BIODIVERSITY NET GAIN & MAJOR INFRASTRUCTURE: WHAT LANDOWNERS & DEVELOPERS NEED TO KNOW

Recent government guidance has provided greater clarity on how Biodiversity Net Gain (BNG) will apply to major infrastructure projects in England.

From 2nd November 2026, BNG will become mandatory minimum 10% for new Nationally Significant Infrastructure Projects (NSIPs); this applies to all Development Consent Order (DCO) applications including major energy, transport and utility schemes. The latest guidance confirms how biodiversity gains should be considered throughout project design and consenting, whilst also introducing a more streamlined approach than many developers had anticipated. The new guidance confirms that BNG will apply only to habitats impacted by development, rather than entire development sites, and that gains can be delivered either on-site or through off-site habitat creation. This represents a significant opportunity for rural landowners for the off-site delivery, whilst giving developers more flexibility in how they meet their obligations.

At Ceres, we are already seeing growing interest from both landowners looking to generate income from environmental markets and developers seeking practical BNG solutions. To explore what the new guidance means in practice, we spoke with Ellen Fake, Farming Consultant at Ceres Rural, and Peter Cole, Partner at Ceres Property.

Q&A: TURNING REGULATION INTO OPPORTUNITY

Q: I’m a landowner. Why should I care about this latest BNG guidance?

Ellen Fake: Because it expands an already growing market.

Major infrastructure projects often have significant biodiversity requirements and frequently need land outside the red line development boundary to provide habitat enhancements. The new guidance gives developers greater certainty about how they can achieve BNG, which in turn creates more opportunities for landowners who can offer suitable land for habitat creation or enhancement.

For many farms and estates, this is not simply about taking land out of production. The most successful projects start with a strategic assessment of the holding to identify areas where biodiversity schemes can complement the wider business, support other environmental objectives and generate long-term revenue.

Q: What’s the biggest mistake landowners make when considering BNG?

Ellen: Waiting until a developer approaches them.

The strongest positions are usually secured by landowners who are proactive. Understanding your baseline habitats, environmental constraints and opportunities, Local Nature Recovery Strategy  (LNRS) priorities and development pressures in your area allow you to identify opportunities before demand arrives.

Landowners should also think carefully about the long-term opportunities and constraints of BNG agreements. The commitment is a minimum 30-year term, so the implications for succession planning, taxation, management responsibilities and future land use all need careful consideration.

Q: What practical steps should landowners be taking now?

Ellen: Three things.

First, assess your land. Not every parcel is suitable for BNG and some habitats generate greater biodiversity value than others.

Second, understand local demand. Both demand in your Local Planning Authority (LPA), neighbouring LPA, and demand in your National Character Area (NCA). Areas experiencing significant infrastructure investment, renewable energy development, housing growth or transport improvements are likely to see increased demand for biodiversity units.

Third, consider BNG as part of a wider environmental strategy. A BNG project can complement other ecosystem services, such as carbon sequestration, natural flood management, nutrient mitigation, and other Environmental Land Management opportunities.  The best outcomes often come from looking at the whole estate rather than a single field.

Q: What does the new guidance mean for developers?

Peter Cole: Greater clarity and greater flexibility.

One of the most useful aspects of the guidance is confirmation that BNG should focus on habitats directly affected by development rather than the entire project area. For many nationally significant infrastructure projects, that creates a more proportionate assessment process, and increases accountability.

The guidance also reinforces the importance of considering biodiversity from the earliest stages of project design. Developers who leave BNG until later in the planning process risk reducing their options and increasing costs.

Q: How early should developers be thinking about BNG?

Peter: Ideally from site selection onwards.

BNG is no longer something that can simply be addressed through a planning condition at the end of the process. It increasingly influences masterplanning, engineering design, stakeholder engagement and project viability.

The earlier biodiversity considerations are built into a scheme, the greater the opportunity to deliver value on site and reduce reliance on purchasing off-site units later.

Q: Will this increase demand for off-site BNG land?

Peter: In many locations, yes.

Some infrastructure projects will be able to accommodate a significant proportion of their biodiversity requirements on site. Others will inevitably require off-site solutions.

The key point is that developers need certainty. They need confidence that the biodiversity gains can be delivered, secured, monitored and maintained over the required timeframe. Landowners who can offer these securities, with well-positioned sites will be attractive to developers.

Q: What should landowners and developers be doing next?

Ellen: Landowners should assess where BNG could fit within their business before opportunities arise.

Peter: Developers should review projects that are likely to be affected by the November implementation date and ensure biodiversity considerations are fully embedded within project planning and design.

The Bigger Picture

The latest guidance represents another step in the evolution of environmental markets. Whilst the focus has been on compliance, there is a broader opportunity to take advantage of here.

For landowners, BNG can provide a new income stream, support wider estate objectives and contribute to nature recovery at landscape scale. For developers, early engagement and strategic planning can help de-risk projects and avoid costly delays later in the planning process.

As demand for biodiversity units continues to grow, those who plan ahead are likely to be best placed to benefit.

Whether you are exploring BNG opportunities as a landowner or seeking practical solutions for a development project, Ceres Group can help you navigate the opportunities and obligations created by the evolving regulatory landscape.