The Act on Distribution and Price Stabilization of Agricultural and Fisheries Product, which specifies rules and regulations on the trading system of fishery products wholesales markets, has been revised several times, mainly in order to improve the trading system. However, there is still a huge gap between the reality and law when it comes to the trading system of the fishery products wholesale market. This study aims to analyze the problems of the trading system of the fishery products wholesale market and to suggest ways to make improvement. The main problem facing the trading system of the fishery products wholesale market is sales on consignment by intermediate wholesalers, and this paper suggests two alternatives to solve the problem. First, intermediate wholesaler can be converted to market wholesalers, but it also entails other problems. The market wholesaler system has never been successfully adopted in the agricultural and fishery products wholesale market, and it is not clear which system is better between the wholesale market corporation and the market wholesaler system. Second, sales on consignment by intermediate wholesalers can be adopted with a positive view toward it. Negotiation transaction can be carried out for sales on consignment as a transaction method under the current Act on Distribution and Price Stabilization of Agricultural and Fisheries Products. However, since the act cannot provide a solution for listing, it is necessary to introduce Japan’s negotiated transaction in advance system as a negotiation transaction method.