GWCT Wales’ response to the Welsh Government’s SFS Consultation

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In December 2023 Welsh Government launched its consultation on the final proposals to the Sustainable Farming Scheme (SFS), which from 2025 is the scheme set to replace the Common Agricultural Policy (CAP) legacy schemes, including the Basic Payment Scheme (BPS), with a deadline of 7 March 2024 to respond to the 19 question consultation.

GWCT Wales’ consultation response includes key concerns with the scheme as is it outlined so far, as well as a reply to the questions posed in the consultation.


Whilst it is to Welsh Government’s credit that they wish to address both the climate and nature emergency, there are some very real threats that, left unaddressed, will likely see this scheme fail due to lack of participation. What is clear from consultation with our members is the adage that ‘you can’t be green if you’re in the red’, meaning that the farming community will find it increasingly difficult to help tackle the climate and nature emergency if they are not properly financially supported and if their businesses are not economically sustainable in the long-term.

Whilst the consultation includes sentences such as, “It recognises the delivery of environmental and social outcomes are dependent on ensuring farm businesses are economically sustainable in the long term”, the GWCT, our members and the wider farming community are concerned that the reality of the universal requirements will make this incredibly difficult.

This scheme offers what really is a last chance saloon for biodiversity recovery in Wales. Whilst on one hand that claim may encourage strict sanctions to enforce nature recovery with an iron grip, in trying to do so we believe that many farmers will be put off and participation will drop to levels offering little hope of a recovery of any kind.

What the GWCT believes is preferable and achievable is working with the farming community and taking a bottom-up, trusting approach. To join together on a journey that encourages participation and collaboration in such a way that nature recovery can slowly be built from the ground up, one step at a time to surpass levels previously seen. Welsh Government’s Farming Facts and Figures, Wales 2022 data shows there to be 10,229 farms in Wales (very small farm types excluded), yet only approximately 3,100 claims were made under Glastir. The percentage of farms in stewardship in Wales pales in comparison with the equivalent in England and highlights the lack of appeal of Glastir for Welsh farmers. Lessons must be learnt, and a more accessible scheme must be created. We would reiterate that climate and nature recovery will not be achievable unless Welsh Government works with the farming community and creates a scheme that encourages participation at the lowest level.

Consultation with our members re-enforces four themes, which we believe are key to the Sustainable Farming Scheme’s success and which similar themes were previously stated by Welsh Government staff during discussions prior to the latest consultation document.

  1. The scheme should be simple to enter and administer.
  2. It should be flexible and avoid being prescriptive
  3. It should be governed by a light regulatory touch
  4. The rewards should reflect the effort expended and the public benefits which result. It is essential that these principles are embedded in the final scheme. Beyond this, there are areas that could be improved, and we hope that our answers to the questions provide some constructive commentary.