Padfield's comment was actually referring to capital ships with sophisticated gun directors and fire control systems. The average overall hit rate for naval combat was about 7%.
I don't have SH5, but in previous incarnations the gunfire is much too accurate. At 1000 meters on a perfectly calm day you should be hitting a large target most of the time, but as soon as the boat starts rocking at all you should be hitting about 20% of the time. A u-boat has no fire-control system at all, just the tube sight mounted to the gun, which is mounted to the deck, which is in constant motion. A merchant ship is larger and has less motion, but the u-boat is a smaller target, so theirs shouldn't be much better.
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