFCA are opposed to such practices and wish to put barriers in the way of this occurring?
One of the most significant issues relates to a parent taking their children fishing, especially if they are encouraging their children into match angling. Without the children present, the parent only has their individual quota available, but we don’t suppose the IFCA proposes the children are taken out of school during low tide to do a bit of extra-curricular bait digging? If the answer is a permit, we really have to ask why additional cost barriers are being implemented in the course of getting children engaged in angling?
Whilst a judicial review would appear to have very slim prospects, the FOR and EIR requests will help to inform a consultation response when the byelaw is reviewed. This is scheduled for April 2026 and will offer a fresh opportunity for revision. The reviews rarely overturn a byelaw, and the match angling community does not seem to suggest this should occur, but a revision on the limits so as not to unfairly penalise match anglers and those gathering collectively to reduce collective carbon footprints feels like a very sensible and collaborative direction for all to be heading in.
We believe this will be the first of many hand gathering byelaws by the countries 10 IFCAs. It is therefore pivotal for anglers to get engaged and start feeding in to such matters, especially when consultations are open. Just because this is happening in Sussex, does not mean it will not soon impact you in other regions.
YourAnglingVoice will continue to communicate the findings from the FOI/EIR request and engage with the angling community, in particular match anglers, ahead of the byelaw review in April 2026. We receive no funding from memberships, charitable grants or government contracts, we are simply anglers trying to ensure our collective voices are heard. If you want to support this work, one off donations are available via ‘buymeacoffee’ and you can offer your support here: https://buymeacoffee.com/youranglingvoice
Please email [email protected] with any specific questions or comments on this subject.
