You Bought Fish, You Became An Employer

A fish plant signs no employment contracts with the crews that supply it. It negotiates prices, takes delivery and pays for product. On the face of it that is a purchase of goods. The Employment Insurance regulations treat it as something else entirely.

A Note On Currency

Everything here is stated as verified in August 2026 and requires confirmation before reliance.

We quote the Employment Insurance (Fishing) Regulations, SOR/96-445, from the consolidated text as published[1], and CRA's payroll guidance on payments to fishers[2]. Those are primary sources.

We also use a Government of Canada evaluation of EI fishing benefits published in 2026[3], which is unusually current for this series.

One source is a consumer question and answer website, which we identify as such and use only for a single reporting detail we could not corroborate[5].

Our arithmetic uses assumed EI premium rates and a maximum insurable earnings figure. Rates and the maximum change annually and we did not verify the current figures. They must be confirmed before any use.

This is not tax or legal advice. Whether a particular business is a buyer, and whether particular workers are fishers, are determinations on specific facts.

The Deeming Rule

The provision itself, which is short and does a great deal.

The regulations provide that where a catch is delivered in Canada to a buyer or to a buyer's agent by a member of the crew that made the catch, the buyer shall be considered to be the employer of all fishers who are members of that crew and who share in the proceeds from the sale of the catch[1].

Read the conditions carefully, and this is our own analysis.

The trigger is delivery of a catch. Not a contract, not an engagement, not a payment for labour. A physical delivery of goods.

The consequence attaches to the buyer, being the person receiving the fish.

And it reaches all fishers who share in the proceeds, not only the person who made the delivery. The captain who ties up at the dock brings with him, for these purposes, everyone aboard who is on a share.

Three features follow.

The buyer has no say in who those people are. Crew composition is the vessel's business.

The buyer's obligation is determined by an event it does not control, being whoever the captain happened to sail with.

And the obligation arises automatically, without any document passing between the buyer and the crew.

Who Is A Buyer

The definition, which draws a bright line by intended use.

The regulations define a buyer as a person who buys a catch for the purpose of reselling it, either in the form in which it was caught or after processing, and not for the purpose of using it as food, feed or bait[1].

CRA's guidance restates it as a person who buys a catch to resell it raw or after processing, and notes that a buyer does not buy a catch to use it for food, feed, or bait[2].

Three observations, ours.

The test is about purpose, not about the goods. The same fish, delivered at the same dock, produces the obligation or does not depending on what the recipient intends to do with it.

Processing does not take a person outside the definition. A plant that fillets, freezes or cans and then sells is still buying to resell.

And the three excluded purposes are specific: food, feed or bait. Buying for consumption, for animal feed, or as bait for further fishing is outside.

That last point identifies who is inside. The population caught by this rule is processors, wholesalers, brokers and exporters, which is to say the commercial buying side of the entire industry.

The Same Fish, Two Answers

A consequence worth isolating. This section is our own analysis.

Consider one vessel landing one catch and selling it three ways at the same wharf.

To a processor who will freeze and export it. Bought to resell after processing, so the processor is a buyer and becomes the deemed employer of the crew.

To a restaurant that will cook and serve it. Bought as food, so on the definition the restaurant is not a buyer for these purposes.

To a lobster fisherman taking it as bait. Bought as bait, so outside again.

Same fish, same dock, same crew, same afternoon. One of the three acquires a payroll obligation for people it has never met and the other two acquire nothing.

Two practical points.

A business whose purpose is mixed needs to think about this rather than assume. A plant that processes most of what it buys and consumes some internally is buying for different purposes on different lots.

And the determination is made by reference to the buyer's own intention, which means the vessel cannot tell the buyer whether the rule applies. The buyer has to know.

We did not research how mixed purposes are treated and flag it as a question for advice rather than offering a view.

Who Is A Fisher

The other side of the definition.

The 2026 evaluation describes a fisher under the regulations as a self-employed person engaged in fishing, and notes that eligibility for EI fishing benefits is based on insurable earnings from fishing, not hours of insurable employment, unlike EI regular benefits[3].

Commentary on the classification question describes crew paid by a share of the catch or the proceeds, rather than wages, as usually treated as self-employed fishing income earners where the pay is based on a percentage of the catch or sales rather than a fixed wage, and where the worker provides their own tools, gear or equipment[5].

We flag that this last source is a consumer question and answer website and treat it as illustrative rather than authoritative.

Two observations, ours.

The regime exists precisely because these people are self-employed. Ordinary EI attaches to employment; the regulations extend coverage to a self-employed population by constructing an employer for them.

And the benefit test being earnings rather than hours is consistent with that. Hours are meaningless where income is a share of a catch, so the regime measures what the regime can actually observe.

That is a coherent design. Its cost is that somebody has to occupy the employer role, and the regulations assign it to whoever takes delivery.

The Definition Reaches Past The Boat

An extension most people would not anticipate.

The evaluation records that a fisher includes a person engaged, other than under a contract of service or for sport, in any work incidental to making or handling catch, such as loading, unloading, transporting or curing the catch; preparing, repairing, dismantling or laying up the fishing vessel or fishing gear, or in the construction of a fishing vessel for their own use or for the use of a crew of which they are a member in making a catch[3].

Three observations, ours.

The definition covers shore work as well as sea work. Loading, unloading, transporting and curing are all named.

It covers gear and vessel work performed when nobody is fishing at all, including preparing, repairing, dismantling and laying up.

And it covers building a boat, in defined circumstances.

The exclusion for work performed under a contract of service is the boundary that keeps this coherent. Someone employed under an ordinary contract of employment is an employee and is dealt with as one.

So the reach of the definition is to people doing fishing-related work outside an employment contract, which in this industry is a large population working seasonally on informal terms. A buyer forming a view about which of them share in proceeds is not doing something trivial.

Withhold EI, Not Income Tax

The instruction that catches people out, stated plainly by CRA.

Its guidance says: Do not withhold income tax. Under special EI regulations, you must withhold EI premiums on behalf of the worker and remit the worker's share and your share of the EI premiums[2].

Set that against an ordinary payroll and the inversion is complete, which is our own observation.

For an ordinary employee, the employer withholds income tax and EI.

For a self-employed fisher, the buyer withholds EI and not income tax.

Two errors follow from this, running in opposite directions.

A buyer who treats the arrangement as a purchase of goods withholds nothing, and has failed on the EI side.

A buyer who, on discovering it is a deemed employer, treats the crew as ordinary employees withholds income tax it should not have withheld, which creates a different problem for people who file as self-employed.

The correct answer is neither of the two intuitive ones, which is why this is worth stating as directly as CRA does.

Why It Runs That Way

The logic, which is ours and which makes the rule easier to remember.

Income tax withholding exists because employment income is taxed as it is earned and the employer is the convenient collection point.

A self-employed fisher does not have employment income. They have business income from fishing, which they report and pay tax on themselves, with instalments if required. There is nothing for a buyer to withhold against, because the buyer is not paying employment income.

EI is different. The regulations have deliberately brought this population inside the insurance scheme, and an insurance scheme needs premiums collected. Premiums are computed on earnings and collected at source, and the only party positioned to do that is the one paying for the catch.

So the two halves of the ordinary payroll obligation come apart because they exist for different reasons. The income tax half has no application; the EI half has been extended by design.

We offer that as an explanation rather than as authority. It is not stated in the sources; it is our reading of why the instruction takes the shape it does.

Type One And Type Two

A classification that determines how the numbers are computed.

CRA states that the calculation of insurable earnings depends on the situation of the self-employed fisher, and that to help explain it CRA has categorized the fishers as either type 1 or type 2[2].

It describes a type 1 fisher as a member of the crew who either owns or leases the boat or specialized fishing gear used to make a catch, or employs other persons under a contract of service to make a catch[2].

We did not obtain CRA's description of a type 2 fisher and do not state it.

Two observations, ours.

The categorisation is described as CRA's own aid to explanation rather than as a statutory division, which is worth knowing when reading the guidance.

And the type 1 test is about capital and hiring: owning or leasing the vessel or specialised gear, or employing others. In practice that describes the captain or vessel owner, while other crew fall elsewhere.

The practical significance is that a buyer cannot apply one calculation to a whole crew. It has to know which category each person falls into, which is another fact it learns from the vessel rather than from its own records.

Insurable Earnings Are The Gross Value

The measure, which is larger than intuition suggests.

For a type 1 fisher, CRA states that insurable earnings are calculated using the gross value of the catch, excluding the value of any part of a catch the crew did not make, to be included on the T4 slip using code 78[2].

A consumer question and answer source describes code 78 as fishers' EI eligible earnings and refers to a further box reporting fishers' gross income for income tax purposes, stating that for share fishers the two normally reflect the same gross share amount[5]. We identify that source as non-authoritative and report the detail without relying on it.

Two points, ours.

Insurable earnings are measured on gross value, not on net proceeds. Vessel expenses, fuel, gear and the costs that reduce what a fisher actually takes home do not, on this description, reduce the figure the premiums are computed on.

Which means the premium base can be substantially larger than the fisher's economic income, and larger again than any figure the buyer would have derived from the payment it made.

We flag that we did not obtain the full calculation rules, including the treatment of the maximum insurable earnings ceiling in this context, and our arithmetic below applies that ceiling on an assumption.

What The Obligation Costs

The scale, computed by us on assumed rates that must be confirmed.

Take a processor buying from 40 vessels with an average crew of five, being 200 deemed employees it did not hire.

At an average catch value of $400,000 per vessel, a five-way share is $80,000 each, which we cap at an assumed maximum insurable earnings figure of $65,700.

At an assumed employee premium rate of 1.64 percent and an employer rate of 1.4 times that, the numbers are roughly:

$215,496 of employee premiums to withhold.

$301,694 of employer premiums, which is the processor's own money.

$517,190 remitted in total.

The employer share is about 1.89 percent of the $16,000,000 of catch purchased.

Two observations, ours.

Roughly 1.9 percent of purchase value is a real margin item in a commodity business, and a buyer that has not accounted for it has mispriced its product.

And the employer share is not recoverable from anyone. It is a cost of buying fish, arising from a rule that describes the buyer as an employer.

We stress that every rate here is assumed. The structure of the exposure is the point, not these figures.

What Failing To Operate It Costs

The cumulative position, computed by us on the same assumptions.

A processor that has never operated this at all is exposed to roughly $517,190 per year, being about $1,034,381 over two years, $1,551,571 over three and $2,068,762 over four, before penalties and interest which we did not research.

The feature that makes this worse than it first appears, and this is our own point, is the same one this publication has described in the payroll review context.

The employee share was never withheld. There is nothing to recover from crews who were paid in full years ago and who have since fished for other buyers or left the industry.

So the whole amount, both shares, falls on the processor.

Two further consequences.

The exposure scales with volume, which means the largest and most established buyers carry the largest amounts.

And it accrues silently. Nothing in a purchase ledger announces that a payroll obligation was created, because the transaction was recorded as a purchase of inventory.

The Agent Route And Its Recovery Right

A variation the regulations provide for.

Where an agent is involved, the regulations provide that if the agent is not a member of the crew, the agent is considered to be the employer of all the fishers who are members of the crew[1].

And they add a right of recovery: an agent referred to in subsection (4) has the right to recover from the buyer the employer's premiums paid by the agent[1].

Three observations, ours.

The obligation can therefore sit with an intermediary rather than the ultimate buyer, where the transaction runs through one.

But the economics are directed back to the buyer by the recovery right. The agent may be the deemed employer, and the employer premiums are ultimately the buyer's cost.

And the condition that the agent is not a member of the crew matters. An arrangement in which a crew member acts as the selling agent falls elsewhere, and we did not obtain the treatment of that case.

The practical point for a buyer is that using an agent does not make the cost go away. It relocates the administration and leaves the economics where they were, which is worth knowing before restructuring a supply chain in the belief that it will.

Records Kept Separately

An administrative requirement with more bite than it appears.

The regulations provide that every person considered by section 3 to be the employer of fishers shall keep all records, books of account and documents in respect of those fishers separately from those the person keeps and maintains in respect of other insured persons[1].

Two consequences, ours.

A processor with actual employees as well as deemed ones, which describes essentially every fish plant, must run two separate record systems. Plant staff in one, crews of supplying vessels in the other.

And that separation is required rather than merely sensible, so a business that has folded its deemed-employer records into its ordinary payroll files has a compliance failure independent of whether the amounts were right.

Our own reading of why the requirement exists is that the two populations are governed by different rules. One has income tax withheld and the other does not; one is measured in hours and earnings and the other in the gross value of a catch. Mixing them would make either set unauditable.

Which suggests the separation is likely to be looked at, because it is the precondition for examining anything else.

Names, Addresses And Social Insurance Numbers

The specific information a buyer must hold.

The regulations require the records to contain the name, address and Social Insurance Number of each member of the crew and their share of proceeds from the sale of the catch[1].

Consider what that asks of a fish buyer, and this is our own analysis.

It must obtain a Social Insurance Number from every person aboard every vessel that lands to it and shares in proceeds.

It must know each person's share, which is set by an agreement between the captain and the crew that the buyer is not party to and did not see.

And it must hold current addresses for a seasonal, mobile workforce.

None of that information exists in a purchase transaction. A buyer settles with the vessel, not with the crew, and in an ordinary commercial sale would have no reason to know who was aboard.

So the record requirement obliges the buyer to run a collection process against people it has no commercial relationship with, whose cooperation it cannot compel, before or shortly after taking delivery of perishable goods at a wharf.

That is the practical difficulty at the centre of this regime, and the next two sections show that the government's own evaluation has heard it directly from the industry.

The Record Of Employment

The document that turns the record problem into a certification problem.

CRA states that once insurable earnings are calculated, the buyer must report this amount, including the EI premiums deducted, on the ROE[2].

The 2026 evaluation confirms the practice, recording that the buyer completes and files the ROEs[3].

Our own observation is about what that document does.

A record of employment is the instrument on which a person's entitlement to benefits is assessed. It is not an internal record; it is a statement relied on by another arm of government to pay money.

So the buyer is not merely keeping books. It is certifying, to the benefits system, facts about people it did not employ: who was aboard, for how many fishing days, and what share they took.

The evaluation notes that fishing claim investigations reported average annual savings of $321,640 for the EI programme, representing an average of 0.1 percent of all EI savings annually[3].

We report that figure as the evaluation states it and draw no conclusion from it about the prevalence of misreporting, which it does not establish.

What The Industry Told The Government

The evaluation's own findings, which are unusually candid.

It records that in most focus groups with employers, concerns with their obligations as the designated employer was expressed[3].

Participants said that because the buyer completes and files the ROEs, they were seen as the designated employer for self-employed fishers; however, they did not consider their business to be the employer because they did not have authority in hiring the crew members on each vessel, in establishing sharing agreements for income allocation, or other aspects of their employment[3].

They were also concerned that if a crew member was found not to have worked on a vessel as reported, it could negatively impact their business, since they relied solely on the captain's documentation such as crew, crew share agreements, fishing days, to complete information for the ROEs[3].

Two observations, ours.

This is the regulated industry describing the problem to the regulator, recorded in the regulator's own published evaluation. It is a better source for the practical difficulty than any commentary we could find.

And the phrase relied solely on the captain's documentation is the whole issue in five words. The buyer's compliance rests on paperwork produced by a third party with its own interests, which the buyer cannot audit.

Certifying What You Cannot Verify

The analysis that follows, which is ours.

Every other deemed-payer obligation in this series gives the payer some means of protecting itself. A payer withholding on a fee holds back money. A payer reporting a payment reports its own transaction.

This one does not.

The buyer must certify who was on a boat, which it did not see.

It must certify how many days they fished, which it cannot observe.

It must certify what share each took, under an agreement it never read.

And it must do so on a document that determines benefit entitlement, with its own name on it.

Three practical responses follow, and we offer them as the best available rather than as a solution.

Obtain the crew share agreement itself rather than a summary of it, for each vessel and each season.

Require the captain's signed certification of crew, days and shares, which does not transfer the legal obligation but does establish where the information came from and that it was represented as accurate.

And treat consistency checks as routine: the same person reported on two vessels for the same days is the pattern most likely to be examined, and the buyer is the only party positioned to notice it across the vessels it deals with.

Quebec And First Nations Fishers

Two further situations we flag rather than develop.

CRA notes that if the fisher worked in the province of Quebec, the buyer may also have to deduct Quebec Parental Insurance Plan premiums[2].

And it directs that where payments are made to self-employed First Nations fishers, a different path applies, with its guidance on payments to First Nations workers addressing whether a tax exemption and specific reporting requirements apply[2].

We did not research either and state no more than that both exist.

Our own observation is that both are likely to arise in practice rather than exceptionally, given where the Canadian fishery operates and who works in it. A buyer operating on either coast or inland should establish its position on both before assuming the general rules describe its whole obligation.

The First Nations point in particular should be taken to advice rather than inferred from general guidance, because it engages exemptions that turn on facts specific to the individual and the location of the work.

What The Auditor Actually Examines

The enquiry in practice. This section is our own analysis.

Whether any deemed-employer payroll exists at all, which is the threshold question for a business treating landings as purchases.

Purchase records against crew records, to identify vessels that landed catch with no corresponding fisher records.

Whether income tax was withheld, which is an error in the opposite direction and indicates the regime was misunderstood rather than ignored.

The insurable earnings calculation, and whether it used gross value of catch.

Type 1 and type 2 categorisation across a crew, rather than a single method applied to everyone.

Whether records are kept separately from those for the plant's own employees, as the regulations require.

Completeness of the required particulars, being name, address, Social Insurance Number and share for every crew member.

The second item is the one we would expect to be most productive. Landings are documented for fisheries management and for payment, so the record of which vessels delivered exists independently. Comparing it against the fisher records is straightforward and immediately shows what is missing.

What Records Survive

A separate record system for deemed-employer fishers, distinct from the plant's own payroll.

Name, address and Social Insurance Number for every crew member sharing in proceeds, collected per season.

The crew share agreement for each vessel, obtained rather than summarised.

A signed certification from each captain of crew composition, fishing days and shares.

Landing records reconciled to fisher records, so that every delivery has a corresponding crew.

Insurable earnings calculations showing the gross value used and the exclusions applied.

Copies of ROEs filed, with the source documents each was built from.

What To Do

Establish whether you are a buyer. The test is purpose: buying to resell raw or processed puts you inside; buying for food, feed or bait does not.

Do not withhold income tax. CRA's instruction is explicit, and treating deemed employees as ordinary employees is an error in its own right.

Do withhold EI, and budget the employer share. On our illustrative figures it approaches two percent of purchase value, which belongs in your pricing.

Collect crew particulars at the wharf, not at year end. Name, address and Social Insurance Number for everyone sharing in proceeds is a regulatory requirement, and a seasonal workforce disperses.

Get the share agreement, not a summary. You are reporting each person's share and should hold the document that sets it.

Have captains certify in writing. It does not transfer the obligation, and it establishes where your information came from.

Keep the records separately. The regulations require deemed-employer records to be maintained apart from those for other insured persons.

Reconcile landings to crews. Every delivery should have a crew record behind it, and the gaps are what an examination finds first.

Check the agent position before restructuring. An agent who is not a crew member can be the deemed employer, but has a right to recover the employer premiums from the buyer.

Take Quebec and First Nations fishers to advice. Both are flagged in CRA's guidance as separate paths and neither is addressed here.

The Limits Of This Analysis

Several caveats matter. This is not tax or legal advice; whether a business is a buyer, and whether particular workers are fishers, are determinations on specific facts. Everything is stated as verified in August 2026 and requires confirmation. We quote the regulations from consolidated published text and CRA's guidance directly, but we have not read either in full, and in particular we did not obtain CRA's description of a type 2 fisher and state nothing about it. We did not obtain the complete insurable earnings calculation rules, including how the maximum insurable earnings ceiling operates in this context, which our arithmetic assumes. All premium rates and the maximum insurable earnings figure used are assumed, change annually, and were not verified; the figures illustrate structure only. We did not research penalties or interest for failure to remit and state none. We did not research the treatment of mixed purposes where a business buys partly to resell and partly for excluded uses, the position where a selling agent is a crew member, the Quebec Parental Insurance Plan position, or the treatment of First Nations fishers, and flag all four as questions requiring advice. One source is a consumer question and answer website which we identify as non-authoritative and use for a single uncorroborated reporting detail. The same-fish-three-buyers illustration, the explanation of why the withholding runs inverted, the certification analysis and the audit examination structure are our own. This article does not address fishing income tax computation, qualified fishing property, vessel capital cost allowance, provincial licensing, or EI benefit entitlement from the fisher's side.

Related Reading

Payroll Nobody Selected You Where an employer that failed to deduct becomes responsible for the worker's share as well. Corporate Tax Farming As A Sideline The other primary sector with a tax regime built around how the income is actually earned. Sales Tax Nurses Or Nursing Another arrangement where who is supplying whom decides the whole obligation.

Frequently Asked Questions

We buy fish. How can we be an employer?

Because the regulations say so. Where a catch is delivered in Canada to a buyer, the buyer is considered to be the employer of all fishers in that crew who share in the proceeds. The trigger is delivery of goods rather than any contract, and the buyer has no say in who the crew members are.

Does this apply to every purchase of fish?

No. A buyer is defined as someone who buys a catch to resell it, raw or after processing, and not for use as food, feed or bait. So a processor is caught, while a restaurant buying to cook and a fisherman buying bait are not. The same catch can produce different answers depending on the purchaser's purpose.

Do we withhold income tax as well?

No, and this is the point most often got wrong. CRA's instruction is explicit: do not withhold income tax, but do withhold EI premiums and remit both the worker's share and yours. A buyer that treats the crew as ordinary employees has made an error in the opposite direction.

How do we get Social Insurance Numbers for people we never hired?

That is the practical difficulty, and the regulations still require it: records must contain each crew member's name, address and Social Insurance Number, plus their share of proceeds. Collection has to happen at the wharf during the season, because a seasonal crew disperses and the information exists nowhere in a purchase transaction.

What if the captain's information turns out to be wrong?

Industry raised exactly that with government. The 2026 evaluation records buyers saying they rely solely on the captain's documentation for crew, share agreements and fishing days, and worrying about the consequences if a crew member is found not to have worked as reported. Written certification from the captain does not transfer the obligation, but it does establish where the information came from.

Can we avoid this by buying through an agent?

It relocates the administration rather than the cost. An agent who is not a crew member is considered the employer of the crew, but the regulations give that agent a right to recover the employer's premiums from the buyer. The economics come back to you.

References

1. Government of Canada. Employment Insurance (Fishing) Regulations, SOR/96-445, consolidated text as published, on a buyer meaning a person who buys a catch for the purpose of reselling it, either in the form in which it was caught or after processing, and not for the purpose of using it as food, feed or bait; on a catch delivered in Canada to a buyer or a buyer's agent by a member of the crew that made it resulting in the buyer being considered the employer of all fishers who are members of that crew and who share in the proceeds from the sale of the catch; on an agent who is not a member of the crew being considered the employer of all the fishers who are members of the crew; on such an agent having the right to recover from the buyer the employer's premiums paid by the agent; on records being required to contain the name, address and Social Insurance Number of each member of the crew and their share of proceeds from the sale of the catch; and on every person considered to be the employer of fishers being required to keep all records, books of account and documents in respect of those fishers separately from those kept in respect of other insured persons. Note: primary legislation as published in consolidated form; we quote specific provisions and have not read the regulations in full. laws-lois.justice.gc.ca
2. Canada Revenue Agency. Payments to Fishers, payroll deductions guidance, on the instruction not to withhold income tax while under special EI regulations withholding EI premiums on behalf of the worker and remitting both the worker's share and the payer's share; on Quebec Parental Insurance Plan premiums potentially also being deductible where the fisher worked in Quebec; on the calculation of insurable earnings depending on the situation of the self-employed fisher, with CRA categorising fishers as type 1 or type 2; on a type 1 fisher being a crew member who either owns or leases the boat or specialized fishing gear used to make a catch, or employs other persons under a contract of service to make a catch; on the insurable earnings of a type 1 fisher being calculated using the gross value of the catch, excluding the value of any part of a catch the crew did not make, reported on the T4 slip using code 78; on the requirement to report the calculated amount and the EI premiums deducted on the record of employment; on a buyer being a person who buys a catch to resell it raw or after processing rather than to use it for food, feed or bait; and on separate guidance applying to payments made to self-employed First Nations fishers. Note: a CRA primary publication; we did not obtain its description of a type 2 fisher. canada.ca
3. Employment and Social Development Canada. Evaluation of the Employment Insurance Fishing Benefits, 2026, on eligibility for EI fishing benefits being based on insurable earnings from fishing rather than hours of insurable employment, unlike EI regular benefits; on a fisher under the regulations being a self-employed person engaged in fishing, including a person engaged other than under a contract of service or for sport in work incidental to making or handling catch such as loading, unloading, transporting or curing the catch, in preparing, repairing, dismantling or laying up the fishing vessel or fishing gear, or in the construction of a fishing vessel for their own use or the use of a crew of which they are a member; on fishing claim investigations reporting average annual savings of $321,640 for the EI programme, representing an average of 0.1 percent of all EI savings annually; on most employer focus groups expressing concerns with obligations as the designated employer, with participants saying that because the buyer completes and files the ROEs they were seen as the designated employer while not considering their business to be the employer given they had no authority in hiring crew members, establishing sharing agreements for income allocation or other aspects of employment; and on concern that if a crew member was found not to have worked on a vessel as reported it could negatively impact their business, since they relied solely on the captain's documentation such as crew, crew share agreements and fishing days to complete ROE information. Note: a Government of Canada programme evaluation published in 2026. canada.ca
4. Canada Revenue Agency. Canada Pension Plan and Employment Insurance Explained: Fishers, on workers engaged in fishing who are self-employed being covered under the Employment Insurance (Fishing) Regulations and potentially entitled to EI fishing benefits if they qualify; on those workers being responsible for remitting CPP contributions in the same way as other self-employed individuals; and on all employers being required by law to deduct CPP contributions and EI premiums from most amounts they pay to their employees and to remit those amounts along with the employer's share. Note: a CRA primary publication. canada.ca
5. Consumer question and answer website contribution regarding shareperson status on a fishing vessel, on crew paid by a share of the catch or proceeds rather than wages usually being treated as self-employed fishing income earners where pay is a percentage of catch or sales rather than a fixed wage and where the worker provides their own tools, gear or equipment; and on T4 box 78 reporting fishers' EI eligible earnings with a further box reporting gross income for income tax purposes, the two normally reflecting the same gross share amount for share fishers. Note: a consumer question and answer website, not professional guidance; we use it only for a reporting detail we could not corroborate elsewhere and do not rely on it. justanswer.com

This article is provided for general informational purposes and is not tax or legal advice. The regulations and CRA guidance are quoted from primary sources but were not read in full; CRA's description of a type 2 fisher was not obtained. All premium rates and the maximum insurable earnings figure used in the arithmetic are assumed, change annually, and were not verified. Penalties and interest were not researched. One source is a consumer question and answer website identified as non-authoritative.