Animals Australia has lodged formal complaints with Biosecurity Tasmania calling for an immediate investigation into potential breaches of Tasmania's Animal Welfare Act across the state's salmon farming industry.
The extensive complaints concern both the treatment of farmed Atlantic salmon and the suffering and deaths of seals, dolphins, seabirds and other wildlife impacted by salmon farming operations.
"The salmon industry does not have an exemption from Tasmania's Animal Welfare Act. Yet it appears to have been treated as though it does," said Animals Australia's Legal Counsel, Shatha Hamade.
"Environmental approval is not an exemption from animal cruelty laws. A licence to farm salmon is not a licence to cause unreasonable and unjustifiable suffering.
"Why have industry practices that result in great suffering and significant mortality incidents not been investigated as potential breaches of Tasmanian animal welfare laws?"
Tasmania's Animal Welfare Act applies to salmon farming
Atlantic salmon are recognised as animals under Tasmania's Animal Welfare Act 1993.
The Act requires those responsible for animals to take reasonable measures to ensure their welfare and prohibits methods of management, acts and omissions that cause, or are likely to cause, unreasonable and unjustifiable pain or suffering.
Animals Australia's complaint identifies a range of standard industry practices and documented incidents that warrant investigation under these provisions.
These include maintaining salmon in warming and low-oxygen waters; intensive confinement and stocking densities; disease and damaged gills; repeated crowding, pumping, bathing and transport of compromised fish; prolonged feed withdrawal; fin clipping; slaughter practices; and failures to promptly identify, treat or humanely euthanise sick, injured and dying fish.
Government data records that at least four million Atlantic salmon died prematurely in Tasmania during 2025 alone. They represent millions of individual animals capable of experiencing pain and suffering, raising fundamental questions about how they died, how long they suffered, whether that suffering was foreseeable or preventable, and whether adequate action was taken to alleviate it.
"Four million salmon dying prematurely in a single year is not simply an industry loss statistic. It represents animal suffering on an almost unimaginable scale - and suffering that Tasmania's animal welfare laws were enacted to prevent," said Ms Hamade.
"If millions of cattle died because of industry practices, there would be outrage and regulatory consequences. Why is the salmon farming industry not being held to the same legislative standards?
"Just because fish suffer underwater doesn't mean their suffering isn't real."
Potential offences relating to seals, dolphins and seabirds also not investigated
A second Animals Australia complaint documents recurring injury and death involving wildlife interacting with salmon farming operations.
Departmental wildlife interaction records for 2025 identify the deaths of 51 birds, eight seals and five dolphins, as well as the deployment of 3,477 seal crackers and at least 81 beanbag rounds.
The complaint details incidents including dolphins becoming entangled and dying in predator nets, seals suffering projectile injuries and prolonged confinement, and seabirds becoming trapped and dying within salmon farming infrastructure.
These incidents span multiple operators, facilities and years.
"Calling dolphin and seal injuries and deaths 'wildlife interactions' ignores the suffering that has occurred. Animals were injured, trapped, drowned and killed. Each of these events should have been investigated as potential breaches of the Animal Welfare Act."
The regulator cannot say it didn't know
Of particular concern is evidence that animal welfare risks associated with the salmon industry have been known to government for years.
Departmental records cited in Animals Australia's complaint reveal that in 2018 a government wildlife biologist warned that existing seal deterrent practices were likely contravening the Animal Welfare Act "on a significant scale" and said the risk should lead to "decisive and positive action".
Despite repeated incidents since then, the complaint identifies a distinct absence of meaningful regulatory enforcement under the Act.
This raises serious questions about regulatory oversight.
"The regulator's responsibility is not simply to record animal deaths and injuries. Where evidence indicates that animal welfare laws may have been breached, its responsibility is to investigate, and where offences are established, enforce the law."
No industry should be above the Animal Welfare Act
Environmental licences, biosecurity requirements and industry assurance schemes do not replace Tasmania's animal welfare laws.
Nor does the current Independent Salmon Industry Study remove the regulator's responsibility to investigate potential offences. That review is examining the future regulation and sustainability of the salmon industry. It is not a statutory investigation into potential criminal offending under the Animal Welfare Act.
Animals Australia has asked Biosecurity Tasmania to commence formal investigations into the matters detailed in both complaints and to exercise the investigative and enforcement powers available under the Act.
"The salmon industry is not above the law," said Ms Hamade.
"Tasmanians have every right to expect laws to be applied, without fear or favour, regardless of the profitability or influence of the industry involved.
"We are not asking Tasmania to create new protections for these animals. We are asking the regulator to enforce the protections that already exist."
Animals Australia is calling for:
- an immediate formal investigation by Biosecurity Tasmania into the practices and incidents identified in both complaints;
- assessment of those practices and incidents against the offence provisions of the Animal Welfare Act;
- proper use of the regulator's statutory investigative powers to obtain relevant industry records and evidence;
- public accountability regarding the findings of those investigations; and
- enforcement action, including prosecution, wherever the evidence establishes that offences have occurred.
The law already exists. The animals are already protected. It is now a question of whether Tasmania is prepared to enforce it.
