The Department of Agriculture, Environment and Rural Affairs (DAERA)‘s consultation on its draft Nature Recovery Strategy for Northern Ireland marks a significant moment for environmental policy. Stretching to 2032, the Strategy sets out how Northern Ireland intends to halt and reverse biodiversity loss.

 

Strategic objectives

Under the Wildlife and Natural Environment Act (Northern Ireland) 2011, Northern Ireland must maintain and regularly review a Biodiversity Strategy. DAERA’s latest draft aims to meet that duty through five strategic objectives:

• Well Protected Nature and Accelerated Restoration
• Reduction of the Pressures on Biodiversity
• Sustainable Use of Biodiversity through Nature-Friendly Policies and Practice
• Nature Valued and Mainstreamed across All of Government and Society
• Building Strong, Integrated Evidence and Knowledge to Enable Action and Reporting for Nature.

 

To deliver these objectives, the Strategy sets out an ambitious list of 30 or so actions.

 

These include publication of a Tree Planting Action Plan by the end of 2026, a new All Ireland Pollinator Plan, a Protected Sites Delivery Plan, a Land Use Framework by 2027, and a monitoring framework to report annually on the condition of protected sites. Other commitments include new strategies on invasive species, a Plastic Pollution Plan, Northern Ireland’s first Clean Air Strategy, expansion of Farming with Nature schemes, development of environmental markets, and major investment in biodiversity and climate research.

 

Biodiversity duty

The Wildlife and Natural Environment Act also sets out the Biodiversity Duty which applies to government departments and public bodies, stating that it is:

“a duty of every public body, in exercising any functions, to further the conservation of biodiversity so far as is consistent with the proper exercise of those functions.“

 

In recent years there has been an increased focus in strategic environmental litigation on the duties of government departments to exercise their functions in a manner that preserves and enhances the environment, or meets statutory climate change objectives. That trend is likely to continue into 2026, with at least one live challenge before the Courts that will examine the scope of the duty to preserve and enhance ASSIs. The Strategy’s proposals for mandatory reporting on the Biodiversity Duty, introduction of statutory nature restoration targets and civil sanctions, would, if enacted, materially strengthen that duty.

 

Biodiversity net gain

Among the many actions proposed, one stands out for the planning and development sector. DAERA intends to explore options for adopting a biodiversity net gain approach within the planning system.

 

This is an important and potentially transformative proposal, but it will require the Department for Infrastructure (DfI) to lead on policy development. DfI is responsible for planning policy, and any BNG requirement must be reflected clearly in planning policy if it is to be enforceable.

 

The Strategic Planning Policy Statement already requires authorities to work towards the restoration of biodiversity. PPS 2 also requires planning policy to have regard to any strategy designated for the conservation of biodiversity.

 

BNG could provide a structured mechanism to help planning authorities meet their biodiversity duties, but its success depends on having strong, reliable evidence. This is where the findings of The Office for Environmental Protection are highly relevant. The OEP has found that Northern Ireland lacks systematic data on the impact of development on biodiversity. These data gaps make it harder to develop meaningful BNG targets and harder still to enforce them. While the draft Strategy acknowledges the problem, it remains unclear what concrete steps will be taken to fill these gaps and provide the consistent baseline needed for effective BNG.

 

The OEP report also notes that the system in England may offer lessons for Northern Ireland. In England, developers must deliver a 10 percent biodiversity increase or buy BNG units. This approach has faced practical challenges, particularly on smaller or brownfield sites, where viability has been affected. The UK Government has recently proposed exempting sites under 0.2 hectares to address this issue. Meanwhile the BNG regime has been criticised by environmentalists as failing to capture the ecological complexities of sites and simply offsetting biodiversity loss with the promise of a future habitat which may not be delivered.

 

These are important insights for Northern Ireland as it considers its own approach.

 

A future BNG model here must balance ambition with practicality. It must protect nature and address the decline in habitats and species, but it must also work for different types of development across a small and varied region. Flexibility, clarity and realistic implementation pathways will be essential.

 

The commitment to explore BNG is an encouraging step. It aligns Northern Ireland with wider UK and international trends in nature recovery and environmental governance. But success will require DfI and DAERA to work together to develop a clear policy framework and for government to invest seriously in the evidence base. Without good data, BNG will be difficult to design, difficult to deliver and vulnerable to challenge.

 

Co-operation across departments crucial to delivery

The scale of the commitments in the Strategy is striking, however, if you scrape the surface, most of the actions are to develop policy at a future date. Many require coordination across multiple departments and sectors, and several will need Executive approval. With an already congested legislative and policy programme of environmental measures, and an election cycle approaching, delivery will not be straightforward. Effective coordination and political support will be essential.

 

The potential of the Strategy is significant, but the path to delivery will require focus, realism and collaboration across the system.

 

The consultation closes on 18 March 2026.

 

While great care has been taken in the preparation of the content of this article, it does not purport to be a comprehensive statement of the relevant law and full professional advice should be taken before any action is taken in reliance on any item covered.