Scottish salmon farmers recorded more than 35m unexpected salmon deaths in just under three years but there were only two unannounced inspections of facilities over the same period.

In December, the Scottish government’s secretary for rural affairs, Mairi Gougeon, said that there was “a really robust regulatory regime when it comes to fin-fish aquaculture” but animal welfare campaigners say the figures call that claim into question.

According to a freedom of information request by Animal Equality UK, the Animal and Plant Health Agency (APHA), which is responsible for enforcing welfare legislation, inspected just 21 of Scotland’s 213 active salmon farms, between January 2023 and October 2025. None of the 20 worst-performing sites, which together accounted for more than 10m deaths, were inspected.

Additionally, the Scottish government’s website says that unannounced inspections are a “statutory requirement” but only two were carried out between January 2023 and September 2025, both of which were in 2024.

Abigail Penny, the executive director of Animal Equality UK, said: “A complete overhaul of the regulatory system is essential. This low level of scrutiny is embarrassingly poor. How can the cabinet secretary claim regulation is robust when inspections and sanctions are virtually nonexistent? It makes a mockery of the system. Regulators appear far more focused on protecting industry reputation than protecting animals.”

Between January 2023 and October 2025, 35,867,788 salmon deaths were officially reported on Scottish farms. Animal Equality said that the true figure is probably far higher as fish that are culled, die during transport, perish within their first six weeks at sea, or are used as so-called “cleanerfish” are excluded from the figures. Estimates suggest that at least 7m cleanerfish, which peck off lice that infect caged salmon, have died on Scottish salmon farms since 2020.

The APHA has received 22 complaints of fish welfare abuses since 2022, but has never issued a formal warning, care notice or referred a case to the Crown Office and Procurator Fiscal Service. The 20 complaints that were investigated resulted in 12 actions and enforcement which were limited to verbal or written advice and follow-up visits.

APHA refused to disclose inspection report forms to Animal Equality because their release “would likely result in significant detriment to the companies, negatively impacting their ability to conduct business, manage their reputation and their ability to protect their business”.

The Scottish parliament’s rural affairs and islands committee is due to question salmon farming executives on 25 February as part of a continuing inquiry. In January last year, the committee criticised the government for its “slow progress” on regulating the salmon farming industry.

An APHA spokesperson said: “We treat all reports of suspected cases of poor welfare at salmon farms seriously and all are assessed by our vets. We work closely with local authorities and the fish health inspectorate to manage each case through our standard process of triage and assessment.”

A Scottish government spokesperson said: “The fish health inspectorate undertakes approximately 250 statutory finfish site inspections per year as part of listed diseases surveillance. These can be pre-arranged, undertaken at short notice or be unannounced in response to intelligence-based reports.

“Inspectors are trained and experienced in spotting systemic issues related to fish health and biosecurity. Suspected cases of poor welfare are referred to the APHA who are responsible for considering potential breaches in welfare legislation.”

A spokesperson for Salmon Scotland said its farmers operated to some of the highest health, welfare and environmental standards in the world and that activists often “present a misleading picture” of what is happening on farms.

“More than £1bn has been invested in innovation, veterinary care, technology and stock management to continually improve welfare,” their spokesperson said.