Biodiversity net gain for NSIPs

What the government announcement means and how to get ahead 

The UK Government has confirmed that biodiversity net gain (BNG) will apply to nationally significant infrastructure projects (NSIPs) from November 2026. 

This marks a significant shift for infrastructure developers. While the timeline has moved, the core requirement remains. 

BNG is coming to NSIPs. The focus now is on how it will be delivered at scale, with measurable outcomes.  

Extending Biodiversity Net Gain to Nationally Significant Infrastructure Projects would be a notable policy change, influencing large developments including airports, roads and energy infrastructure.

A more practical approach to BNG 

The updated framework reflects the realities of large infrastructure projects. It introduces flexibility while maintaining environmental ambition: 

Delivery across LNRS areas

Supporting more strategic, landscape scale habitat creation

Phased delivery

Aligned with long construction timelines 

Integration into the development consent order (DCO) process

Embedding BNG within the primary planning approval route for NSIPs 

Targeted flexibility

Adjustments where full delivery is not feasible 

In simple terms, BNG is being shaped to work for infrastructure, not just planning policy.   

What this means for applicants  

BNG is now a live issue for NSIPs, and its integration into the DCO process changes how it needs to be approached. 

Scrutiny will increase

BNG assumptions, land availability and long-term delivery will be tested in detail during examination. Strategies must be robust, evidence based and clearly deliverable to remain compliant and avoid delay. 

Flexibility introduces complexity Greater freedom in how BNG is delivered brings more decisions earlier. Developers need a clear and defensible approach from the outset. 

The market is still maturing

Supply, pricing and delivery models are not yet fully established at NSIP scale. This creates both uncertainty and opportunity. 

The implication is clear. BNG is no longer a compliance exercise. It is a core part of project strategy with measurable requirements. 

The opportunity 

BNG for NSIPs will drive significant demand for offsite habitat delivery, enabling: 

• Landscape scale nature recovery 

• Long term land partnerships 

• New commercial approaches across infrastructure portfolios 

For applicants, this is an opportunity to secure supply early, manage risk and shape delivery outcomes while maintaining confidence in compliance. 

Where Biofarm fits 

BNG introduces complexity across planning, ecology, land, compliance and long-term delivery. Biofarm brings these elements together, designing flexible, project specific solutions that respond to the unique requirements of each NSIP.  

We support developers with: 

Strategy and feasibility Defining a credible, policy aligned approach early in the project lifecycle 

National habitat bank coverage aligned to LNRS priorities Delivering off site BNG through a coordinated portfolio of sites, with Biofarm managing design, implementation and long-term stewardship 

Technical and planning support Including biodiversity gain plans, metric review and alignment with DCO requirements 

End to end transaction and delivery Covering commercial structuring, legal agreements, and a ringfenced fund model that secures long term habitat delivery, alongside monitoring, reporting and ongoing compliance 

Our role is straightforward. We take responsibility for making BNG practical, deliverable, measurable and compliant over the full lifecycle of the project, with financial structures in place to protect long term outcomes.  

Why engage now 

Although implementation is set for November 2026, key project decisions are already being made. 

Early engagement allows you to: 

• Reduce risk within the DCO process 

• Secure access to deliverable, policy aligned habitat early 

• Build a strategy that will withstand examination 

• Ensure long term delivery obligations are achievable 

Delaying increases uncertainty. Acting early creates control. 

Start the conversation 

We are working with developers and landowners to prepare for BNG at NSIP scale. 

If you are planning an infrastructure project or reviewing your pipeline, now is the time to engage. 

• What is biodiversity net gain for NSIPs?

  Biodiversity net gain for nationally significant infrastructure projects requires developers to deliver a measurable improvement in biodiversity alongside their scheme. This can be achieved on site, off site, or through a combination of both, and must be evidenced through the biodiversity metric and secured for the long term. 

• When will BNG apply to NSIPs?

  BNG is expected to become mandatory for NSIPs from November 2026. While this may feel distant, most infrastructure projects have long development timelines, meaning BNG requirements are already influencing current planning and design decisions. 

• How is BNG assessed in the DCO process?

  BNG will be embedded within the development consent order process and examined at a national level. Applicants will need to demonstrate that their proposed approach is deliverable, policy aligned and capable of achieving measurable outcomes over the full lifecycle of the project. 

• Can BNG be delivered off site for infrastructure projects?

  Yes. The updated framework allows for greater use of off site delivery, particularly across Local Nature Recovery Strategy areas. This enables more strategic, landscape scale habitat creation, provided it meets policy requirements and is demonstrably deliverable. 

• Why is early engagement important for NSIP BNG?

  Early engagement allows developers to reduce risk, secure access to suitable habitat and build a strategy that will withstand examination. Waiting until later stages can lead to constrained supply, increased costs and greater delivery risk.