Skip to main content
Guidance

What you can count towards a development’s biodiversity net gain

How developers can use habitat creation or enhancements to count towards their biodiversity net gain (BNG).

From:
Department for Environment, Food & Rural Affairs
Published:
2 May 2023
Last updated:
25 August 2026 — See all updates

Applies to England

This page applies to:

  • developments that need planning permission
  • nationally significant infrastructure projects (NSIPs), from 2 November 2026

If you need to create or enhance habitat as part of your development, there are rules about how you may be able to count this towards your biodiversity net gain (BNG). These rules make sure that BNG delivers actions beyond what is already required through statutory obligations or policies.

There are habitat schemes and activities that you can:

  • count in full

  • count up to no net loss

  • not count at all

How these schemes and activities can count towards your BNG depends on whether you create these habitats as:

  • mitigation and compensation actions for other impacts

  • enhancing actions

The same rules on what you can count apply across both on-site and off-site BNG. However, any off-site habitat creation and enhancement must be registered on the biodiversity gain sites register for it to count towards your BNG.

Special rules apply to delivering BNG on protected sites. Protected sites are areas that have a high level of legal and policy protection because of their natural and cultural importance. You should avoid impacts to protected sites wherever possible.

What you can count in full

You may be able to count in full enhancing activities delivered to comply with certain statutory obligations or policies. For example:  

You can satisfy all of your BNG through these enhancing activities, including up to no net loss as well as your 10% net gain (or more where applicable).

Enhancing protected sites for BNG purposes

You may want to carry out enhancing activities within a protected site to contribute to your BNG. You can count these activities in full towards your BNG if both the following conditions apply: 

  • you do not carry out these enhancing activities for other statutory obligations  

  • there are no adverse impacts on the protected site

Before you can enhance habitat within a protected site, you must: 

You must adhere to the following rules to provide enhancements within a protected site: 

  • terrestrial protected sites – you can enhance the non-designated features of the protected site providing there are no adverse impacts on the protected site 

  • intertidal protected sites – you can enhance any intertidal habitat on a protected site, including any designated features

What you can count up to no net loss

If you are carrying out habitat mitigation or compensation activities required through statutory obligations or policies, some of these can only count up to no net loss. Your additional 10% net gain above no net loss must come from separate activities other than mitigation and compensation.  

Activities that count up to no net loss include: 

  • nutrient neutrality or mitigation

  • mitigation or compensation to protected species or protected sites  

  • river basin management plan (RBMP) mitigation 

  • suitable alternative natural green space (SANG)

  • environmental impact assessment mitigation  

  • mitigation or compensation to functionally linked land (FLL) 

  • district level licensing schemes 

  • sustainable drainage systems (SuDS) – when part of nutrient neutrality

Mitigation or compensation to protected sites

You may enhance habitats within a protected site as mitigation or compensation for other statutory obligations or policies, if agreed with the consenting body.  

Any mitigation or compensation for impacts on protected sites can only count up to no net loss. You will need to deliver additional measures to meet your net gain. 

Example

Your development has a baseline biodiversity value of 10 units. The development works will result in the loss of habitats equivalent to 5 biodiversity units.  

In addition, you need to do habitat creation to mitigate for impacts the development will have on a nearby protected site (for example, provide SANG). These works create 6 biodiversity units but, because this is mitigation activity that must be agreed with the consenting authority, you can only count 5 of these units. This will bring your total back to 10 units, giving you the equivalent of no net loss. 

You must therefore deliver an additional 1 unit to achieve your 10% BNG. This unit must come from habitat creation or enhancement activities specifically for the purpose of BNG, or from those activities that can count in full. This can include additional habitat enhancement works on the mitigation site itself, other on-site or off-site gains, or the purchase of statutory biodiversity credits.

To count mitigation or compensation to protected sites towards your BNG, you must adhere to the following rules: 

  • terrestrial protected sites – you can only enhance the non-designated features of the protected site, providing there are no adverse impacts on the protected site 

  • intertidal protected sites – you can enhance any intertidal habitat on a protected site, including any designated features

What does not count at all

You cannot include some habitat activities towards your BNG at all. For example: 

  • restocking conditions relating to a tree felling licence or a restocking notice 

  • remediation under the environmental damage regulations 

  • remedial habitat creation or enhancement carried out under an existing planning obligation or condition such as a landfill restoration plan

How to include other activities in your BNG 

To count other habitat creation or enhancement activities towards your BNG, you must include them in your:  

  • metric calculation  

  • biodiversity gain plan – for developments that need planning permission 

  • outline and updated or phase biodiversity gain plans – for NSIPs 

If you are counting work for another activity in part towards your BNG, you should enter it into your metric calculation like any other habitat creation or enhancement work. You should also explain clearly in your biodiversity gain plan how at least 10% of your BNG is coming from habitat creation or enhancement outside the activity.

Updates to this page

Published 2 May 2023
Last updated 25 August 2026 Show all updates

  1. We have clarified the rules about creation and enhancement activities that can count in full, can count up to no net loss or do not count at all towards biodiversity net gain (BNG). This update also introduces guidance on habitat enhancements and mitigation within protected sites, and how they can count towards your BNG. The guidance also includes requirements when carrying out such activities within a protected site.

  2. Updated guidance to show it also applies to nationally significant infrastructure projects (NSIPs). Biodiversity net gain will be mandatory for NSIPs from 2 November 2026.

  3. Updated to add that NatureSpace’s district licensing scheme counts in part towards BNG, and clarify that counting Natural England’s district level licensing (DLL) in part towards BNG is not available yet. Natural England is working on how DLL may be able to count towards BNG in future.

  4. Updated to clarify that counting district licensing in part towards BNG is not available yet. Natural England is working on how it may be able to count towards BNG in future.

  5. Updated to state that biodiversity net gain (BNG) is mandatory from 12 February 2024. Also completely updated throughout to clarify the rules on what you can count in full, in part or not at all, including a table showing rules for specific schemes, and how to count other schemes towards BNG.

  6. First published.

Sign up for emails or print this page

Contents

Related content