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South Africa’s Draft Third National Biodiversity Strategy and Action Plan (2026-2035) Submission made by the African Centre for Biodiversity to the Department of Forestry, Fisheries and the Environment

September 2026

The African Centre for Biodiversity (ACB) is committed to dismantling inequalities and resisting corporate industrial expansion in Africa’s food and agriculture systems.

This submission is endorsed by: Abanebhongo Persons with Disabilities Agroecology Action Collective -

Implementing partners Association for Rural Advancement (AFRA) www.afra.co.za Biowatch South Africa www.biowatch.org.za Environmental Monitoring Group (EMG) www.emg.org.za Surplus People Project (SPP) www.spp.org.za Trust for Community Outreach and Education (TCOE) www.tcoe.org.za

Participating organisations and networks Eastern Cape and Mpumalanga Water Caucuses Ilizwi Lamafama Land Network National Engagement Strategy (LandNNES) www.landnnes.org Mopani Farmers’ Association (MFA) Rural Women’s Assembly (RWA) www.ruralwomensassembly.org Sovereign Agroecology for Food Empowerment (SAFE) www.safe.net.za

Climate Lounge https://climatelounge.org.za/ Eastern Cape Agroecology Farmers' Association (ECAFA) Legal Resources Centre (LRC) https://lrc.org.za/ Mycelium Colab https://myceliumcolab.com/ Women’s Leadership and Training Programme (WLTE) https://wltp.co.za/

Table of Contents Acronyms..................................................................................................................................... 3 Introduction ................................................................................................................................. 3 Key inputs .................................................................................................................................... 5 Address structural drivers of biodiversity loss ......................................................................................... 1 Establish a dedicated Agricultural Transformation thematic area ............................................................ 1 Protect agricultural biodiversity, genetic diversity, and the commons ...................................................... 1 Strengthen implementation, accountability, and monitoring ................................................................... 1 Align fully with the KMGBF monitoring framework ................................................................................. 1 Apply precaution and strengthen biosafety governance .......................................................................... 1 Mainstream rights and community authority .......................................................................................... 2 Ensure rights-based conservation and restoration................................................................................... 2 Prioritise pollution prevention and agroecological transitions ................................................................. 2 Reorient biodiversity finance towards public accountability and justice ................................................... 2 Adopt a genuinely transformative vision ................................................................................................ 2

South Africa’s NBSAP ................................................................................................................... 2 Mainstreaming biodiversity.......................................................................................................... 4 Restoration and alien invasive species .......................................................................................... 6 Ecosystem conservation ............................................................................................................... 2 Species conservation .................................................................................................................... 2 Sustainable use and the biodiversity economy .............................................................................. 1 Proposed revised national target............................................................................................................ 2 Proposed indicators: .............................................................................................................................. 2 Sustainable use .................................................................................................................................................................. 2 Rights and customary use ................................................................................................................................................. 2 Biodiversity-dependent livelihoods .................................................................................................................................. 2 Sustainable consumption .................................................................................................................................................. 3 Additional actions.............................................................................................................................................................. 3

ACB recommendations ................................................................................................................. 1 Pollution and waste management ................................................................................................ 1 Ecological infrastructure and climate resilience ............................................................................. 3 Proposed revised national target............................................................................................................ 2

Access and benefit sharing ........................................................................................................... 3 Biosafety and benefits of biotechnology ....................................................................................... 4 Means of implementation ............................................................................................................ 1 Knowledge, participation and inclusion ........................................................................................ 4 Conclusion ................................................................................................................................... 4 References and bibliography ........................................................................................................ 6

Acronyms ACB BFP CBD COP CSOs DEA DFFE EGDs FNA FMSS FPIC HHPs IPBES-Food IPLCs KMGBF LMOs NbS NBSAP OECMs SANBI TWN UN UNHRC WRM

African Centre for Biodiversity Biodiversity Finance Plan Convention on Biological Diversity Conference of the Parties of the CBD Civil society organisations Department of Environmental Affairs (former) Department of Forestry, Fisheries and the Environment Engineered gene drives Financial Needs Assessment Farmer-managed seed systems Free, prior and informed consent Highly hazardous pesticides International Panel of Experts on Sustainable Food Systems Indigenous Peoples and Local Communities Kunming-Montreal Global Biodiversity Framework Living modified organisms Nature-based Solutions National Biodiversity Strategy and Action Plan Other Effective Area-Based Conservation Measures South African National Biodiversity Institute Third World Network United Nations United Nations Human Rights Council World Rainforest Movement

Introduction The African Centre for Biodiversity (ACB) has worked for more than two decades at the intersection of biodiversity, agriculture, food systems, seed sovereignty, biosafety, and environmental justice in South Africa and across the African continent. Our work has focused particularly on the impacts of industrial agriculture, corporate concentration, biotechnology, extractivism, and other drivers of biodiversity loss, as well as on the protection of agricultural biodiversity, farmer-managed seed systems (FMSS), agroecology, and farmers' rights. Thus, the organisation has a long history of working on the role of biotechnology and biosafety concerns for over two decades. Beyond this, the ACB also actively participates in international biodiversity governance processes under the Convention on Biological Diversity (CBD) and has contributed, together with civil society partners globally, to policy discussions surrounding the Kunming-Montreal Global Biodiversity Framework (KMGBF), adopted in 2022. It is with this extensive background, expertise, and engagement, both internationally and with the South African government, that the ACB submits comments on the third version of South Africa’s National Biodiversity Strategy and Action Plan (NBSAP) and national targets, as part of a global process to align NBSAPs with the KMGBF.

The biodiversity crisis is not simply the result of isolated pressures that can be addressed through fragmented conservation interventions. It is produced and intensified by economic and governance systems that permit the continued degradation of ecosystems, the expansion of chemically intensive and genetically uniform production systems, extractive land and resource use, pollution, harmful public incentives, and the concentration of control over land, seed, knowledge, technology, and finance. An effective NBSAP must therefore do more than align national targets with the KMGBF. It must provide a credible pathway for transforming the systems and institutions that drive biodiversity loss, while safeguarding the rights, knowledge and authority of the communities that conserve, use and regenerate biodiversity. The KMGBF was adopted in 2022 during the CBD’s fifteenth Conference of the Parties (COP) 15 under Decision 15/4.1 It sets out pathways to reach the global vision of a world living in harmony with nature by 2050 and includes four goals and 23 targets to be implemented by 2050—with specific goals for 2030—and features a comprehensive monitoring framework to track progress. The headline and binary indicators in the monitoring framework were updated in accordance with Decision 16/31 of the CBD.2 Figure 1 illustrates the 23 targets of the KMGBF, with Targets 1-8 aimed at reducing threats to biodiversity, Targets 8-13 at meeting people’s needs, and Targets 14-23 at providing tools and solutions for implementation.

Figure 1: 23 targets of the GBF Source: Nature Positive 3

1 https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-en.pdf 2 https://www.cbd.int/doc/decisions/cop-16/cop-16-dec-31-en.pdf 3 https://naturepositive.com/news/the-kunming-montreal-global-biodiversity-framework/

As South Africa prepares to submit its revised NBSAP ahead of COP 17, to be held in Armenia in October, we urge the South African Government to take bold steps to halt and reverse biodiversity loss. We welcome South Africa's efforts to align its NBSAP with the KMGBF and recognise several important advances in the current draft. These include greater attention to rights-holders, the integration of certain KMGBF targets, recognition of genetic diversity, and efforts to strengthen biodiversity planning and implementation. However, despite these advances, the current draft remains insufficiently ambitious in several critical areas and does not yet reflect the scale or urgency of the biodiversity crisis confronting South Africa. A central concern running throughout this submission is that the NBSAP often addresses biodiversity loss through fragmented technical interventions while paying insufficient attention to the structural drivers of biodiversity decline. Biodiversity loss cannot be understood in isolation from the systems that produce it, including industrial agriculture, pollution, extractivism, harmful subsidies, corporate concentration, unsustainable production and consumption patterns, weak regulatory oversight, and growing pressures to financialise nature. Addressing biodiversity loss, therefore, requires transformative changes in governance, production systems, and economic priorities. We believe that South Africa's Biodiversity White Paper provides an important foundation for such a transformation through its emphasis on ubuntu, duty of care, justice, participation and ecological stewardship. These principles should guide not only conservation actions but the overall vision, implementation and financing of biodiversity governance. Throughout this submission, we therefore advocate for a stronger focus on agricultural transformation and agroecology, protection of agricultural biodiversity and FMSS, rights-based conservation and restoration, precautionary governance of emerging technologies, public-interest approaches to biodiversity finance, and the meaningful participation and authority of communities who continue to conserve biodiversity in practice.

Key inputs The current draft National Biodiversity Strategy and Action Plan (NBSAP) contains several important advances and demonstrates South Africa's commitment to aligning with the KMGBF. However, it is not yet sufficiently ambitious, coherent, or transformative. Without substantial revision, it risks becoming an implementation-light strategy characterised by numerous targets and activities but inadequate baselines and data, weak costing, unclear institutional responsibilities, insufficient timelines and accountability mechanisms, and an overreliance on market-based approaches to biodiversity governance and finance.

ACB therefore recommends that the NBSAP be strengthened in the following areas:

Address structural drivers of biodiversity loss The NBSAP must move beyond fragmented conservation interventions and directly address the political and economic drivers of biodiversity decline, including industrial agriculture, extractivism, harmful subsidies, corporate concentration, unsustainable production and consumption patterns, pollution, weak regulatory oversight, and the growing financialisation of nature. Biodiversity loss cannot be addressed effectively without confronting the systems driving ecological degradation.

Establish a dedicated Agricultural Transformation thematic area Agriculture is one of the most significant drivers of biodiversity loss in South Africa yet remains inadequately addressed throughout the NBSAP. Agroecological transitions, food-system transformation, agricultural biodiversity, soil health, pollinator protection, diversified farming systems, and reduced dependence on harmful external inputs should be recognised as central biodiversity objectives rather than peripheral agricultural concerns.

Protect agricultural biodiversity, genetic diversity, and the commons The NBSAP should strengthen the in-situ conservation and sustainable use of agricultural biodiversity, including crop wild relatives, indigenous crops, landraces, locally adapted livestock diversity, and FMSS. Public-interest breeding, participatory plant breeding, community seed systems and farmers' rights should be recognised as essential components of biodiversity conservation and climate resilience.

Strengthen implementation, accountability, and monitoring Every target should be supported by clearly defined actions, indicators, baselines, data sources, milestones, implementation responsibilities, monitoring arrangements, and realistic cost estimates. Current weaknesses in data availability, monitoring systems, and costing undermine confidence in implementation and accountability.

Align fully with the KMGBF monitoring framework All relevant KMGBF headline indicators should be incorporated into the NBSAP, particularly Indicator 18.2 concerning subsidies and incentives harmful to biodiversity. The NBSAP should establish mechanisms to identify, assess, disclose, reform, and redirect incentives that contribute to biodiversity loss across sectors.

Apply precaution and strengthen biosafety governance The NBSAP should explicitly address biodiversity risks associated with synthetic biology, engineered gene drives, RNAi-based applications, genetically engineered pesticides, and other emerging genetic technologies. The precautionary principle should guide risk assessment, decision-making, monitoring, public participation, liability, and regulatory oversight.

Mainstream rights and community authority Free, prior and informed consent (FPIC), secure tenure rights, farmers' rights, customary governance systems, Indigenous and local knowledge systems, and community authority should apply across all thematic areas. Rights should not be treated solely as a participation issue but as a foundational condition for legitimate biodiversity governance.

Ensure rights-based conservation and restoration Protected area expansion, restoration initiatives, and Other Effective Area-Based Conservation Measures (OECMs) must respect land and resource rights, livelihoods, customary governance, and community stewardship. Conservation and restoration should not reproduce exclusionary or fortress-conservation approaches.

Prioritise pollution prevention and agroecological transitions The NBSAP should move beyond pollution management towards pollution prevention by supporting transitions away from pollution-intensive production systems, including reductions in highly hazardous pesticides (HHPs), synthetic fertilisers, and other harmful agricultural inputs, while strengthening agroecological alternatives.

Reorient biodiversity finance towards public accountability and justice The NBSAP should not rely disproportionately on biodiversity offsets, biodiversity credits, carbon markets, green bonds, and blended-finance mechanisms. It should prioritise public finance, subsidy reform, polluter accountability, community-led conservation and restoration, public-interest research, and direct support for local stewardship and biodiversity-enhancing livelihoods.

Adopt a genuinely transformative vision South Africa has an opportunity to develop an NBSAP rooted in ecological integrity, ubuntu, duty of care, agroecology, precaution, farmers' rights, biodiversity justice, public accountability, and democratic participation. Realising this opportunity will require significant strengthening of the present draft before submission. These recommendations should be read as proposed revisions to the architecture, targets, indicators, actions, implementation arrangements, and financing approach of the draft NBSAP, rather than as supplementary considerations to be addressed during implementation.

South Africa’s NBSAP South Africa’s NBSAP is organised into 12 thematic areas, as illustrated by Figure 2, which also shows the alignment with South Africa’s White Paper on the Conservation and Sustainable Use of Biodiversity. South Africa’s NBSAP is aligned with The White Paper, which provides policy certainty and guidance in the conservation, sustainable use, and fair and equitable access and benefit sharing

of South Africa's biodiversity, to contribute to the transformation and prosperity of society, and the well-being of people and nature. The White Paper was published for implementation in June 2023. It has key, useful concepts to guide biodiversity conservation and sustainable use, most notably the Duty of Care4 and the philosophy of Ubuntu.5

Figure 2: Summary theory of change illustrating the 12 thematic areas, goals and vision of the White Paper on the Conservation and Sustainable Use of South Africa’s Biodiversity, and the global targets of the Kunming-Montreal Global Biodiversity Framework. While there are some positive developments within these thematic areas and the national targets, indicators and actions as outlined in the NBSAP; for example, the inclusion of farmers as rights holders, there are significant questions and concerns. These will be discussed in detail. It is worth noting that three headline indicators of the KMGBF are not reflected in the final draft NBSAP: - 18.2 (Value of subsidies and other incentives harmful to biodiversity); - D1 (International public funding, including official development assistance (ODA) for conservation and sustainable use of biodiversity and ecosystems); and - 22.1 (Land-use change and land tenure in the traditional territories of indigenous peoples and local communities) (DFFE et al., 2026).

4 In the White Paper, duty of care is defined as: reasonable measures to be taken to prevent harm from occurring to

biodiversity within the environment and ecosystems that they are part of, allowing consideration and various options when harms that cannot reasonably be avoided or stopped, be minimised and rectified. 5 In the White Paper, Ubuntu is defined as a traditional unifying way of life that recognises the importance of interdependent and respectful relationships among the human, natural and spiritual elements, taking into consideration dignity, compassion, co-operation, communalism, sharing, caring, and responsiveness that individuals and groups display for one another and for the environment.

This should be rectified before submitting the NBSAP to the CBD. In general, actions do not correspond to specific national targets. In addition, many indicators lack data and/or data sources. Altogether, this makes measuring indicators challenging, even despite limited ambition. Implementation cannot be treated as a later or separate stage of the NBSAP. Targets without baselines, actions, responsible institutions, timeframes, data systems, and adequate public financing are aspirations rather than implementable commitments. These elements must therefore be incorporated into the NBSAP before submission, rather than developed only after its adoption. The KMGBF has 27 headline indicators designed to measure progress towards the four goals and 23 targets. The headline indicators constitute the minimum set that all parties to the CBD are required to report on in their national reports. South Africa is currently able to reliably report on 9 of the 27 headline indicators (DFFE et al, 2026). South Africa has outlined 79 national indicators and 125 discrete activities across the 12 thematic areas in the NBSAP. Due to data and consultation constraints, the present Financial Needs Assessment (FNA) provides a tentative costing for 17 so-called priority activities, which account for only some of the actions in the first five thematic areas. The cost of implementing these 17 activities is estimated at approximately R656.71 million over the ten-year period (2026/27–2035/36). Significant high-cost areas such as large-scale ecological restoration, protected area expansion toward 30x30 targets, full implementation of species recovery, biodiversity economy scaling, pollution control infrastructure, and ecosystem-based climate adaptation require further costing and stakeholder validation. Much of this will be financed through so-called innovative market-based instruments. This will be discussed later in the submission, as we believe this demands scrutiny and caution, in relation to the future of biodiversity financing, and its implications. In the section below, we outline the national targets, indicators, and actions and their relation to the KMGBF. We have only commented on the areas where we have expertise and left the others for those with expertise in those areas.

Mainstreaming biodiversity This thematic area addresses KMGBF Targets 1, 10, 12, 14, 15, and 18, which collectively seek to ensure that biodiversity considerations are integrated across decision-making processes, productive sectors, spatial planning systems, economic activities, and public policy. Mainstreaming biodiversity is therefore not simply a technical exercise. It is the means through which the structural drivers of biodiversity loss are addressed across society and the economy. If biodiversity considerations remain confined to conservation authorities and protected areas, biodiversity loss will continue despite improvements elsewhere. The draft NBSAP recognises the importance of integrating biodiversity into policies, planning processes, and development decisions. However, the current formulation remains insufficiently ambitious and does not adequately address the economic, institutional, and governance drivers of biodiversity decline. While the national target aims to integrate biodiversity and its values across sectors and spheres of government, the associated indicators and actions are often disconnected,

inadequately costed, insufficiently linked to implementation responsibilities, and, in several instances, limited to establishing baselines rather than driving transformation. The draft also omits several critical elements of the KMGBF. These include stronger commitments to participatory spatial planning, the recognition of the rights of Indigenous Peoples and Local Communities, the reduction of biodiversity loss in areas of high biodiversity importance to near-zero levels, and the reform of incentives and subsidies that are harmful to biodiversity. These omissions weaken the NBSAP's ability to address the underlying causes of biodiversity decline and limit its contribution to transformative change. A particular concern is the treatment of agriculture. South Africa's National Biodiversity Assessment identifies agriculture as one of the most significant drivers of biodiversity loss, yet agricultural transformation is afforded limited attention within the NBSAP and is largely reduced to establishing baselines for sustainable agricultural areas. Mainstreaming biodiversity into agriculture cannot be achieved through monitoring alone. It requires deliberate policy interventions that support a transition away from chemically intensive, biodiversity-destructive production systems towards agroecological production systems that conserve and regenerate biodiversity while strengthening food sovereignty, climate resilience, and rural livelihoods. ACB therefore recommends the establishment of a dedicated Agricultural Transformation thematic area within the NBSAP. Agriculture should not be treated as a subsidiary component of mainstreaming. Rather, it should be recognised as a strategic area requiring its own targets, indicators, actions, financing arrangements, and institutional responsibilities. Such a thematic area should promote agroecology, agroforestry, silvo-pastoral systems, integrated pest management, FMSS, pollinator conservation, soil biodiversity protection, locally adapted seed, livestock diversity, and support for smallholder farmers, pastoralists, and small-scale fishers. These interventions are consistent with KMGBF Target 10 and international guidance on mainstreaming biodiversity into agrifood systems. The treatment of biodiversity finance within this thematic area also requires substantial revision. While the draft NBSAP emphasises biodiversity credits, offsets, bonds, and blended finance mechanisms, these instruments carry significant risks. Biodiversity mainstreaming should not become synonymous with the financialisation and commodification of nature. Instead, greater attention should be given to public investment, subsidy reform, fiscal measures, direct support for biodiversity-positive livelihoods, and community-accountable financing mechanisms. Biodiversity finance should address the causes of biodiversity loss rather than create mechanisms that allow ongoing destruction to be offset elsewhere. The omission of KMGBF headline Indicator 18.2 is particularly concerning. The current draft includes positive incentives for biodiversity conservation but excludes the indicator relating to subsidies and incentives harmful to biodiversity. This represents a significant gap in implementation. South Africa should commit to identifying, reviewing, reforming, and progressively eliminating subsidies and incentives that contribute to biodiversity loss, including those associated with industrial agriculture, environmentally harmful land-use practices, pollution, and other destructive activities.

Similarly, biodiversity mainstreaming must extend beyond government planning processes and include corporate accountability. Businesses whose activities affect biodiversity should be required to assess, disclose, prevent, mitigate, and remedy biodiversity-related impacts and dependencies. Mainstreaming cannot succeed if responsibility remains concentrated within environmental authorities while major economic sectors continue to externalise biodiversity costs. Finally, mainstreaming must be grounded in rights-based governance. FPIC, secure tenure rights, farmers' rights, customary governance systems, Indigenous and local knowledge, and community authority should be treated as cross-cutting principles applicable across all thematic areas. Biodiversity mainstreaming is not only about integrating biodiversity into economic decision-making; it is also about ensuring that decisions affecting biodiversity are democratic, accountable, and socially just. The principles of Ubuntu and Duty of Care articulated in South Africa's Biodiversity White Paper provide an important foundation for such an approach.

We therefore recommend that: • •

• • • • •

•

A dedicated Agricultural Transformation thematic area be established within the NBSAP. KMGBF Headline Indicator 18.2 be incorporated into the national monitoring framework, together with a national target on identifying, reforming, and eliminating incentives harmful to biodiversity. Actions in this thematic area go beyond baseline establishment and include measurable commitments to the agroecological transition. Specific actions be included to support agroecology, agroforestry, silvo-pastoral systems, integrated pest management, pollinator protection, and soil biodiversity conservation. Public support be directed towards smallholder farmers, pastoralists, small-scale fishers, and communities already practising biodiversity-enhancing production systems. Rights-based principles, including FPIC, farmers' rights, and customary governance systems, be integrated across all actions and indicators. Biodiversity finance prioritises public, redistributive, and community-accountable mechanisms rather than reliance on biodiversity offsets, credits, and other market-based instruments. All indicators be linked to clear actions, responsible institutions, timelines, budgets, and monitoring arrangements to ensure accountability and implementation.

Restoration and alien invasive species This thematic area addresses KMGBF Targets 2 and 6; namely, the restoration of degraded ecosystems and the prevention and management of invasive alien species. The national target is that, by 2035, at least 22% of degraded terrestrial ecosystems across biomes—together with priority degraded freshwater and coastal ecosystems—are restored or rehabilitated and durably maintained, while the impacts of invasive alien species are identified, managed, and minimised.

ACB welcomes the inclusion of a dedicated restoration target and recognises the importance of invasive alien species management in South Africa. These continue to impose significant ecological, hydrological, and economic costs, particularly in water-stressed catchments and degraded ecosystems. Effective prevention, monitoring, control, and long-term management of invasive alien species must remain core components of biodiversity conservation and restoration efforts. However, the thematic area places disproportionate emphasis on invasive alien species while paying insufficient attention to the broader and interacting drivers of ecosystem degradation. Restoration cannot be reduced to alien plant clearing programmes. While invasive alien species are an important pressure, South Africa's own assessments identify land degradation as being driven by a combination of factors, including unsustainable agricultural practices, inappropriate grazing systems, mining, infrastructure development, pollution, water extraction, and land-use change. A restoration strategy that focuses primarily on invasive alien species risks treating symptoms rather than causes. The current draft also appears to privilege invasive alien species management over ecological restoration itself. Clearing invasive species does not automatically result in ecosystem recovery. Restoration should be measured by improvements in ecosystem functioning, biodiversity recovery, ecological integrity, habitat connectivity, water regulation, and soil health and resilience, rather than by hectares cleared alone. The NBSAP should therefore include indicators that assess ecological outcomes and not merely restoration activities. A further concern relates to ambition. KMGBF Target 2 commits the Parties to ensuring that at least 30% of degraded ecosystems are effectively restored by 2030. It is therefore unclear why South Africa proposes restoring only 22% of degraded ecosystems by 2035. If resource constraints are the reason, they should be explicitly stated and accompanied by a pathway to progressively increase ambition. As currently drafted, the target appears inconsistent with the level of ambition envisaged under the KMGBF. Importantly, restoration should not be confined to formally protected landscapes. South Africa's biodiversity crisis is occurring across working landscapes, agricultural areas, catchments, and communal lands. Restoration efforts should therefore include support for agroecological transitions, restoration of soil biodiversity, riparian rehabilitation, pollinator recovery, landscape connectivity, and the regeneration of degraded production systems. Biodiversity restoration and agricultural transformation should be treated as mutually reinforcing objectives rather than separate policy domains. The NBSAP should also strengthen the social dimensions of restoration. Restoration interventions can have profound implications for access to land, water, and natural resources. For this reason, restoration activities must be guided by environmental justice, equitable participation, transparency, accountability, and secure tenure rights. The principles of Ubuntu and Duty of Care articulated in South Africa's Biodiversity White Paper provide an important foundation for ensuring that restoration contributes simultaneously to ecological recovery and social well-being. Caution is required regarding the proposed use of biodiversity credits, carbon credits, biodiversity offsets, and related market-based instruments to finance restoration. Restoration should not become dependent on mechanisms that permit continued environmental destruction elsewhere or

that commodify biodiversity and ecosystem functions. Public finance, redirected harmful subsidies, community-based conservation funds, and locally accountable restoration programmes provide more equitable and ecologically robust alternatives. Finally, stronger linkages should be established between this thematic area and those addressing pollution, climate resilience, agricultural transformation, and ecosystem conservation. Restoration will only be durable if the activities causing degradation are simultaneously reduced or eliminated. Otherwise, restoration efforts risk becoming an ongoing cycle of rehabilitation without addressing the underlying causes of biodiversity loss.

We therefore recommend: • • • • • •

South Africa provides a clear justification for the proposed restoration target of 22% by 2035 and indicate how this aligns with KMGBF Target 2. Indicators be strengthened to measure ecosystem recovery, ecological integrity, and ecosystem functioning rather than hectares treated or cleared alone. Invasive alien species management remains a priority but should be situated within a broader strategy that addresses the multiple drivers of ecosystem degradation. Restoration actions explicitly include agroecological restoration, soil regeneration, landscape connectivity, and biodiversity recovery within production landscapes. Restoration programmes be implemented through rights-based approaches that secure participation, tenure rights, and community governance. References to biodiversity credits, offsets, and related market-based mechanisms should be removed or substantially qualified by robust social, ecological, and governance safeguards.

Ecosystem conservation This thematic area addresses KMGBF Target 3, which commits Parties to effectively conserve and manage at least 30% of terrestrial, inland water, coastal and marine areas by 2030 through ecologically representative, well-connected, effectively governed, and equitably managed systems of protected areas and OECMs. The national target proposes that by 2035 South Africa will expand protected and conserved areas to cover 21% of terrestrial and freshwater areas and 20% of marine areas. ACB welcomes the recognition that protected and conserved areas remain fundamental components of biodiversity conservation. However, it is unclear why South Africa's proposed targets fall significantly below the level of ambition established under the KMGBF. While the draft NBSAP indicates that current targets are informed by the National Protected Area Expansion Strategy and available financing commitments, the rationale for maintaining substantially lower targets than those agreed internationally should be explicitly justified and accompanied by a pathway for progressively increasing ambition.

At the same time, biodiversity conservation cannot be reduced to numerical area-based targets. The effectiveness of conservation depends not only on the quantity of land or sea brought under conservation management, but also on ecological representation, connectivity, governance quality, long-term management effectiveness, and the ability to address the underlying drivers of biodiversity loss. Expansion alone will not halt biodiversity decline if destructive activities continue elsewhere across landscapes and seascapes. The draft NBSAP should therefore place greater emphasis on conservation effectiveness and ecological integrity. Protected areas must be connected to wider ecological landscapes and supported by broader interventions that address habitat loss, land degradation, pollution, unsustainable production systems and climate change. Conservation should be understood as a landscape-scale undertaking rather than being confined to formally designated protected areas. Particular attention should be given to the social and historical dimensions of conservation. Across Africa and globally, conservation has often been associated with displacement, exclusion, and restrictions on access to land and natural resources. The implementation of Target 3 provides an opportunity to move beyond these approaches. Any expansion of protected areas, stewardship programmes, or OECMs should be guided by human rights, secure tenure, FPIC, equitable governance, and meaningful participation by Indigenous Peoples and Local Communities, smallholder farmers, pastoralists, and small-scale fishing communities. Conservation outcomes are more likely to be durable when local communities are recognised as rights holders and conservation partners rather than as beneficiaries or obstacles. ACB strongly supports retaining and strengthening provisions on equitable governance within this thematic area. These provisions should be extended to explicitly recognise customary governance systems, community conserved areas, and locally governed conservation initiatives as legitimate and important contributions to national biodiversity goals. The draft NBSAP also presents an opportunity to broaden the understanding of OECMs. Biodiversity conservation occurs not only within protected areas but also within working landscapes and seascapes where communities actively maintain ecological functions and biodiversity. Agroecological farming systems, pastoral systems, and community-managed fisheries often support habitat connectivity, soil biodiversity, pollinator populations, water conservation, and landscape resilience while simultaneously producing food and sustaining livelihoods. Where these systems demonstrably contribute to long-term biodiversity outcomes, they should be recognised and supported as OECMs. Recognising agroecological production landscapes as OECMs would help bridge the artificial divide between conservation and production. It would also align biodiversity conservation with broader objectives relating to food sovereignty, climate resilience, restoration, agricultural biodiversity, and sustainable livelihoods. Such recognition would be particularly important for smallholder farming communities, pastoralists, and small-scale fishing communities whose stewardship of biodiversity has historically been overlooked within formal conservation frameworks. Finally, the question of financing conservation requires careful consideration. While additional resources are undoubtedly necessary to support conservation expansion and management, financing mechanisms should strengthen community stewardship, ecological integrity and long-term

public accountability. Community trust funds, stewardship support mechanisms, and locally governed conservation financing arrangements may provide more socially just and ecologically appropriate alternatives than market-based instruments, which risk commodifying biodiversity and conservation outcomes.

We therefore recommend that: • • • • • •

South Africa provides a clear justification for conservation targets that fall below the KMGBF commitment to conserve 30% of terrestrial, freshwater, coastal, and marine areas. Greater emphasis is placed on ecological effectiveness, representation, connectivity, and governance quality rather than on area-based expansion alone. All conservation expansion be implemented through rights-based approaches grounded in FPIC, secure tenure, equitable governance, and meaningful participation. Community conserved areas, customary governance systems, and locally governed conservation initiatives be explicitly recognised and supported. Agroecological production systems, pastoral landscapes, and community-managed fisheries that contribute to long-term biodiversity outcomes be considered for recognition as OECMs. Conservation finance mechanisms prioritise community stewardship, public accountability, and long-term ecological integrity.

Species conservation This thematic area addresses KMGBF Target 4, which seeks to halt human-induced extinctions, support species recovery, maintain genetic diversity within and between populations, and safeguard the adaptive potential of wild and domesticated species. South Africa's proposed national target is to prevent new extinctions, support the recovery of priority threatened species, maintain genetic diversity, and improve species protection levels by 10% by 2035. ACB welcomes the inclusion of genetic diversity within this thematic area and supports actions to improve the assessment and monitoring of indigenous species, crop wild relatives, landraces, and domesticated genetic resources. These actions acknowledge that biodiversity conservation extends beyond species protection to include the conservation of the genetic diversity on which ecological resilience, food systems, and adaptation depend. However, the current framing remains heavily weighted towards species recovery and ex-situ conservation, while giving insufficient attention to the dynamic processes through which genetic diversity is maintained, regenerated, and adapted within landscapes and farming systems. Biodiversity is conserved not only in protected areas, seed banks, and biobanks. It is also conserved through the everyday practices of farmers, pastoralists, and local communities who continue to save, exchange, select, breed, and adapt plants and animals in response to changing ecological, climatic, and social conditions. The conservation of crop wild relatives, landraces, indigenous livestock breeds, and other agricultural biodiversity is therefore not simply a conservation issue. It is also a question of food sovereignty, resilience, governance, and justice. These genetic resources form part of a shared

biological heritage that has been collectively developed and maintained over generations. Their continued existence depends not only on technical conservation interventions but also on the communities, knowledge systems, and ecological relationships that sustain them. Particular attention should be given to indigenous and underutilised crops. These crops are often adapted to local ecological conditions, require fewer external inputs, contribute to dietary diversity, and possess valuable traits related to drought tolerance, climate resilience, and resistance to pests and diseases. Yet they remain marginalised within agricultural research systems, breeding programmes, extension services, and public policy. Their decline reflects not only biodiversity loss but also the erosion of knowledge systems, food cultures, and local seed systems that have historically sustained agricultural diversity. The current draft also fails to adequately address the relationship between biodiversity loss and increasing concentration within the seed sector. Globally, seed systems have become increasingly consolidated within a small number of corporations, contributing to greater genetic uniformity, narrowing breeding priorities, and increasing dependence on proprietary seed systems. This trend has accelerated the erosion of agricultural biodiversity and weakened farming communities' capacity to maintain locally adapted diversity. Conservation of genetic diversity, therefore, requires confronting the structural drivers that contribute to its loss. A strategy focused solely on conserving genetic resources while ignoring the systems that are eroding them will be insufficient. For this reason, the NBSAP should place far greater emphasis on rebuilding and strengthening public-interest breeding. Public breeding programmes play a critical role in maintaining broad genetic pools, supporting locally adapted crops and livestock, responding to public rather than commercial priorities, and ensuring that genetic resources remain available for future generations. These have historically contributed significantly to the conservation and development of agricultural biodiversity and remain essential for advancing agroecological transitions, climate resilience, and food sovereignty. Support for public-interest breeding should not be confined to major commercial crops. Public investment should prioritise indigenous crops, underutilised crops, crop wild relatives, and farmers' varieties and landraces, including participatory breeding initiatives that directly involve farmers and farming communities. Such approaches help maintain diversity within production systems while strengthening local adaptation and resilience. Similarly, FMSS should be recognised as central institutions of biodiversity conservation. FMSS continue to supply seed for millions of farmers and remain among the most important mechanisms through which crop diversity is conserved, exchanged, and adapted. Through seed saving, exchange, selection, and local innovation, farmers actively maintain genetic diversity that is frequently absent from formal conservation systems. Yet these systems receive little policy support despite their enormous contribution to biodiversity conservation. The NBSAP should therefore explicitly recognise FMSS as a cornerstone of agricultural biodiversity conservation and provide support for community seed banks, local seed networks, seed exchange initiatives, farmer-led conservation programmes, and participatory plant breeding. Strengthening FMSS is not merely an agricultural intervention. It is a biodiversity conservation intervention.

Stronger linkages should also be established between this thematic area and the Access and Benefit Sharing, Agricultural Transformation, and Knowledge, Participation, and Inclusion thematic areas. The conservation of genetic diversity cannot be separated from farmers' rights, traditional knowledge, customary governance systems, access to genetic resources, and equitable benefitsharing. Genetic diversity is embedded within social and ecological relationships and should not be treated solely as a biological resource. Ultimately, species conservation should not be understood only as preventing extinction. It should be understood as maintaining the ecological, genetic, cultural, and social foundations that enable biodiversity to evolve, adapt, and flourish. Conserving biodiversity, therefore, requires support for the commons-based systems that continue to generate and sustain diversity, including FMSS, Indigenous and local knowledge systems, public-interest breeding institutions, and agroecological production systems.

We therefore recommend that: • • •

•

• • •

•

Greater emphasis be placed on the in-situ conservation and sustainable use of crop wild relatives, indigenous crops, landraces, and indigenous livestock diversity. The NBSAP explicitly recognise FMSS as a primary mechanism for conserving and regenerating agricultural biodiversity. Public investment in public-interest breeding programmes be substantially increased, with particular attention to indigenous crops, underutilised crops, farmers' varieties, landraces, and crop wild relatives. Public breeding institutions be adequately resourced to conserve, develop, and make available diverse genetic resources in ways that serve public rather than purely commercial interests. Participatory plant breeding, community seed banks, farmer-led seed conservation initiatives, and local seed exchange networks be explicitly supported. Farmers' rights to save, use, exchange, improve, and sell farm-saved seed be recognised as integral components of biodiversity conservation. Indicators be developed to monitor the status of genetic diversity within farming systems, FMSS, and indigenous crop production, rather than focusing exclusively on ex-situ collections. Stronger linkages should be established among the Species Conservation, Agricultural Transformation, Access and Benefit Sharing, and Knowledge and Participation thematic areas. Dedicated support be provided for the conservation, cultivation, breeding, distribution, and use of indigenous and underutilised crops as part of broader efforts to strengthen biodiversity, resilience, food sovereignty, and the commons.

Sustainable use and the biodiversity economy This thematic area addresses KMGBF Targets 5, 9, and 16. Together, these targets seek to ensure that: • • •

the use, harvesting, and trade of wild species are sustainable, safe, and legal; biodiversity continues to provide social, economic and environmental benefits to people; and unsustainable consumption patterns are reduced.

The KMGBF places particular emphasis on protecting and encouraging customary sustainable use by Indigenous Peoples and Local Communities (IPLCs), ensuring that biodiversity contributes to human well-being while maintaining ecological integrity. The draft NBSAP establishes the following national target: By 2035, achieve a transformed, inclusive, and viable biodiversity economy that ensures sustainable management, harvest, and use of wild species, safe and legal trade, while protecting and encouraging customary sustainable use by local communities. While understanding the need to protect customary use and traditional knowledge, it is also important to recognise the threats towards certain species related to their use in the production and sale of muthi (traditional medicine). This threat applies particularly to certain bird and snake species, but also to other animals. While there are positive aspects to this thematic area, including attention to unsustainable fisheries, by-catch reduction measures, customary use, and animal welfare considerations, the overall framing remains problematic. The draft treats biodiversity primarily as an economic sector to be expanded, rather than as a public good, a commons, a source of livelihoods, cultural identity, food security, and ecological resilience. The concept of a biodiversity economy is increasingly promoted internationally and nationally as a means of linking conservation and development. However, biodiversity cannot be reduced to an economic asset class or a collection of market opportunities. Biodiversity underpins ecosystem functioning, food systems, water security, cultural practices, climate resilience, and community wellbeing. Economic benefits may arise from biodiversity, but they must remain subordinate to ecological integrity, rights, and sustainability. A central weakness of the current draft is that it conflates sustainable use with commercialisation. The expansion of biodiversity-based value chains, bioprospecting markets, wildlife industries, and biodiversity enterprises is treated as inherently positive, despite the absence of clear safeguards to prevent overexploitation, elite capture, privatisation of common resources, inequitable benefit distribution, and the commodification of biodiversity.

Yet international experience demonstrates that assigning economic value to biodiversity does not automatically lead to conservation outcomes and may, in some circumstances, undermine ecological integrity and community rights in the absence of appropriate governance frameworks. The NBSAP should therefore distinguish clearly between: • • • • • •

sustainable use; customary use; subsistence use; biodiversity-based livelihoods; biodiversity enterprises; and biodiversity markets.

These are not interchangeable concepts. The KMGBF is clear that customary sustainable use must be respected and protected. Sustainable use should therefore begin with the rights, knowledge systems, governance institutions, and livelihood needs of the communities who directly depend on biodiversity, rather than from assumptions about market growth or commercial expansion. While understanding the need to protect customary use and traditional knowledge, it is also important to recognise the threats towards certain species related to their use in the production and sale of muthi (traditional medicine). This threat applies particularly to certain bird and snake species, but also to other animals. Particular attention should be given to small-scale fishing communities, pastoralists, forestdependent communities, medicinal plant users, traditional healers, seed custodians, and other biodiversity-dependent communities whose livelihoods are often threatened by industrial extraction, privatisation, exclusionary conservation models, and inequitable value chains. These communities are frequently portrayed as beneficiaries of biodiversity programmes when in reality they are already biodiversity stewards and rights holders. Their role should therefore be recognised and supported rather than subordinated to commercial biodiversity development initiatives. The draft also overlooks the relationship between biodiversity use and food systems. Sustainable use cannot be confined to wildlife, fisheries, and bioprospecting. Agricultural biodiversity, traditional livestock breeds, FMSS, indigenous crops, wild foods, pollinators, and agroecological production systems all contribute to the use of biodiversity while simultaneously supporting food sovereignty and ecosystem resilience. Stronger linkages are therefore required with the Agricultural Transformation, Species Conservation, and Access and Benefit Sharing thematic areas. The treatment of sustainable consumption under Target 16 is similarly weak. Unsustainable consumption is a significant driver of biodiversity loss globally and nationally. Yet the draft focuses overwhelmingly on increasing biodiversity-based economic activities while providing limited attention to reducing unsustainable consumption patterns, waste generation, overconsumption of natural resources, and environmentally damaging production systems. A genuinely transformative approach would address both production and consumption systems simultaneously.

In addition, the NBSAP should explicitly recognise that biodiversity use occurs within unequal economic and political systems. Corporate concentration, unequal market power, land inequality, barriers to market access, and unequal benefit-sharing frequently determine who benefits from biodiversity and who bears the ecological and social costs of its exploitation. Sustainable use therefore requires governance reforms, not simply market expansion.

Proposed revised national target By 2035, biodiversity is used, managed, harvested, and traded in ways that are ecologically sustainable, socially equitable, and rights-based, maintaining ecosystem integrity while supporting food sovereignty, livelihoods, cultural practices, customary sustainable use, community wellbeing, and the fair distribution of benefits.

Proposed indicators: Sustainable use 1. 2. 3. 4. 5.

Status and trends of priority wild species subject to harvesting and use. Number of wild species management systems operating under sustainable-use frameworks. Percentage of fisheries operating within scientifically determined sustainable limits. Reduction in by-catch and non-target species mortality. Number of biodiversity-dependent livelihoods supported through sustainable-use programmes.

Rights and customary use 1. Number of policies, programmes, and management systems recognising and protecting customary sustainable use. 2. Number of small-scale fishing, pastoralist, forest-dependent, and biodiversity-dependent communities participating in governance and decision-making processes. 3. Percentage of biodiversity-use programmes incorporating FPIC and equitable benefit-sharing mechanisms where applicable. 4. Number of policies and programmes educating about the threat of extinction of animals used in muthi (traditional medicine) production, and regulating or finding alternatives to killing threatened species.

Biodiversity-dependent livelihoods 1. Number of community-owned or community-controlled biodiversity enterprises. 2. Value of benefits retained by local communities from biodiversity-related activities. 3. Number of biodiversity stewardship and conservation initiatives directly supporting local livelihoods.

Sustainable consumption 1. National measures adopted to reduce unsustainable consumption patterns impacting biodiversity. 2. Reduction in biodiversity-related waste streams and resource-intensive consumption practices. 3. Number of public procurement programmes incorporating biodiversity sustainability criteria. 4. National measures guiding local use of birds, snakes, and other animals for muthi (traditional medicine) adopted to protect these species.

Additional actions By 2027 • • • •

Develop a national framework for customary sustainable use and biodiversity-dependent livelihoods. Review biodiversity economy policies to assess impacts on rights, equity, biodiversity outcomes, and community benefit-sharing. Establish baseline data on biodiversity-dependent livelihoods and customary-use systems. Develop sustainable consumption indicators aligned with KMGBF Target 16.

By 2030 • • • • •

Strengthen legal recognition of customary sustainable use and community governance systems. Expand support for small-scale fisheries, pastoralists, medicinal plant users, and other biodiversity-dependent communities. Establish transparent benefit-sharing mechanisms for biodiversity-related enterprises and value chains. Reduce unsustainable harvesting and by-catch in priority sectors. Introduce biodiversity-sensitive public procurement standards.

By 2035 • • • •

Demonstrate measurable improvements in biodiversity status associated with sustainableuse programmes. Demonstrate increased benefits retained by biodiversity-dependent communities. Demonstrate reductions in unsustainable consumption pressures affecting biodiversity. Ensure that biodiversity-related economic activities contribute to ecological integrity, social equity, and community well-being.

ACB recommendations ACB therefore recommends that: 1. The thematic area be reframed around sustainable use, rights, and livelihoods, rather than biodiversity economy growth alone. 2. Customary sustainable use should be treated as a central pillar of implementation, not a subsidiary component. 3. Stronger linkages should be established with agroecology, agricultural biodiversity, FMSS, and food sovereignty. 4. Sustainable consumption measures under KMGBF Target 16 be significantly strengthened. 5. Biodiversity-related enterprises be subject to ecological, social, and rights-based safeguards. 6. Community governance, equitable benefit-sharing, and local ownership be prioritised over purely commercial biodiversity development models. 7. Biodiversity is not treated primarily as a market asset, but as a public good that sustains ecological integrity, livelihoods, cultural identity, and collective well-being.

Pollution and waste management This thematic area addresses KMGBF Target 7, which seeks to reduce pollution from all sources to levels that are not harmful to biodiversity and ecosystem functions, including excess nutrients, pesticides, hazardous chemicals, and plastic pollution. South Africa's proposed national target is to reduce pollution from all sources to levels that are not harmful to biodiversity and ecosystem services through improved management of waste, wastewater, effluent, nutrient loading, pesticides, hazardous chemicals, and other contaminants. ACB welcomes the inclusion of a dedicated pollution target and recognises the important actions included in relation to HHPs, pesticide regulation, agrochemical runoff, and hazardous chemical management. However, the current framing remains largely focused on managing pollution after it has been generated, rather than addressing the production systems and economic drivers that produce it in the first place. Pollution is not merely a waste-management challenge. It is a symptom of broader production systems that externalise ecological and social costs. In South Africa, industrial agriculture remains a major source of nutrient pollution, pesticide contamination, soil degradation, biodiversity loss, and water pollution. Excessive dependence on synthetic fertilisers, pesticides, and other chemical inputs has become embedded within dominant agricultural systems, generating cumulative impacts across terrestrial, freshwater, and marine ecosystems. The NBSAP should therefore move beyond pollution control and explicitly address pollution prevention. This requires recognising that biodiversity protection will not be achieved through improved management of pollutants alone, but through transitions away from production systems that are inherently pollution intensive. Reducing pollution and restoring biodiversity will require

support for agroecological farming systems, integrated pest management, diversified production systems, biological pest control, soil regeneration, and reduced dependence on synthetic inputs. Particular attention should be given to HHPs. South Africa has already committed to phasing out active ingredients and formulations that meet internationally recognised criteria for carcinogenicity, mutagenicity, and reproductive toxicity. This commitment should be reflected more strongly within the NBSAP through explicit timelines, monitoring mechanisms, and accountability measures. Delayed implementation, exemptions, and derogations risk undermining biodiversity protection and public health objectives. Clearer actions are required to prevent weak implementation across departments, and, in some cases, to ensure the proper use of such HHPs, as in the derogation case for glufosinate ammonium in South Africa.6 Therefore, South Africa must lead boldly and phase out HHPs without delay. Limited data availability on pesticide environmental concentrations and/or aggregated total applied toxicity reflects a weak national monitoring system that needs strengthening. In general, there is a lack of data regarding pollution from all sources, as well as sales and applications of pesticides and synthetic fertilisers (CBD, 2026). The current draft also highlights significant limitations in available data relating to pesticide use, pesticide toxicity, environmental concentrations, fertiliser application, and broader pollution trends. These data gaps should not be treated merely as technical shortcomings. They represent a significant governance challenge. Effective biodiversity protection requires transparent, publicly accessible systems for monitoring pollution sources, pollution levels, and ecological impacts. Without such information, it will be difficult to assess progress against either national targets or KMGBF commitments. ACB is also concerned that emerging biotechnologies are insufficiently integrated into discussions of pollution. New technologies, including RNAi-based sprays, genetically engineered pesticides, and other gene-silencing technologies, are increasingly blurring the boundaries among pesticides, biotechnology, and biosafety governance. These technologies raise unresolved questions regarding environmental persistence, non-target effects, ecological interactions, monitoring, liability, and regulatory oversight. The NBSAP should explicitly recognise these emerging risks and ensure close alignment between this thematic area and the Biosafety and Biotechnology thematic area. Similarly, greater attention should be given to nutrient pollution. Excessive application of synthetic fertilisers contributes to eutrophication, freshwater degradation, soil degradation, and biodiversity loss. The NBSAP should therefore include actions aimed at reducing dependence on synthetic fertilisers through improved nutrient cycling, composting, organic soil fertility management, and agroecological approaches that rebuild soil health while reducing nutrient losses. The treatment of plastic pollution also requires strengthening. Although KMGBF Target 7 explicitly includes plastic pollution, South Africa's draft NBSAP offers limited recognition of this growing threat. Despite KMGBF’s explicit call to work towards eliminating plastic pollution, South Africa’s NBSAP is silent on this issue. Plastic waste poses a severe threat to biodiversity, with countless animals dying from plastic ingestion or entanglement every year, and many more are affected by the

6 See ACB’s objections here

toxicity of plastic compounds and additives leached into the environment (Li et al., 2020; AzevedoSantos et al., 2021). Therefore, we suggest adding a national indicator and/or action, such as implementing regulations to prevent, reduce, and ultimately eliminate plastic pollution, to address this escalating crisis, which impacts terrestrial, aquatic, and marine biodiversity and ecosystem health. More broadly, pollution should be viewed through the lens of the White Paper's Duty of Care principle. Activities that generate persistent pollution and harm to biodiversity should not simply be managed more efficiently. They should be progressively reduced, substituted or eliminated where safer and more ecologically sustainable alternatives exist. Pollution prevention, precaution and accountability should therefore become organising principles of this thematic area.

We therefore recommend that: • • • • •

• • •

The NBSAP places greater emphasis on pollution prevention rather than on pollution management alone. Explicit links be made between pollution reduction and agroecological transitions, including reduced dependence on synthetic fertilisers and pesticides. South Africa establishes clear timelines and accountability measures for the phase-out of HHPs. National monitoring systems for pesticide use, pesticide toxicity, nutrient pollution, and environmental contamination be significantly strengthened and made publicly accessible. Emerging technologies including RNAi-based sprays, genetically engineered pesticides, and related technologies be explicitly recognised as potential sources of environmental risk requiring precautionary oversight. Additional actions be included to reduce nutrient pollution through soil health restoration, nutrient recycling, and agroecological nutrient management. A dedicated indicator and associated actions addressing plastic pollution reduction and elimination be incorporated into the NBSAP. The Duty of Care principle be explicitly applied to pollution-generating activities, prioritising avoidance, substitution, and reduction of harmful pollutants at source.

Ecological infrastructure and climate resilience This thematic area addresses KMGBF Targets 8 (Minimise the impacts of climate change on biodiversity and build resilience) and 11 (Restore, maintain, and enhance nature's contributions to people). The national target under this thematic area is: By 2035, ecosystem-based adaptation, or nature-based solutions, are implemented to restore and maintain ecological infrastructure, including strategic water source areas, to enhance the resilience of ecosystems, species, and communities to climate change and ocean acidification, thereby reducing climate-related disaster risks and generating other societal benefits. The inclusion of ecological infrastructure, ecosystem-based adaptation (EbA), strategic water source areas, climate resilience, and the alignment of South Africa's biodiversity and climate commitments

are important and welcome developments. In particular, efforts to align South Africa's Nationally Determined Contributions (NDCs) and the NBSAP are necessary, given the increasing recognition that climate change and biodiversity loss are deeply interconnected crises. However, the current framing remains insufficiently ambitious and fails to adequately address the climate crisis's scale and complexity. Climate change is largely treated as an external pressure to which biodiversity must adapt. Yet biodiversity loss and climate change are not separate crises. They are driven by many of the same underlying economic, political, and production systems, including industrial agriculture, fossil fuel dependence, extractivism, deforestation, unsustainable consumption patterns, land degradation, and the increasing concentration of economic power. Addressing climate impacts on biodiversity therefore requires confronting the drivers of both crises simultaneously, rather than treating climate change as a discrete environmental variable. The thematic area also places insufficient emphasis on mitigation. While Target 8 focuses on adaptation and resilience, biodiversity policy cannot ignore the fact that biodiversity protection itself is impossible without rapid reductions in greenhouse gas emissions. Ecological resilience has limits. Beyond certain warming thresholds, ecosystems may experience irreversible transformation regardless of adaptation interventions. Climate resilience strategies should therefore be explicitly linked to measures that reduce emissions while simultaneously protecting biodiversity, strengthening local food systems, and supporting social justice. This requires closer integration among biodiversity, climate, agricultural, energy, and land-use policies. Particularly concerning is the continued reliance on the concept of Nature-based Solutions (NbS). While NbS are increasingly promoted as responses to climate change and biodiversity loss, their definitions remain broad, ambiguous, and vulnerable to misuse. As currently applied, the term may encompass activities ranging from ecological restoration and community-led conservation to industrial tree plantations, carbon offset projects, conservation enclosures, and other interventions that may have adverse impacts on biodiversity, livelihoods, and rights. The risk is not merely conceptual. The lack of clear safeguards creates opportunities for climate mitigation and adaptation projects to proceed under the NbS banner while reproducing social exclusion, land dispossession, and ecological simplification. As Kill (2024) argues, the growing popularity of NbS has created significant risks of co-option, particularly where climate mitigation objectives become prioritised over biodiversity, rights, and social justice outcomes. With NbS now embedded within international biodiversity and climate governance frameworks, robust safeguards become increasingly important. Any use of NbS within the NBSAP should therefore be conditional upon explicit human rights protections, secure land tenure, FPIC, equitable benefit-sharing, transparency, accountability, and demonstrated biodiversity benefits. Activities such as industrial monoculture plantations should not be recognised as biodiversity-positive climate responses simply because they generate carbon benefits. More broadly, the draft does not adequately recognise that some climate responses may themselves pose risks to biodiversity. Renewable energy infrastructure, carbon markets, carbon offset projects, afforestation schemes, bioenergy expansion, and other climate-related interventions may generate significant ecological and social impacts if poorly designed.

Biodiversity policy should therefore assess climate interventions through a precautionary lens and ensure that climate action does not become another driver of biodiversity loss, land concentration, or community displacement. Climate resilience must not be achieved at the expense of ecological integrity or social justice. The NBSAP should also more explicitly acknowledge that climate change is already reshaping ecological systems in South Africa. Species distributions, fire regimes, rainfall patterns, freshwater availability, coastal processes, and ecosystem functions are changing, often in ways that challenge traditional conservation assumptions. As Schlaepfer and Lawler (2022) note, climate change may require conservation approaches that recognise ecological change rather than attempting to preserve static historical conditions. This creates difficult governance questions regarding ecological transitions, assisted adaptation, shifting species distributions, and the future configuration of conservation landscapes. These issues receive little attention in the current draft despite their growing significance for biodiversity governance. Climate adaptation should therefore move beyond protecting existing biodiversity assets towards supporting ecological transitions that maintain ecosystem functions, resilience, and human wellbeing under changing climatic conditions. This includes strengthening ecological connectivity, restoring degraded ecosystems, protecting climate refugia, improving landscape-scale planning, and supporting adaptive governance approaches capable of responding to uncertainty and change. The role of agroecology within climate resilience is also significantly underdeveloped. South Africa's biodiversity and climate strategies should explicitly recognise agroecological transitions as among the most effective pathways for simultaneously addressing biodiversity loss, climate vulnerability, food insecurity, and rural livelihoods. Agroecological systems enhance soil carbon, improve water retention, reduce dependence on fossilfuel-derived inputs, strengthen biodiversity, diversify production systems, and increase resilience to climatic shocks. Yet agroecology remains largely absent from this thematic area despite its direct relevance to both biodiversity and climate objectives. The NBSAP should therefore establish stronger links between ecological infrastructure, agricultural transformation, and food-system resilience. Strategic water source areas, wetlands, riparian systems, grasslands, rangelands, and agroecological landscapes should be understood not only as biodiversity assets but also as critical climate adaptation infrastructure. Public investment in ecological infrastructure should simultaneously support biodiversity recovery, water security, climate resilience, and food sovereignty. A further concern relates to rights and governance. The draft refers generally to community resilience but does not sufficiently recognise IPLCs as rights holders and governance actors in climate adaptation processes. Climate adaptation interventions frequently affect land use, resource access, conservation management, and development priorities. The rights, knowledge systems, and governance institutions of IPLCs should therefore be central to adaptation planning rather than treated as stakeholders to be consulted after decisions have been made. Strengthening the rights of IPLCs is not merely a social objective; it is a biodiversity and climate imperative.

The White Paper's principles of Ubuntu and Duty of Care provide a particularly useful framework for this thematic area. Climate resilience should not be understood narrowly as technical risk management. Rather, it should be understood as strengthening reciprocal relationships between people, ecosystems, and future generations, while ensuring that those most vulnerable to climate impacts are supported through equitable and democratic governance arrangements. We therefore suggest:

Proposed revised national target By 2035, ecological infrastructure, ecosystem integrity and biodiversity are restored, maintained and governed in ways that strengthen climate resilience, food sovereignty, water security, and community well-being, while contributing to climate mitigation, supporting ecological adaptation to climate change, protecting the rights of IPLCs, and ensuring that climate responses do not generate new forms of biodiversity loss, ecological degradation, or social injustice.

Additional actions • • • • • •

• •

Align biodiversity, climate, agriculture, land-use, and water governance policies within a coherent national framework. Recognise agroecological transitions as a central climate adaptation and mitigation strategy. Identify and protect climate refugia, ecological corridors, and priority adaptation landscapes. Develop safeguards to ensure that climate mitigation and adaptation projects do not undermine biodiversity, land rights, tenure security, or community governance. Require all NbS initiatives to demonstrate measurable biodiversity benefits and compliance with human-rights-based safeguards. Establish monitoring systems to assess biodiversity impacts associated with renewable energy infrastructure, carbon projects, afforestation initiatives, and other climate-related interventions. Strengthen the participation and decision-making authority of IPLCs in climate adaptation planning and implementation. Integrate biodiversity objectives directly into climate adaptation planning and climate objectives directly into biodiversity planning.

Additional indicators • • • • • •

Area of ecological infrastructure that simultaneously contributes to biodiversity conservation, climate resilience, and water security. Number of climate adaptation initiatives incorporating FPIC and rights-based safeguards. Area of agroecological landscapes contributing to climate resilience and biodiversity outcomes. Status and connectivity of climate refugia and ecological corridors. Biodiversity impacts associated with climate mitigation and adaptation projects. Number of biodiversity and climate policies jointly implemented across sectors.

Access and benefit sharing Access and benefit sharing should not be understood merely as a regulatory compliance mechanism governing access to genetic resources. It is fundamentally concerned with justice, equity, conservation, and the governance of biodiversity. Its effectiveness depends on whether the communities, farmers and Indigenous Peoples who conserve, develop, use, and transmit biodiversity and associated knowledge are recognised as rights holders and can exercise meaningful authority over those resources and knowledge systems. This national target addresses target 13 (increase the sharing of benefits from genetic resources, digital sequence information, and traditional knowledge) under the KMGBF. The target is: By 2035, increase fair and equitable benefit sharing by ensuring more users of genetic resources and traditional knowledge are compliant with access and benefit sharing requirements, resulting in measurable growth of monetary and non-monetary benefits for biodiversity conservation and for indigenous peoples, local communities and farmers as rights holders. There are five national indicators and 10 actions under this thematic area. South Africa takes significant steps here; first, through regulatory reform to incorporate digital sequence information, and; second, by advancing farmers’ rights, agroecology, and agricultural biodiversity more broadly.7 While the national indicator and actions are vital steps in this regard, the focus is on seed banks and ex-situ conservation of crop wild relatives and farmers’ varieties, neglecting the fact that agrobiodiversity needs to be conserved and adapted in situ, i.e., on farms. The conservation of crop wild relatives, landraces, and indigenous genetic resources cannot be reduced to ex situ conservation in seed banks or biobanks. In situ and on-farm conservation through farmers’ practices, seed saving, exchange, selection, local adaptation, and community seed systems must be recognised, protected, and funded. The NBSAP should also explicitly support legal and policy reforms that give effect to farmers’ rights to save, use, exchange, and sell farm-saved seed, and ensure that benefit-sharing does not become a narrow compliance exercise detached from the communities who sustain agricultural biodiversity. We therefore suggest that this be included under this indicator: By 2035, increase the number of indigenous genetic resources, including crop wild relatives and indigenous landraces secured both in-situ and ex-situ. This thematic area relates to target 4 of the KMGBF on genetic diversity (thematic area Species Conservation in SA’s NBSAP), and Target 21 on participation and knowledge (thematic area Knowledge, Participation and Inclusion). It would be good to indicate the connection to both these thematic areas under this thematic area. In addition, there is a need to develop lawful and equitable genetic sequence data governance and database engineering that aligns with open science principles while fully recognising the sovereign rights of states and the rights of IPLCs over their genetic resources. This requires engagement with

7 Implement the International Treaty on Plant Genetic Resources for Food and Agriculture (ITPGRFA) by ensuring agricultural

policies reflect farmers’ rights, conserving plant genetic resources for food and agriculture, and promoting agroecological farming systems and update, publish, and implement the National Strategic Action Plan for the Conservation and Sustainable Use of Crop Wild Relatives in South Africa.

evolving governance frameworks such as the FAIR,8 CARE,9 and TRUST10 principles, as well as the more recent LISTEN11 principles, to reconcile open science with ethical, legal, and equity

considerations in the governance of genetic sequence data (Carlson et al., 2025). It is suggested that South Africa recognises and gives effect to the rights articulated in the United Nations Declaration on the Rights of Indigenous Peoples and the United Nations Declaration on the Rights of Peasants and Other People Working in Rural Areas, to recognise and realise the rights of IPLCs, including smallholder farming communities, to make ABS effective and meaningful for equitable use and conservation of biodiversity and its associated knowledge.

Biosafety and benefits of biotechnology This national target addresses target 17 (strengthen biosafety and distribute the benefits of biotechnology) of the KMGBF. The national target is: By 2035, strengthen capacity and enhance implementation of biosafety measures for the safe transfer, handling, use, and release of genetically modified organisms into the environment, and facilitate equitable participation in biotechnology research, development and access to its benefits, while minimising risks to biodiversity and human health. There are three national indicators and eight actions under this thematic area. This target is heavily skewed towards the benefits of biotechnology, without adequate considerations of the biosafety risks associated with genetic engineering. This is not surprising, as South Africa is a pro-biotech country, with a history of the use of such products, despite clear and notable impacts on biodiversity, such as through the indiscriminate use of associate agrochemicals. Even today there is a process underway to commercialise genetically modified Canola, despite there being wild relatives in many parts of the country.12 While actions under this target identify the need to strengthen and maintain human and institutional capacity for reviewing applications of genetically modified organisms, conducting risk assessments, detection, identification, monitoring environmental impacts, and ensuring compliance and enforcement, we are concerned with the overall—and almost absolute—promotion of biotechnology under this thematic area. Biosafety cannot be reduced to capacity building for approvals, benefit-sharing, or access to technology. It must include precaution, risk assessment, socio-economic assessment, liability and redress, independent expertise, horizon scanning, monitoring, public participation, and the ability to say no to technologies where risks are uncertain, irreversible, or unacceptable. This is especially important given emerging technologies such as synthetic biology, engineered gene drives, RNAibased sprays, and genetically engineered pesticides. The NBSAP should be a place where South

8 Findable, accessible, interoperable, and reusable 9 Collective benefit, authority to control, responsibility and ethics 10 Transparency, responsibility, user focus, sustainability, and technology 11 Licensed, identified, supervised, transparent, enforced, non-exclusive 12 For more information see ACB’s objective here

Africa commits to strong public-interest biosafety governance, rather than simply facilitating biotechnology development. The addition of developing tools to measure socio-economic impacts in one action is important, but there remain concerns around on whether and how to establish precautionary thresholds, strengthen independent risk assessment capacity, integrate socioeconomic considerations, and ensure sovereignty over biological data, research trajectories, and technological choices in decision-making processes. As said, the NBSAP appears to focus too heavily on the benefits of biotechnology and insufficiently addresses new genetic engineering applications in agriculture. While the GMO Act will be revised to cater for new modern technologies, we believe that precautionary thresholds, horizon scanning, and mechanisms to address uncertainty, irreversibility, and transboundary impacts—in particular associated with increasingly complex and high-risk technological trajectories, such as synthetic biology and engineered gene drives (EGDs) —must be firmly integrated into regulatory processes (Masinjila & Mayet, 2023). RNAi sprays and genetically engineered pesticides are good examples of why South Africa needs a precautionary, integrated, and forward-looking regulatory approach. These technologies must not fall through regulatory gaps or be treated solely as plant protection products without proper assessment of ecological, socio-economic, biosafety, and rights-related impacts. These issues reinforce the need for the NBSAP to explicitly require precautionary assessment, independent science, public participation, socio-economic assessment, transparency, and post-release monitoring before such technologies are deployed in agricultural landscapes. Parties to the CBD met in Nairobi for the Twenty-eighth meeting of the Subsidiary Body on Scientific, Technical and Technological Advice (SBSSTA-28) and the Seventh meeting of the Subsidiary Body on Implementation (SBI-7), which were held from 27 July–1 August, and 3–12 August 2026, respectively (TWN, 2026). These issues were addresses there ahead of COP17. As we head towards COP17 in Armenia, decisions remain heavily bracketed and highly contentious. We urge the South African government to push for the thematic action plan on synthetic biology to be responsive to broader cross-cutting issues, including biosecurity and biosafety concerns, the need for robust regulatory frameworks, liability and redress for damage, equity considerations, environmental and social safeguards, the importance of strengthening public sector research for public good, technology transfer of environmentally sound and appropriate technologies, and data sovereignty, and support for the establishment of a new Ad-Hoc Technical Expert Group on synthetic biology. The twelfth meeting of the parties to the Cartagena Protocol (CP-MOP12) will be held concurrently to COP. The provisional agenda includes multiple items directly relevant to EGD governance, including risk assessment and risk management of living modified organisms (LMOs); detection and identification of LMOs; socio-economic considerations; national legislation, regulations, and guidelines on new developments in modern biotechnology; and the Nagoya–Kuala Lumpur Supplementary Protocol on Liability and Redress. We urge the South African government to push for a moratorium on EGDs, in response to the problematic voluntary guidelines being put forward to assess them.

South Africa’s NBSAP should serve as a site for instilling precautionary thresholds, independent assessment capacity, data sovereignty, and where community authority can be concretely defined and operationalised. Only through such an approach can Target 17 move beyond symbolic recognition to become an effective safeguard for biodiversity and for the communities whose lives and livelihoods depend on it in an era of rapidly evolving biotechnology. However, currently, the heavily bias towards equitable benefit sharing of biotechnology overlooks and neglects the historical contestation over these technologies and reinforces them as a technical and procedural issue rather than a governance and human rights issue.

Means of implementation This target addresses targets 19 (resource mobilisation) and target 20 (Capacity-Building, Technology Transfer, and Scientific and Technical Cooperation for Biodiversity) under the KMGBF. The national target is: By 2035, human and financial resources are secured and enhanced through mobilising financial resources from all sources and fostering a transformed, suitably skilled workforce to effectively implement the National Biodiversity Strategy and Action Plan. This target primarily focuses on financing, which is the main difference between this draft of the NBSAP and previous versions. It encompasses 5 national indicators and 14 actions. According to the Global Review Report (2026), Parties reported funding for biodiversity capacitybuilding is overwhelmingly short-term or project-based, and often externally sourced, meaning that training programmes, monitoring systems, and research initiatives are frequently discontinued at the end of a project. Domestic budget allocations for biodiversity research and technology remain insufficient, and the lack of sustainable financing mechanisms perpetuates dependence on international donors. South Africa’s biodiversity finance is heavily dependent on public-sector expenditure (BIOFIN, 2025), with funding concentrated at the national level, where the Department of Forestry, Fisheries and the Environment (DFFE) and its public entities account for 61% of historical biodiversity investment. Provincial government collectively contributes 22% of total spending, while municipalities, represent the smallest share at just 1%, despite their critical role in local biodiversity management and spatial planning. While the public sector remains the primary funder, international donors, nongovernmental organisations, and the private sector provide complementary support, although these funds are often harder to track and quantify (BIOFIN, 2025). International donors continue to play an important role in funding large-scale projects, with the Global Environment Facility (GEF) providing cumulative grant allocations of USD 232.1 million across its recent cycles and the Green Climate Fund (GCF) approving major grants, including USD 40.1 million for ecosystem-based disaster risk reduction in 2025. The Biodiversity Expenditure Review was conducted to understand historical spending patterns and guide future financing decisions for the updated NBSAP (BIOFIN, 2025). The review found that while nominal biodiversity expenditure grew to R20.14 billion in 2024, real spending power has persistently declined, with total expenditure remaining below 1% of the national budget. The successful implementation of the NBSAP is fundamentally contingent upon securing adequate, sustainable, and predictable financing.

A Financial Needs Assessment (FNA) was undertaken in parallel with the development of the NBSAP to estimate resources required for implementation. The present FNA provides costing for only 17 socalled priority activities, out of a total of 125 activities, due to data and consultation constraints. These costed activities amount to approximately R656.71 million over 10 years (2026/27–2035/36). These 17 costed actions represent only some of the actions from the first five thematic areas (mainstreaming, restoration, ecosystem conservation, species conservation, and human-wildlife conflict), with the remaining seven completely unaddressed. Even then, those areas of significant high-costs such as large-scale ecological restoration, protected area expansion toward 30x30 targets, full species recovery implementation, biodiversity economy scaling, pollution control infrastructure, and ecosystem-based climate adaptation require further costing and stakeholder validation. The Biodiversity Finance Plan (BFP) was developed after the FNA to provide a strategic roadmap for mobilising and aligning financial resources to support the implementation of South Africa’s biodiversity commitments. The BFP is anchored on four core objectives, namely: • • • •

Mobilising private and blended finance to complement public funding and scale investment in nature-positive activities. Introducing innovative market-based instruments that create economic incentives for conservation. Strengthening biodiversity integration within public financial management systems, including improved expenditure tracking and accountability. Enhancing governance, monitoring, and coordination mechanisms to improve the effectiveness and transparency of biodiversity finance.

Central to the BFP is the establishment of a National Biodiversity Blended Finance Facility, which would serve as a catalytic platform for mobilising and coordinating investment from public institutions, development finance partners, and private capital markets. The Facility would support investments in ecosystem restoration, biodiversity stewardship, ecological infrastructure, and biodiversity-based economic activities. This is complemented by a set of targeted instruments that include: environmental fiscal benefits, biodiversity budget tagging, biodiversity offsets banking, thematic bonds, conservation trust funds, green finance mechanisms, Environmental tariffs and fees, Crowdfunding and philanthropy platforms. Noticeably, throughout the NBSAP, there is emphasis on “innovative finance instruments”, such as green bonds, biodiversity offsets, and biodiversity credits, similar to SANParks’ Strategic Plan 20252030 (SANParks, 2025). In one action13 there is mention of ensuring environmental and social safeguards, which is a necessary addition but has no process to define what this means and is not

13 Stimulate and scale up innovative finance instruments such as green bonds, biodiversity offsets, and biodiversity credits,

ensuring they include environmental and social safeguards.

reflected in the BFP itself. Beyond this, such approaches may entrench the financialisation and commodification of biodiversity, allow ongoing destruction to be offset elsewhere, shift responsibility away from the state, and open biodiversity governance to private financial interests. These represent a particular concern in how the NBSAP envisions the future of biodiversity finance and governance. The failure to fully cost and address the many indicators and actions reflects limited potential to realise commitments under NBSAP and deep concerns over the focus on market-based instruments to reduce the fiscal burdens of biodiversity governance, without defining and outlining the necessary social and environmental safeguards. Fundamentally, addressing the activities driving biodiversity loss, finding more appropriate forms of public, redistributive and community-accountable finance— such as increased public budget allocations, redirecting harmful subsidies, community trust funds, support for FMSS, community-led restoration, public-interest research, and direct support to smallholder farmers, pastoralists, small-scale fishers, and local communities, which restore and regenerate biodiversity—must form part of the actions included under this thematic area. In terms of capacities, technology transfer, and science and technical cooperation, according to the Global Report Review (CBD, 2026), weak institutional coordination and fragmented mandates across multiple government bodies, agencies, and academic institutions leads to duplication of effort, overlapping responsibilities, and difficulty consolidating a coherent national agenda for research and implementation. Biodiversity data is frequently siloed across institutions without common standards or interoperability, undermining the ability to track progress or inform policy. High staff turnover further erodes institutional memory, meaning skills gained through training are seldom anchored in long-term national systems. One action under this thematic area reflects the need for capacitation on human rights and inclusive approaches to enable effective engagement with IPLCs—an action which must remain. Where technology transfer and cooperation is mentioned, we urge there to be emphasis on locally appropriate technology transfers, to prioritise: -

open, appropriate, publicly governed, and community-accountable technologies; protect Indigenous, traditional, farmer, and agroecological knowledge systems from extraction and misappropriation; ensure FPIC where relevant; ensure fair and equitable benefit-sharing; prevent biodiversity monitoring and data systems from being captured by offset markets, corporate disclosure schemes, or proprietary conservation technologies; promote equity, co-design, precaution, and sovereignty by supporting public interest research, South-South cooperation, regional knowledge exchange, community-led monitoring, agroecological innovation, FMSS, and investment in public sector scientific capacity, while ensuring that biosafety, socio-economic assessment, data sovereignty, and the precautionary principle guide all technology-related implementation.

Therefore, in the action: Facilitate technology transfer and scientific cooperation, including through the operation of the Technical and Scientific Cooperation (TSC) Centre, to enhance technical capabilities, encourage innovation, and foster joint research programmes, we suggest adding: require free, prior, and informed consent where relevant, and ensure fair and equitable benefitsharing and sovereignty of public interest research.

Knowledge, participation and inclusion This thematic area addresses target 21 (Knowledge), 22 (Participation) and 23 (Gender equity) of the KMGBF. The national target is: By 2035, ensure access to scientific and traditional knowledge, with free, prior and informed consent of knowledge holders, to empower women, youth, previously disadvantaged individuals, persons with disabilities and indigenous peoples and local communities to participate meaningfully and access justice, thereby advancing transformation in biodiversity conservation and sustainable use. This target aligns with Goal 4 of the White Paper, situating South Africa’s commitment to justice, transformation and inclusivity in biodiversity conservation and sustainable use through the principle of Ubuntu. Within this thematic area, there are 10 national indicators and 9 actions. There are some crucial additions under this target that could be extended to other areas of the NBSAP, or at least to clear linkages between thematic areas. For example, developing and implementing FPIC protocols are necessary for all the actions identified across all thematic areas, and not exclusively for the use of indigenous and traditional knowledge. The rights, tenure, customary laws, and traditional knowledge are necessary inclusions in the NBSAP and should feature in all areas of work. The addition of a specific action on the rights and tenure systems for small-scale fishers and coastal communities is an important inclusion and could feature under the Sustainable Use and Biodiversity Economy thematic area.

Conclusion South Africa has taken important steps towards aligning its NBSAP with the KMGBF and the country's Biodiversity White Paper. The draft contains several positive developments, including increased recognition of rights-holders, stronger treatment of genetic diversity, attention to ecosystem restoration and biodiversity planning, and efforts to strengthen implementation and financing mechanisms. However, the draft remains insufficiently ambitious and risks becoming an implementation-light framework that does not adequately confront the underlying causes of biodiversity loss. Across multiple thematic areas, indicators, actions, data systems, budgets, responsibilities, and timelines remain weak, incomplete, or disconnected from one another. This raises significant concerns regarding implementation, accountability, and the ability to achieve stated objectives. A recurring weakness throughout the draft is the tendency to treat biodiversity loss as a collection of discrete technical problems rather than as the outcome of broader political, economic, and governance systems. Biodiversity decline is closely linked to industrial agriculture, pollution,

extractivism, harmful subsidies, concentration of economic power, weak regulation, and inequitable governance arrangements. Without addressing these structural drivers, conservation, and restoration interventions are unlikely to deliver transformative outcomes. The NBSAP also provides an opportunity to place agricultural biodiversity, FMSS, indigenous crops, public-interest breeding, agroecology, and farmers' rights at the centre of biodiversity governance. These systems and practices contribute not only to biodiversity conservation but also to climate resilience, food sovereignty, social justice, and ecological regeneration. Strengthening them should be recognised as a core biodiversity objective. Similarly, rights cannot be treated as a separate thematic issue. FPIC, tenure security, customary governance, traditional knowledge, community authority, and equitable participation should underpin all aspects of biodiversity governance, including conservation, restoration, climate adaptation, access and benefit-sharing, biosafety, and biodiversity finance. We remain particularly concerned about the increasing reliance on biodiversity offsets, biodiversity credits, carbon markets, and other market-based financial instruments throughout the draft. Biodiversity governance should be grounded primarily in public accountability, public investment, subsidy reform, polluter responsibility, and community-led stewardship rather than the continued commodification and financialisation of nature.

Ultimately, South Africa has an opportunity to produce a genuinely transformative NBSAP rooted in ecological integrity, Ubuntu, duty of care, agroecology, biodiversity justice, precaution, public accountability, democratic participation, and respect for the commons. Such an approach would better reflect both the ambitions of the KMGBF and the transformative vision contained in South Africa's Biodiversity White Paper. Realising this opportunity will require substantial strengthening of the current draft before its submission to the CBD.

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