Defra's new environmental plan presents £110 million for England's protected landscapes as fresh investment. Its own watchdog says the money was already committed, and a second flagship promise is missing the evidence to back it up.
Estimated reading time: 6 minutes
In short. Defra published the Environmental Improvement Plan 2025 on 1 December 2025 [1], its revised statutory plan for meeting Environment Act 2021 targets. Its commitment to "provide over £110 million direct funding to Protected Landscapes organisations by April 2026" (page 20) [2] is, per the Office for Environmental Protection's own assessment of EIP25, "a restatement of already committed spending" with no additional resources attached (page 4) [3]. EIP25 also dropped its 2028 target for SSSI features to have an up-to-date condition assessment as "unachievable" (page 117) [2]; Defra's own July 2026 progress report shows that abandoned measure still "below the required trajectory" at 35%, while the softer measure that replaced it for 2030 is separately reported as on track [4]. A third finding: the OEP says the delivery plan for the Environment Act's legally-binding species targets "states that delivering other interim targets will achieve the statutory species targets without providing the evidence showing how", a "significant omission of important detail" (page 2) [3]. Three documented mistakes: four stars.
Defra published the Environmental Improvement Plan 2025 on 1 December 2025 [1], the government's revised answer to a legal duty under section 10 of the Environment Act 2021: set out how it will meet the statutory targets for nature, air, water and waste that Parliament itself wrote into law. Six weeks later, the Office for Environmental Protection, the independent body Parliament created in the same Act to check government's homework, published its own first look at the document [3]. Its overall verdict was positive: EIP25 is "a more coherent plan" than its 2023 predecessor, presenting government's approach "more clearly and transparently" (page 1) [3]. Three of its specific findings are less flattering, and they hold up against a direct check of the plan's own words and against Defra's first progress report on delivering it, published seven months later [4].
The claims, tested
| The claim | What we found | Verdict |
|---|---|---|
| EIP25's "Actions for commitment 4" instruct Defra to "Provide over £110 million direct funding to Protected Landscapes organisations by April 2026 to support local action on nationally important priorities, including nature restoration and access for all" (page 20) [2] | The OEP's assessment of this exact commitment, published six weeks after EIP25, found that "the £110 million funding commitment for Protected Landscapes actions is a restatement of already committed spending so there are no additional resources for the already constrained public bodies responsible for their operation" (page 4) [3] | A figure presented as a forward funding commitment that the plan's own watchdog says adds no new money |
| Among its revised Environment Act interim targets for nature, EIP25 states it has "removed the interim target for all SSSIs to have an up-to-date condition assessment by 2028 as this was unachievable in the timeframe", pushing that ambition to 2032, and sets a new, nearer-term test: "By December 2030 50% of Site of Special Scientific Interest (SSSI) features to have actions on track to achieve favourable condition" (page 117) [2] | Defra's first Annual Progress Report, published 16 July 2026, records the new "actions on track" measure at just under 26% by the end of March 2026, which it calls "in line with the anticipated trajectory". The old, abandoned measure, the share of SSSI features with an up-to-date condition assessment, is tracked separately and stood at approximately 35% over the same period, which the same report calls "below the required trajectory" [4] | The harder, more checkable measure was dropped as unachievable and is still lagging; the measure that replaced it for the nearer deadline is self-reported as on track |
| EIP25 sets out a delivery plan for the Environment Act's legally-binding species abundance targets, the first of its statutory nature targets (page 117) [2] | The OEP's assessment found that "the delivery plan for legally-binding species targets points in turn to other delivery plans and states that delivering other interim targets will achieve the statutory species targets without providing the evidence showing how", calling it "a significant omission of important detail" (page 2) [3] | The plan asserts that hitting its other targets will deliver its most prominent legal target, without showing its working |
The mistakes, counted
A headline funding figure for protected landscapes restates money already committed (1). Protected Landscapes are the 10 National Parks and 34 National Landscapes that, in EIP25's own words, "cover 25% of England" (page 20) [2]. Commitment 4 promises to "enable Protected Landscapes organisations to make land greener, wilder, and more accessible to all", and its first action is "over £110 million direct funding... by April 2026" (page 20) [2]. Read on its own, that sentence describes new money arriving at a fixed, near-term date. The OEP checked it against the funding settlement already in place and found the £110 million was already committed before EIP25 was published, with no additional resources for the public bodies that run these landscapes (page 4) [3].
The harder SSSI measure was dropped as unachievable; the measure that replaced it for 2030 is reported as on track while the dropped one still lags (2). EIP23 had set a single test: every Site of Special Scientific Interest feature to have an up-to-date condition assessment by 2028. EIP25 abandons it, in its own words, because it "was unachievable in the timeframe", and pushes that ambition to 2032 (page 117) [2]. For the nearer term, it substitutes a different test: 50% of SSSI features to have "actions on track to achieve favourable condition" by December 2030 (page 117) [2]. Defra's first progress report under the new plan shows why the substitution matters: the new "actions on track" measure is running at just under 26%, which the report itself calls on trajectory, while the old measure it replaced, the one judged unachievable, is still moving (33% to 35% over the same five months) but remains, in the report's own words, "below the required trajectory" [4]. The metric government dropped because it could not be hit on time is still behind; the metric that took its place for the nearer deadline is the one declared on track.
The delivery route to the plan's most prominent legal target does not show its working (3). Species abundance is the first of the Environment Act's statutory nature targets: halt the decline by 2030, and reach a level by 2042 that is both higher than 2022 and at least 10% higher than 2030 (page 117) [2]. Per the OEP's reading, EIP25 does not set out a direct delivery plan for that target; instead it states that achieving its other, separate interim targets, on habitat restoration, farm wildlife, invasive species and the rest, will together deliver the statutory species target, without showing the evidence or the calculation behind that claim (page 2) [3]. The OEP calls this "a significant omission of important detail" (page 2) [3], not a dispute over the target's ambition, but a gap in whether the plan can show its arithmetic adds up to the legal requirement it exists to meet.
Credit where due
The OEP's overall judgement on EIP25 is genuinely positive, and the plan deserves that credit stated plainly. Set against EIP23, the OEP found it "a more coherent plan that presents government's approach to improving the natural environment more clearly and transparently", with "more detailed information on how key targets will be delivered" (page 1) [3]. The OEP had given government detailed advice on improving the EIP in September 2024, and its briefing note records that "much of the advice we provided has been taken on board" (page 1) [3]. EIP25 is also candid, not evasive, about the SSSI deadline it dropped: the plan does not bury the change, it states outright that the 2028 target "was unachievable" and names 2032 as the new date (page 117) [2]. A government document that admits a deadline has failed, in its own words, is doing something plainer than most.
Verdict
Four stars, from three documented mistakes. EIP25 is, on the OEP's own independent assessment, a better plan than the one it replaced: clearer, more detailed, more responsive to the watchdog's advice. But a headline funding figure for England's protected landscapes restates money already committed rather than adding to it, the harder of two measures for one of its nature targets was dropped as unachievable and is still lagging behind the softer measure that replaced it, and the delivery route to its most prominent legal target skips the evidence for its own central claim. None of that is hidden. All three were found by checking the plan's own words, and Defra's own first report on delivering it, against the assessment of the regulator Parliament built to do exactly this job.
The star score counts three documented mistakes. First, EIP25's commitment to "provide over £110 million direct funding to Protected Landscapes organisations by April 2026" (page 20) is, per the OEP's own assessment of this exact commitment, "a restatement of already committed spending" with no additional resources attached (page 4). Second, EIP25 dropped its 2028 target for SSSI features to have an up-to-date condition assessment as "unachievable" (page 117); Defra's July 2026 progress report shows that dropped measure still running "below the required trajectory" at 35%, while the 2030 measure that replaced it for the nearer term is separately reported as on track at just under 26%. Third, the OEP found the delivery plan for the Environment Act's legally-binding species targets "states that delivering other interim targets will achieve the statutory species targets without providing the evidence showing how", calling it "a significant omission of important detail" (page 2). Three falls in the 1 to 3 band: four stars; the bands are on the ratings page. This piece makes no finding about the conduct of any named official; the plan's structure and its watchdog's published assessment are institutional facts, not any individual's decision. Checked directly against the Environmental Improvement Plan 2025, the OEP's Initial Assessment of EIP25 and Defra's EIP Annual Progress Report 2025 to 2026, all fetched 27 October 2026.
Sources
- Environmental Improvement Plan 2025, Defra, published 1 December 2025
- Environmental Improvement Plan 2025 (PDF), Defra, December 2025
- Environmental Improvement Plan 2025: Briefing Note from the Office for Environmental Protection (PDF), Office for Environmental Protection, January 2026
- Environmental Improvement Plan: Annual Progress Report, Defra, published 16 July 2026