In August, we wrote about version 3.0 of the Woodland Carbon Code, published on 1 August 2025 following a stakeholder consultation (Woodland Carbon Code - version 3.0.) One clear message from the consultation was that project participants are increasingly enthusiastic about the potential to measure and monetise the biodiversity enhancements which can be achieved by woodland creation projects; 60% of consultation respondents agreed or strongly agreed with the proposal to allow Woodland Carbon Code projects to monitor biodiversity baseline.

From version 3.0 of the Code, Scottish Forestry are piloting a methodology for measuring the biodiversity baseline of a project. The pilot is optional – it is not a requirement under the Code at this time - and is open to any woodland project under development or already validated to the Code. If the biodiversity baseline of a project is measured, this can be recorded in the Carbon Registry; and as the project continues to be monitored in the future, changes in biodiversity can also be recorded. Assessment of the biodiversity baseline must be carried out by an independent validator and this could be at validation or at verification stage. An approved biodiversity monitoring action plan must also be submitted.

So how are biodiversity baseline and enhancement to be measured? The biodiversity quantification framework being piloted was developed through a FIRNS (Facility for Investment Ready Nature in Scotland) project throughout 2024 and 2025; it proposes measuring both:

  • taxonomic indicators (such as plant, bird and insect abundance and diversity); and
  • structural metrics (in essence, an assessment of ecological condition against certain standards using the DEFRA BNG metric (or future Scottish equivalent) or woodland ecological condition tool).

Other factors, such as soil eDNA and connectivity, are also potential indicators to be considered. Guidance is available now on how to measure and record these indicators (SRUC guidance on taxonomic indicators and DEFRA tool/woodland ecological condition tool for structural metrics).

This is all at an early and evolving stage. It is important to note that Scottish Forestry are not at this time committing to production of separate biodiversity credits as part of the Woodland Carbon Code; those opting to participate in the pilot are doing so on the basis there is no guarantee of any added or separate biodiversity units, despite the additional costs (financial and time) that biodiversity measurement and recording will inevitably give rise to. The Version 3.0 consultation brought in to focus certain other stakeholder concerns around biodiversity quantification of woodland projects, including the lack of certainty and consistency around measurement and recording methods, risk of double counting, and potential prejudice to woodland schemes which choose not to monitor biodiversity.

However, there is clear support for biodiversity quantification and promotion, both (i) from landowners and project developers (seeking, amongst other things, to encourage private investment in woodland projects) and (ii) at governmental level (the Scottish Biodiversity Strategy to 2045 sets out the Scottish Government’s plan to halt species loss and to restore and regenerate biodiversity across Scotland’s land by 2045). It is hoped that this pilot will allow feasibility and practicalities to be explored, and market understanding and confidence to be enhanced. Funding has been awarded to continue the FIRNS project to Phase 2; as part of that, FIRNS commits to refine and develop metrics, review costs and potential incomes and create a roadmap for including biodiversity crediting into the Woodland Carbon Code.

For further information or advice, please get in touch with one of our agricultural lawyers or your usual Brodies contact.

Contributor

Amy Cugini

Legal Director