If we go Str-based, plus a size modifier, we might as well just state that "make a bull rush attempt as if the archerfish were making the attempt" or similar wording, eh?
That's pretty much what I was thinking. Although I'm now wondering whether it shouldn't knock the target prone like an Overrun attack, since it can knock a target prone as well as drive them back.
The original creature appears to only be able to wash away creatures up to 200 pounds, suggesting the attack is limited to Medium sized or smaller target.
Do we want to include the "An attack roll of 20 indicates that the victim is stunned for 1-3 rounds by the force of the jet".
If we put everything in, we'd get something like the following:
Water Jet (Ex): A giant archerfish can spit a powerful jet of water as a ranged touch attack with a 30 foot range. This jet can push back or knock over any opponent smaller than the archerfish. Assuming the jet hits, the archerfish and its opponent make opposed Strength checks with the same modifiers as a bull rush attack (a typical archerfish has +8 on this Strength check). If the archerfish wins the contest it pushes its opponent back 5 feet, plus an additional 5 feet for each 5 points by which its Strength check result is greater than the opponent's Strength check. Any opponent that is pushed back by a water jet must also make a DC 15 Reflex save or fall prone.
In addition, if the giant archerfish rolls a critical hit with a water jet, the target must make a DC 15 Fortitude save or be stunned for 1 round.
The giant archerfish's water jet can not push back or knock over an opponent of an equal size to the archerfish or larger, but the waterjet can still stun such large opponents if it makes a critical hit.
The save DCs are Strength-based.