
The Pulse by GRESB
The Pulse by GRESB is an insightful content series featuring the GRESB team, partners, GRESB Foundation members, and other experts. Each episode focuses on an important topic related to either GRESB, sustainability issues within real assets industry, decarbonization efforts, or the wider market.
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New rules and biodiversity: Diving into the changing landscape for infrastructure
In this episode of The Pulse by GRESB, Antonina Ivanova, Associate on the Infrastructure team at GRESB, speaks with CMS experts Rebecca Roffe and Laura Gunn to unpack the fast-growing field of biodiversity regulation and what it means for infrastructure. The conversation explores regulatory drivers in the UK, EU, and beyond, the practical challenges and opportunities for investors and asset managers, and how early integration of biodiversity considerations can support compliance, resilience, and long-term value creation. Tune in to learn how infrastructure players can stay ahead as biodiversity becomes a central factor in sustainable investment.
Transcript
Can’t listen? Read the full transcript below. Please note that edits have been made for readability.
Antonina: Welcome to The Pulse by GRESB. I’m your host, Tonya Ivanova, Associate in the Infrastructure team at GRESB. Today we’re diving into a topic gaining rapid momentum in the infrastructure world: biodiversity regulation and what it means for the sector.
I’m joined by two experts from CMS: Rebecca Roffe, Partner in Planning, and Laura Gunn, Associate in Environment. Together, we’ll explore the drivers behind these changes, the risks and opportunities for investors and asset managers, and how the industry can stay ahead of the curve. Rebecca, Laura—welcome to The Pulse.
Rebecca: Thank you. It’s great to be here.
Laura: Thank you so much for having us.
Antonina: To start, why is biodiversity becoming such a big focus in the infrastructure world? Rebecca, maybe you can kick this off.
Rebecca: Of course. In the UK, we’ve seen major policy drivers for biodiversity improvements. A mandatory process for biodiversity net gain was introduced in February 2024 for town and country planning applications. And from 2026, it will also apply to large, nationally significant infrastructure projects.
The key shift is moving beyond simply mitigating biodiversity loss to actually delivering tangible improvements. Projects must now deliver at least a 10% uplift in biodiversity. While the details are still being finalized, this is a clear step toward embedding biodiversity in infrastructure development. At the moment, this only applies in England, but other devolved administrations are watching closely.
Antonina: That’s helpful context. Laura, are we seeing similar approaches globally?
Laura: Yes. The UK is a leading example, but it’s part of a broader global trend. Globally, biodiversity loss is increasingly recognized as a systemic risk to supply chains, resilience, and even license to operate.
We have the Kunming-Montreal Global Biodiversity Framework from COP15, and in the EU, the Nature Restoration Law and Biodiversity Strategy for 2030. These require member states to restore 20% of degraded land and sea by 2030, and 100% by 2050. We can expect more BNG-style measures to emerge as these laws are implemented.
Elsewhere—in Australia, Canada, Southeast Asia—we’re seeing biodiversity credit schemes, evaluation frameworks, and ecological compensation strategies. In Ireland, new laws require biodiversity strategies at local authority level, annual reporting by public bodies, and planning reforms that embed biodiversity into decision-making. The revised National Planning Framework also requires a national restoration plan by 2026.
So while terminology varies, the direction is clear: biodiversity enhancement is becoming a standard expectation worldwide.
Antonina: Thank you, Laura. With all this regulatory movement, what are the implications for investors and industry players?
Rebecca: In England, the mandatory 10% net gain creates real complexity. Gains can be delivered onsite, offsite via habitat banks, or through government credits. Offsite habitats must be managed for 30 years, which adds layers of agreements and project delays. Local authorities also lack resources, which slows progress.
But there are opportunities too. Some investors are exploring their own habitat banks—buying or leasing land for biodiversity projects, then selling units back into the statutory system. These units are in high demand and can be lucrative.
Laura: And from a global perspective, we’re also seeing the rise of standardized disclosure frameworks like the Taskforce on Nature-related Financial Disclosures (TNFD). While voluntary, they push investors and asset managers to report biodiversity metrics. In the EU, the Corporate Sustainability Reporting Directive (CSRD) will further embed biodiversity reporting.
Antonina: Given this, how can managers and owners ensure their assets stay compliant with evolving regulations?
Laura: The key is early integration. Biodiversity should be addressed from the outset—during site selection, design, and feasibility. That means ecological expertise, baseline assessments, and nature-based solutions.
Managers need to track regulatory changes closely, budget for biodiversity gains, and align internal reporting with voluntary frameworks like TNFD. Upskilling teams in biodiversity literacy is also becoming as important as carbon literacy.
Rebecca: Exactly. It’s about planning ahead and accepting that biodiversity requirements are here to stay. Beyond BNG, we’re also seeing proposals for nature levies, environmental outcomes reports, and environmental delivery plans. The regulatory landscape is expanding quickly, so managers must be proactive.
Antonina: Thank you both. It’s clear biodiversity is no longer optional—it’s becoming a core consideration for investors, developers, and asset managers.
If you’d like to explore this topic further, visit the GRESB website or reach out to us directly. That’s all for this episode of The Pulse. Many thanks to Rebecca and Laura for joining and sharing their expertise.
Rebecca: Thank you.
Laura: Thanks very much.