About the African Centre for Biodiversity
The African Centre for Biodiversity (ACB) is a research and advocacy organisation advancing food sovereignty and agroecology across Africa. Our work focuses on biosafety, seed systems, agricultural biodiversity, and the structural drivers reshaping food and farming systems in ways that threaten ecological integrity and social justice.
For over a decade, the ACB has engaged in continental and global biodiversity governance processes, including participating as an observer throughout the multi-year negotiations that produced the Kunming-Montreal Global Biodiversity Framework (KM-GBF or GBF), contributing civil society perspectives on its targets and indicators, biosafety, and the rights of smallholder farmers and Indigenous peoples. Our long record of evidence-based research, legal interventions, and small-scale farmer-centred advocacy has earned the ACB a respected role in championing seed sovereignty, resisting biosafety deregulation, and promoting agroecological approaches to counter the expansion of industrial agriculture.
About this s ubmission
This submission to the South African Human Rights Commission (SAHRC or Commission) draws on the ACB’s extensive research and its fact sheet series on the various GBF targets1, which provide the analytical foundation for understanding South Africa (SA)’s obligations under the KM-GBF. It reflects the ACB’s deep concern that the ongoing revision of SA’s National Biodiversity Strategy and Action Plan (NBSAP) lacks a meaningful, accessible mechanism for civil society participation, contrary to the GBF’s explicit requirement for whole-of-government and whole-of-society processes. In presenting these inputs, the submission advances a case for a transformative, justice-centred NBSAP that confronts the structural drivers of biodiversity loss, particularly at the agriculture-biodiversity interface, and ensures alignment with Constitutional rights, including the right to food, land, participation, and a healthy environment.
Recommendations sought from the SAHRC
1. This submission is underpinned by our extreme disquiet that there is no meaningful, accessible, or functional mechanism for civil society participation in the ongoing revision of SA’s NBSAP. The 17th Conference of the Parties (COP17) to the Convention on Biological Diversity (CBD) is fast approaching in October 2026, with Parties being called upon to finalise their GBF-aligned NBSAPs We therefore request that the Commission make a strong recommendation to the Department of Forestry, Fisheries and the
1 GBF-aligned NBSAPs to ensure just, sustainable futures for all life to thrive: the role of African civil society https://t2m.io/GBF_NBSAPs_factsheetseries
Environment (DFFE) and the South African National Biodiversity Institute (SANBI) to take urgent and decisive action to remedy the absence of a meaningful participation mechanism and to ensure that the voices of communities, social movements, and civil society organisations inform the core of the revised NBSAP.
2. Further to this, we request that the Commission make strong recommendations to the DFFE to ensure that SA’s revised NBSAP addresses the structural drivers that cause continued ecosystem degradation, undermine long-term ecological resilience, and erode the realisation of the Constitutional right to food. Industrial agriculture and its expansion, harmful subsidies, corporate seed, chemical input dependency, and extractivist land use practices remain central pressures accelerating biodiversity loss while simultaneously deepening food insecurity by locking farmers and communities into ecologically degrading and economically exclusionary production systems. These systemic drivers cannot be treated as secondary issues; they require explicit identification and binding, time-bound reforms in the NBSAP if SA is to meet the ambitions of the GBF and uphold its human rights obligations, including the right of all people to have access to sufficient, safe, and nutritious food.
3. Equally important is the imperative for whole-of-government and whole-of-society participation. Effective and equitable implementation depends on governance arrangements that centre Indigenous Peoples and Local Communities (IPLCs), small-scale producers, women, and youth groups whose rights, knowledge, and stewardship practices have historically been marginalised. Embedding justice and equity across all national targets is essential. Land rights, food sovereignty, and community-based biodiversity governance must be integrated into the NBSAP to avoid entrenching existing inequalities. Weak indicators and opaque reporting were major failures of the Aichi Biodiversity Targets (2011-2020) under the CBD, and SA must therefore establish clear baselines, context-appropriate indicators, and transparent, participatory monitoring systems that enable meaningful civil society oversight.
1 . Complaint: Absence of m eaningful m echanism for c ivil s ociety p articipation
The ACB has submitted a complaint to the Minister of Forestry, Fisheries, and the Environment, requesting that the DFFE establish a formal, accessible, and well-structured participation mechanism for civil society and IPLCs regarding the revision of SA’s NBSAP. Such a mechanism must provide reasonable opportunities for civil society engagement – through online and inperson convenings, written submissions, and technical dialogues – on draft targets, indicators, baselines, financing, and implementation frameworks. Such an approach would embed justice-
centred, community-informed priorities into the NBSAP, while reflecting the lived realities of those most affected by biodiversity loss, climate change, and environmentally harmful development.
It is important for the SAHRC to note that, for more than a year, the ACB has made sustained, good-faith efforts to participate in the revision of SA’s NBSAP. Despite repeated correspondence with officials in the DFFE and SANBI, no clear guidance has been provided on how or where civil society submissions should be submitted. The absence of a defined process has effectively excluded civil society from a revision that, under the GBF, must follow a whole-of-government and whole-of-society approach.
As a result, IPLCs, small-scale producers, women, youth, and organisations deeply involved in biodiversity stewardship have been left without any formal avenue to influence national targets, indicators, or implementation plans. This exclusion contradicts both the spirit and the explicit requirements of the GBF, which identifies inclusive participation as a foundational condition for credible planning, monitoring, reporting, and review. In the absence of early, meaningful engagement, the revised NBSAP risks replicating long-standing weaknesses observed under the Aichi framework, including poor cross-sectoral alignment, insufficient attention to structural drivers of biodiversity loss, and limited public oversight.
Despite multiple written attempts by the ACB to seek clarity, neither a directive, consultation schedule, nor any formal submission mechanism has been communicated. Occasional responses from officials have provided no practical direction, and no draft targets, baselines, indicators, or budget frameworks have been released for public comment. Invitations to technical working groups were neither extended to civil society actors nor made publicly available.
Together, these omissions have created a procedural vacuum. By failing to establish a predictable, transparent, and properly structured engagement process, DFFE and SANBI have restricted participation to informal or private channels accessible only to selected actors. This undermines public trust and prevents the shared ownership of the NBSAP that the GBF requires
2 . The c ase for a t ransformational, j ustice - c entred NBSAP : l essons from Aichi
and structural drivers
SA’s persistent underperformance in meeting its biodiversity commitments is the direct result of a continued failure to confront the systemic drivers of ecological decline – industrial agriculture, extractive land-use practices, accelerating habitat loss, land degradation, and chronically weak cross-sectoral alignment. These are not peripheral issues; they are fundamental structural pressures that the revised NBSAP must address through explicit, time-bound reforms. Under the COP15 Decision 15/6, Parties are obligated to demonstrate robust, credible systems for planning, monitoring, reporting, and review – systems that rely on genuine
whole-of-government and whole-of-society participation, not tokenistic or ad hoc engagement. The Global Environment Facility (GEF)-funded Umbrella Programme reinforces this obligation by mandating inclusive participation, gender-responsive approaches, policy coherence, and implementation readiness as prerequisites for a GBF-aligned NBSAP.
3. Transformative p lanning and c ross - s ectoral a lignment
3.1 Naming drivers and delivering time-bound reforms
To catalyse systemic change, the NBSAP should explicitly identify key drivers of biodiversity loss and commit to enforceable reforms. These include pesticide phase-downs, redirection of harmful subsidies, diversification of agricultural production systems, and biodiversity-positive spatial planning.
3.2 Creating a coherent policy architecture
A national policy coherence framework, led by a Cabinet-level biodiversity mainstreaming task team, is essential to align the mandates of agriculture, land reform, water, mining, energy, and finance. This body should publish annual reports tracking progress against GBF indicators.
3.3 Institutionalising participatory governance
A permanent National Civil Society and IPLC Advisory Forum should be established to guide NBSAP implementation. This forum must operate with free, prior, and informed consent (FPIC) protocols and guarantee open access to draft targets, indicators, budgets, and monitoring data.
4. S A ’s climate change obligations under the GBF (Target 8)
Meeting the GBF’s climate-related obligations requires SA’s NBSAP to embed a coherent strategy that recognises biodiversity as essential to both climate change mitigation and adaptation. Ecosystems such as wetlands, grasslands, forests, and agroecological production landscapes are critical carbon sinks and buffers against climate shocks, yet they remain under intense pressure from land-use change, industrial agriculture, and extractivist development. A transformative, justice-centred approach to the NBSAP therefore demands large-scale ecosystem restoration, protection of high-integrity landscapes, and the recognition and support of agroecology as a climate-resilient production system that enhances soil carbon, stabilises water cycles, and strengthens community adaptive capacities. Ensuring that climate responses do not reproduce historical injustices requires robust safeguards, including FPIC, protection of land rights, and the exclusion of offsetting schemes that enable continued ecosystem degradation. By prioritising nature-based, community-driven resilience pathways, SA can deliver a climate-aligned NBSAP that addresses both ecological stability and the needs and rights of those most vulnerable to climate impacts.
5. T ransitioning to agroecology ( Target s 3 and 10 )
As part of meeting its obligations under Target 3, SA should formally recognise agroecological production landscapes that deliver sustained biodiversity outcomes as qualifying other effective area-based conservation measures (OECMs), where communities choose this pathway. Many small-scale farmers, pastoralists, and agroecological producer groups steward multifunctional landscapes that enhance on-farm diversity, regenerate soil and water systems, and maintain ecological connectivity across working lands – functions that meet OECM criteria when governance systems are locally embedded and evidence-based. To secure these contributions, the NBSAP should provide long-term financing, legal support, and participatory mapping for community-governed OECMs, including those rooted in agroecological production. This must include support for community land-use planning, recognition of customary tenure, and strengthening of governance.
Meeting SA’s obligations under Target 10, which explicitly mentions agroecology, requires a decisive shift toward agroecology as the foundation of sustainable, biodiversity-positive agricultural production systems. Agroecology directly advances Target 10 by reducing pressures on ecosystems, restoring soil and water systems, and enhancing on-farm genetic and species diversity through diversified, low-input production practices. The revised NBSAP must therefore commit to scaling farmer-led and community-rooted agroecological approaches, such as agroforestry mosaics, rangeland restoration, riparian rehabilitation, and community seed diversity systems. Because industrial, input-intensive agriculture is a major structural driver of ecosystem degradation, expanding agroecology is not optional: it is essential for meeting GBF requirements while strengthening resilience, improving livelihoods, and advancing food sovereignty. Embedding agroecology into the NBSAP – through supportive extension systems, repurposed subsidies, integrated spatial planning, and long-term financing – will ensure that Target 10 implementation drives systemic transformation rather than marginal, technical adjustments.
6. H alting s pecies e xtinction and s ecuring g enetic d iversity ( Target 4)
To halt species decline and protect genetic diversity, SA should establish a cross-cutting national programme for plant genetic resources for food and agriculture (PGRFA) and seed diversity. This should include targets for on-farm conservation, community seed banks, and participatory varietal selection initiatives.
Recognising and protecting farmer-managed seed systems (FMSS) is critical. Alignment of legislation and policy must safeguard farmers’ seed rights and customary seed practices, consistent with international norms on farmers’ rights. SA should also advance fair and effective benefit-sharing for digital sequence information (DSI) and establish national safeguards against data extractivism and biopiracy.
7. Reducing p ollution to l evels n ot h armful to b iodiversity ( Target 7)
Meeting Target 7 requires SA to adopt quantified national commitments that directly address the three major pollution streams most harmful to biodiversity: nutrient loading, pesticides (especially highly hazardous pesticides (HHPs)), and plastics. In line with ACB’s Target 7 analysis, the NBSAP must commit to halving excess nutrient losses, halving overall pesticide risk through a time-bound phase-out of HHPs, and preventing, reducing, and moving towards eliminating plastic pollution at source. These commitments must be rooted in whole-system reforms rather than incremental technical fixes.
Pollution must be addressed at its source through decisive structural changes to agricultural, chemical, and waste governance systems. Agricultural subsidies, extension services, and public procurement must be redesigned to reward nutrient efficiency, lower chemical inputs, and a shift towards agroecology, rather than reinforcing dependence on synthetic fertilisers and hazardous pesticides.
Effective implementation requires robust monitoring systems. SA must:
• Establish national nutrient load baselines and catchment-level tracking,
• Adopt risk-based pesticide indicators that measure actual ecological exposure,
• Monitor HHP phase-out trajectories and integrated pest management (IPM) and/or agroecology adoption rates, and
• Map plastic leakage and microplastics in priority ecosystems.
These metrics should feed into transparent, participatory reporting systems in which civil society, particularly communities most affected by pollution, has meaningful oversight.
Implementation must also be rights-based and gender-responsive. Pollution controls often disproportionately affect small-scale farmers, women waste-pickers, and rural communities burdened by contaminated land and water systems. The NBSAP must therefore ensure FPIC, accessible data, grievance mechanisms, and active inclusion of affected groups in co-designing pollution-reduction strategies and monitoring frameworks.
8. Monitoring, r eporting, and r eview
A robust monitoring, reporting, and review system is essential to the credibility of the NBSAP implementation. SA should publish baselines, methods, and spatial datasets for GBF targets, and co-develop indicators that integrate ecological and social outcomes. All datasets should be publicly accessible to enable civil society oversight.
Whole-of-society monitoring should be institutionalised through resourced community-based monitoring integrated with CBD reporting tools. The government should commit to biannual public progress briefings and enable independent reviews by civil society coalitions, academia, and research institutions to ensure a transparent assessment of NBSAP quality and implementation.
9. F inancing the t ransition
Financing SA’s biodiversity commitments must be anchored in public interest principles and a clear break with harmful subsidies that incentivise biodiversity loss. ACB’s work shows that subsidies embedded in agricultural, water, energy, and land-use regimes – such as price supports for synthetic fertilisers and pesticides, concessional credit tied to input-intensive models, tax exemptions for agrochemicals, fiscally-favoured water and electricity tariffs for high-input irrigation, and incentives that enable extractive or habitat-converting land uses – distort incentives and lock farmers and local economies into ecologically degrading pathways. The revised NBSAP should therefore commit to a national harmful subsidy review and a time-bound repurposing plan that redirects public expenditure away from chemical-dependent, landdegrading, and extractivist practices, and towards agroecology, restoration, and rights-based conservation. By ending harmful subsidies and repurposing public finance toward agroecology, community stewardship, and restoration, SA can unlock a just, durable, and ecologically grounded transition – one that delivers measurable biodiversity gains while improving livelihoods and resilience.
Conclusion
Reforming the structural drivers of biodiversity loss is essential not only for ecological integrity but also for advancing food sovereignty, particularly for small-scale farmers and IPLCs. Industrial agriculture, harmful subsidies, and chemical-input lock-ins restrict farmers’ control over production by creating a dependency on external inputs, proprietary seeds, and market-driven models that undermine local autonomy and agricultural biodiversity. In contrast, time-bound reforms that phase out harmful subsidies, redirect public finance towards agroecology, protect FMSS, and strengthen community land rights directly expand people’s ability to define their own food and farming systems. These changes enable diversified, ecologically regenerative production rooted in local knowledge, seed diversity, and community governance – core elements of food sovereignty. In this way, addressing structural ecological drivers through a justice-centred NBSAP opens political and economic space for farmers and communities to build resilient, biodiverse food systems that secure both the right to food and the right to produce food in socially just, ecologically sustainable, and meaningful ways.
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