(17) The Commission continued to seek and verify all information it deemed necessary. The oral and written comments submitted by the Comoros following the Decision of 1 October 2015 were considered and taken into account. The Comoros was kept informed, either orally or in writing, of the Commission's considerations.

(18) In the light of the elements gathered, as shown in recitals 37 to 93, the Commission believes that the Comoros has not sufficiently addressed the areas of concern and shortcomings described in the Decision of 1 October 2015. Nor has the Comoros fully implemented the measures suggested in the accompanying action plan.

(19) On 1 October 2015, the Commission notified the Comoros pursuant to Article 32 of the IUU Regulation that it considered the possibility of identifying the Comoros as a non-cooperating third country(3).

(20) The Commission suggested the Comoros to implement, in close cooperation with its services, an action plan to rectify the shortcomings identified in its Decision of 1 October 2015.

(21) The main shortcomings identified by the Commission were related to several failures to implement international law obligations, linked in particular to the adoption of an adequate legal framework and registration and licensing procedures, management of the Comorian register, lack of cooperation and information sharing within the Comorian administration and with third countries where Comorian vessels operate, lack of adequate and efficient monitoring and lack of a deterrent sanctioning system. Other identified shortcomings relate, more generally, to the compliance with international obligations including recommendations and resolutions of Regional Fisheries Management Organisations (RFMOs). A lack of consistency with recommendations and resolutions from relevant bodies such as the International Plan of Action against Illegal, Unreported and Unregulated fishing of the United Nations (IPOA IUU) and the FAO Voluntary Guidelines for Flag State Performance were also identified. However, the lack of consistency with non-binding recommendations and resolutions was considered only as supporting evidence and not as a basis for the identification.

(22) On 5 January 2016, the Commission organised a conference call with the Comorian authorities to stress the importance for the Comoros to react to the Decision of 1 October 2015.

(23) Through its letter dated 6 January 2016 transmitted to the Commission on 29 January 2016, the Comoros informed the Commission of institutional arrangements set up in order to address the shortcomings identified in the Decision of 1 October 2015. This letter was accompanied by supporting documentation.

(24) Consultations between the Commission and the Comoros took place on 16 March 2016 in Brussels. During that meeting, the Comoros notably expressed their commitment to resolve the issues related to the management of the Comorian register. In the course of this meeting, the Comoros provided a list of fishing and fishing-related vessels purported to be flying the flag of the Comoros.