The Pygmy Devilray has an extremely low reproductive output with only one pup born per litter, and is therefore likely to have very low productivity incapable of withstanding and recovering from even very low levels of fishing mortality. Increasing international trade in gill plates has led to the expansion of largely unregulated and unmonitored devilray (Mobula spp.) fisheries. The species is a target of large artisanal fisheries in México and Peru, and is taken as bycatch of small- and large-scale fisheries with much of this catch likely unreported or aggregated and reported as Mobula spp. There are no current or historical estimates of the population size and trend of the Pygmy Devilray and further information is required from throughout its range. Based on distribution data, high catchability due to its schooling behaviour, limited productivity, directed and targeted fisheries, ongoing demand in trade, and a dataset showing declines in devilray sighting records around Cocos Island, it is suspected that the Pygmy Devilray may have been depleted in areas where significant fisheries or threats for mobulids exist. There are likely some refuges from fishing, for example in Ecuador’s Galápagos Marine Resources Reserve and while it should be noted that illegal fishing is an ongoing issue in the reserve, this refuge suggests that this species may not be at a level of extinction risk characteristic of some other mobuild rays. Overall, it is suspected that this species has undergone a reduction of ~30–49% over the last three generations (38 years), with a further population reduction suspected over the next three generation lengths (2018–2056). Therefore, the Pygmy Devilray is assessed as Vulnerable A2d+3d.