On the failure to p rovide an i nclusive m echanism for c ivil - s ociety i nput in the NBSAP revision and recommendations for a t ransparent p rocess
Submission to the Minister of Forestry, Fisheries , and the Environment
To : The Honourable Mr. Wille Aucamp Minister@dffe.gov.za
CC: Director General: Ms. Nomfundo Tshabalala dg@dffe.gov.za
Submitted by : Mariam Mayet
Executive D irector African Centre for Biodiversity
Dear Mr. Aucamp,
This submission sets out a formal complaint regarding the absence of any meaningful, accessible, or functional mechanism for civil-society participation in the ongoing revision of South Africa’s National Biodiversity Strategy and Action Plan (NBSAP).
To remedy these defects, we call for the immediate establishment of a transparent and publicly communicated participation process, including an open call for civil-society inputs, release of all draft targets and technical materials for comment, and the creation of multi-stakeholder engagement forums that allow communities, Indigenous Peoples, farmers, and civil-society organisations to contribute substantively to the development of the revised NBSAP
About the ACB
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 (GBF), contributing civil-society perspectives on biosafety, targets, indicators, and the rights of smallholder farmers and Indigenous peoples.
Our long record of evidence-based research, legal interventions, and farmer-centred advocacy has earned the ACB a respected role in championing seed sovereignty, resisting biosafety deregulation, and promoting agroecological approaches to counter industrial agricultural expansion.
1. The reason for directly approaching you, Honourable Minister and Director General
1.1 Complaint: Absence of a meaningful mechanism for civil society participation
For more than a year, the ACB has made sustained and good-faith efforts to participate in the revision of South Africa’s NBSAP. Despite repeated correspondence with officials in the Department of Forestry, Fisheries, and the Environment (DFFE) and the South African National Biodiversity Institute (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, communities, Indigenous Peoples, 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 KM-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 longstanding 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.
1.2 Urgency and imminent COP-17 obligations
There is now an urgent need for decisive corrective action. Under the Convention on Biological Diversity (CBD), Parties are required to revise and submit their updated NBSAPS ahead of the next Conference of the Parties (COP) 17 in Armenia, in October 2026, ensuring alignment with the GBF and demonstrating credible national implementation pathways.
With COP 17 looming, South Africa must urgently finalise a robust, participatory, and evidencebased NBSAP that reflects whole-of-society input. Failure to establish an inclusive process at this critical juncture risks not only producing a weak and unaccountable national strategy but also undermining South Africa’s international reporting obligations and its standing as a Party committed to transparent, rights-based biodiversity governance.
Immediate steps to remedy the current procedural deficiencies are therefore essential to ensure that the revised NBSAP can be submitted to COP 17 as a legitimate, defensible, and truly national plan.
2. The democratic and legal basis for civil-society participation
South Africa’s commitments under the CBD and the GBF are unequivocal: biodiversity planning, target-setting, implementation, and monitoring must be co-developed with a wide range of societal actors, including civil society, IPLCs, women, youth, farmers, small-scale producers, and
knowledge holders. The KM-GBF explicitly embeds participatory governance in Target 14 , Target 21 , and Decision 15/6 , all of which emphasise transparent, inclusive, and iterative engagement.
Domestically, the obligation to enable meaningful public participation arises from:
• Section 24 of the Constitution , which requires the State to take reasonable legislative and other measures to protect the environment for present and future generations.
• Section 195 of the Promotion of Administrative Justice Act (PAJA) requires participatory, accountable, and transparent decision-making.
• The P ublic A ccess to Information Act (PA IA ) and PAJA guarantee procedural fairness and access to information in administrative processes.
• The National Environmental Management Act (NEMA) enshrines the principle of environmental governance that places participation by all interested and affected parties at the centre of environmental decision-making.
Given these clear legal requirements, the absence of a functional participation mechanism in the NBSAP revision process is not only procedurally deficient – it constitutes a material failure of the State’s constitutional, administrative, and international obligations.
3. Participation in NBSAP revision is not optional but material to compliance
The NBSAP is not a symbolic planning document; it is the core national instrument through which South Africa must demonstrate:
1. GBF alignment and delivery of the 2030 global targets
2. Integrated cross-sectoral policy coherence, including agriculture, fisheries, forestry, energy, mining, water, land reform, and rural development
3. Evidence-based monitoring, reporting, and review (MRR) capability
4. Budgeted implementation pathways that can be independently verified
Progress on structural drivers of biodiversity loss, including industrial agriculture, fossil fuels, land use change, and pollution.
Civil-society organisations – especially those working with communities on the ground – are indispensable to this process because they:
• Provide ground-truthing of biodiversity trends.
• Supply data and evidence from outside government sources.
• Monitor violations, harmful projects, and biodiversity-damaging development
• Bring Indigenous and traditional knowledge into national planning .
• Act as public accountability structures, preventing greenwashing or false reporting
• Support compliance with community stewardship, land rights, and environmental justice principles.
Excluding independent civil-society voices fundamentally weakens the reliability and legitimacy of the national biodiversity governance system.
4. Recommendations for restoring transparency, accountability, and participation
To ensure that South Africa’s NBSAP revision aligns with the transparency, inclusion, and accountability standards required under the GBF, it is essential that the Department establishes a formal, accessible, and well-structured participation mechanism for civil society, and Indigenous Peoples and Local Communities (IPLCs).
This mechanism should provide reasonable opportunities for engagement – through online and in-person convenings, written submissions, and technical dialogues – on draft targets, indicators, baselines, financing, and implementation frameworks. Such an approach would embed justicecentred, community-informed priorities into the NBSAP, while reflecting the lived realities of those most affected by biodiversity loss, climate change, and environmentally harmful development.
A credible participation process also requires a transparent engagement roadmap that clearly outlines timelines, public input modalities, and feedback channels. All draft materials – including baselines, indicators, costing frameworks, and spatial datasets – must be made available for public review.
These steps would align South Africa with global best practices and enable the development of a robust monitoring, reporting, and review system that ensures accountability. Civil society must have access to the information needed to evaluate progress, detect shortcomings, and help shape adaptive management responses, including those related to agroecology, climate resilience, and the structural drivers of biodiversity loss.
Meaningful inclusion must extend into implementation and monitoring. Whole-of-society monitoring – enabled by resourced community-based biodiversity monitoring, independent civil society shadow reporting, and academic review – would enhance transparency and provide an essential check on government reporting to the CBD.
Embedding Indigenous and local knowledge systems, agroecological expertise, and community stewardship practices would strengthen the NBSAP’s capacity to address climate change impacts, protect ecosystems, and support sustainable livelihoods. These mechanisms are necessary to overcome the current exclusionary situation and to fulfil the participatory governance requirements set out in Decision 15/6 of the KM-GBF.
A. Establish a n ational c ivil - s ociety p articipation m echanism (CSPM)
• Publicly announce an open call for participation.
• Create a transparent registry of civil-society organisations, IPLCs, farmers, custodians, and community networks.
• Form multi-stakeholder thematic working groups covering inter alia, agroecology, biosafety, seeds, Indigenous knowledge, spatial planning, protected areas, agriculture, climate change, and finance.
B. Release a ll d raft and t echnical m aterials for r eview
• Draft targets, baselines, indicators, and implementation matrices.
• Financing frameworks.
• Alignment analysis between GBF targets and national priorities.
• Draft MRR systems.
• Spatial and scientific data used for target setting.
C. Publish a t ransparent p articipation r oadmap
• Clear milestones and timelines.
• Internal responsibilities for DFFE, Department of Agriculture, Land Reform and Rural Development (DALRRD), SANBI, etc.
• Publication dates for all draft materials.
• Deadlines for written submissions.
• Mandatory government responses to stakeholder inputs.
D. Institutionalise c ommunity - b ased and w hole - of - s ociety m onitoring
• Hold annual public review forums.
• Integrate Indigenous and local knowledge systems (ILKS).
• Develop public dashboards and scorecards to track GBF progress.
E. Address s tructural d rivers of b iodiversity l oss
Participation must explicitly include dialogue on:
• Industrial agricultural expansion and its climate impacts.
• Barriers to scaling agroecology and farmer-led climate-resilient practices
• Synthetic biology, gene editing, and biosafety deregulation.
• Corporate concentration in seed and input systems.
• Water extraction, mining, and land-use conversion.
• Harmful pesticides and chemical pollution.
• Energy and infrastructure projects with significant biodiversity risks.
• Climate-related threats to ecosystems, livelihoods, and food systems.
• Carbon markets, offsets, and nature-based solutions that risk land grabs or greenwashing.
Without addressing these drivers, the NBSAP cannot serve as a transformative strategy and risks reinforcing the status quo.
Conclusion
For the NBSAP to meet the ambition of the GBF and fulfil South Africa’s constitutional and legal obligations to ensure an ecologically sustainable future, it must be developed in genuine partnership with civil society rather than in isolation from it. We therefore urge the Honourable Minister and Director-General to take immediate steps to rectify the procedural deficiencies outlined in this submission. A transparent, well-resourced, and inclusive participation mechanism is not only a legal requirement – it is essential for a credible, just, and transformative NBSAP capable of driving meaningful change for people, biodiversity, and the climate.
We look forward to hearing from you at your earliest convenience
Kind regards
Mariam Mayet
Executive Director
African Centre for Biodiversity mariam@acbio.org.za www.acbio.org.za