Rethinking capacities of regulatory market-assurance intermediaries: the case of seafood sustainability audits

Credible assurances about the invisible qualities of goods and services – such as sustainability features – are key to market governance. The theory of regulatory intermediaries offers a lens for assessing diverse regulatory contexts where differently configured actors serve as market-assurance intermediaries between rule-makers and rule-targets. Studies using this theory have clarified the consequences of these configurations for regulatory capture, co-regulation, feedback effects, and the (re)production of knowledge and power. However, the distinction and relations between organisational and individual intermediaries remain under theorised. We reconceptualise the individual capacities of expertise and independence and assess these for 283 individuals performing 312 seafood sustainability audits for the Marine Stewardship Council (MSC). Examining the individuals and teams performing these audits uncovers otherwise invisible biases within intermediary processes, including in assessors’ professional, educational and personal backgrounds, the composition of assessment teams and assessors’ experience in conducting MSC audits. The analysis highlights that intermediary capacities are co-determined by individual assessors and audit organisations and are only partly under the control of the MSC as regulator. A shift to an individual level of analysis thus elucidates new consequences for the legitimacy of the regulator and intermediaries and for the (re)production of power and inequities in global market governance.