COMMENTS ON DRAFT NATIONAL BIODIVERSITY STRATEGY AND ACTION PLAN

On 9 September 2026, the Biodiversity Law Centre submitted detailed comments on South Africa’s draft National Biodiversity Strategy and Action Plan 2026 – 2035 (“Draft NBSAP”) to the Department of Forestry, Fisheries and Environment’s (“DFFE”). The comments are endorsed by the Southern African Faith Communities’ Environment Institute (“SAFCEI”).

The Draft NBSAP is the blueprint for South Africa’s implementation of the Convention on Biological Diversity (“CBD”) for the next decade. It serves as SA’s primary tool to implement and contribute to the CBD’s Kunming-Montreal Global Biodiversity Framework (“GBF”), which sets out ambitious targets and goals to urgently ramp up efforts to halt and reverse alarming biodiversity. As SA is one of the most biodiverse countries in the world, the Draft NBSAP is a unique opportunity to provide for a substantial national contribution to the achievement of a world where biodiversity is protected and restored – enabling its fundamental role to human well-being, a healthy planet, and economic prosperity for all.

While the BLC welcomes the Draft NBSAP’s efforts to align with the CBD and GBF, our submission primarily flags concerns with its lack of concrete and time-framed mechanisms to meet the GBF’s targets and goals in the face of major drivers of biodiversity loss, especially in the contexts of arid lands (which face particular threats from a proliferation of mining), estuaries and estuarine functional zones, and marine ecosystems. Our comments also propose recommendations to remedy these shortcomings in the Draft NBSAP. In this regard –

1. Arid Lands – In the context of SA’s sensitive arid lands (including the Succulent and Nama Karoo), noting the increasing prevalence of mining in these ecosystems, the BLC recommends supplementing the Draft NBSAP to include targets and actions that address prospecting and mining’s biodiversity impacts (beyond pollution), such as habitat degradation and loss. This is particularly acute because cumulative impacts are often not considered, requiring urgent action to implement strategic environmental planning in the Nama and Succulent Karoo landscapes. The Draft NBSAP should also hold prospecting and mining companies accountable to their financial commitments to rehabilitate the environment following mining.
2. Estuaries – To meaningfully protect and restore estuaries (which are simultaneously vital ecological infrastructure and of one of SA’s least protected ecosystems), the BLC calls for the Draft NBSAP to extend its strategising focus to estuaries’ full Estuarine Functional Zones (beyond the bodies of water); to prioritise the restoration of important heavily and critically modified estuaries; to provide for increased regulation of recreational fishing in estuaries; and to target the declaration of estuaries, and their EFZs, as protected areas – all while ensuring intergovernmental co-ordination on estuarine management, noting estuaries’ straddling of multiple government mandates. Coordinated, catchment-level management is vital to ensuring estuaries are protected at an ecosystem level.
3. Marine ecosystems – In the face of increasing threats facing marine ecosystems, including from climate change, overfishing, and illegal harvesting, the BLC calls for the Draft NBSAP to recognise marine ecosystems as ecological infrastructure, and to implement the legislative provisions adopting  an ecosystem-based approach to fisheries management across marine, estuarine, and freshwater systems – including through decision-making on total allowable catch, total applied effort and individual permits. Our comments highlight sharks specifically, calling for dedicated targets and actions aimed at urgently addressing sharks’ high extinction risk.

Our submission also addresses other issues with the Draft NBSAP, including recommending mandatory biodiversity disclosures by businesses (particularly for financial institutions large and transnational companies); and recommending the addition of target and action milestones ahead of the Draft NBSAP’s 2035 expiration, in order to identify and manage bottlenecks in its execution before 2035.

Our comments can be found below: