Biodiversity Finance Journal

Reforming Subsidies That Harm Nature

The Kunming-Montreal Global Biodiversity Framework contains its own arithmetic. Target 18 commits parties to reduce incentives harmful for biodiversity by at least 500 billion dollars a year by 2030. Target 19 commits them to mobilise at least 200 billion dollars a year for biodiversity over the same period. The flow governments agreed to stop is two and a half times the flow they agreed to raise. Everything else in conservation finance is arguing over the smaller number.

Target 18 also carries a deadline that has already passed. Its instruction is conjoined rather than sequenced: identify by 2025, and eliminate, phase out or reform incentives harmful for biodiversity in what the text calls a proportionate, just, fair, effective and equitable way, starting with the most harmful, while scaling up positive incentives for conservation and sustainable use. Identification is the only step carrying a year, and it is the hard part. A subsidy is rarely labelled as harmful to biodiversity in any budget document. It appears as a fuel rebate, a fertiliser price, an import tariff, a vessel construction grant or a per-hectare payment, and its ecological effect is a consequence of the policy rather than its stated purpose.

The monitoring framework adopted alongside the targets shows how the parties handled that. Target 18 gets two headline indicators: the positive incentives in place to promote conservation and sustainable use, and the value of subsidies and other incentives harmful to biodiversity that have been eliminated, phased out or reformed. Its component indicator is the value of such subsidies and incentives that are redirected, repurposed or eliminated. Read all three together and they measure change rather than level. What a government has altered is counted at the top of the dashboard. What remains is not.

Level does appear elsewhere in the framework. Its complementary indicators include trends in potentially environmentally harmful elements of government support to agriculture on the producer support estimate, trends in the number and value of government fossil fuel support measures, and the amount of fossil fuel subsidies per unit of gross domestic product. So the framework is not silent about the size of the problem. It is partial about it, and the partiality follows sector lines: agriculture and fossil fuels are measured, and support harmful to biodiversity as a whole is not.

What is published sector by sector is a set of estimates, each built on its own method, its own country sample and its own definition of harm. Two of them, agriculture and fisheries, are set out below. The cross-sector work on environmentally harmful support that produces the figure most often quoted as a global total is published by the OECD, and no OECD number appears here.

The agriculture figure has a reversal inside it

The Food and Agriculture Organization, the United Nations Development Programme and the United Nations Environment Programme published a joint estimate in 2021 covering 88 countries. Net support to agricultural producers over 2013 to 2018 averaged almost 540 billion dollars a year, around 15 per cent of total agricultural production value. About 294 billion of that came as price incentives, meaning border measures such as import tariffs and export subsidies that open a gap between the domestic producer price and the border price of a commodity. Around 245 billion came as fiscal subsidies paid to farmers, of which the report puts 70 per cent as tied to producing a specific commodity or to unconstrained use of variable inputs. A further 110 billion went to the sector collectively as general services and public goods, and that figure sits outside the 540 billion rather than inside it.

The report's own characterisation is careful. It says over two thirds of the producer support is considered price-distorting and largely harmful to the environment, and that on current trends the total could reach almost 1.8 trillion dollars by 2030. It does not say that two thirds of world agricultural spending damages biodiversity, and the distinction is worth keeping, because the categories being counted are defined by their effect on prices and markets first.

The finding most often dropped from summaries is that the sign of the support flips with income. In high-income countries, and increasingly in middle-income ones, price incentives and production-tied fiscal subsidies dominate. In most low-income countries the farming sector is penalised rather than supported, by policies that hold food prices down for poor consumers and therefore tax producers indirectly. Reform in those two settings is not the same policy under a different flag. Removing a coupled subsidy in one country and removing an implicit tax in another point opposite ways, which is why Target 18 was written with the words proportionate, just and equitable in it.

If reform is difficult, redirection is not obviously easier, and Europe has audited its own attempt. The European Court of Auditors examined the contribution of the Common Agricultural Policy to farmland biodiversity and reported in 2020. Its title states the conclusion: the policy contribution has not halted the decline. Populations of farmland birds and grassland butterflies in Europe have fallen by more than 30 per cent since 1990. For the 2014 to 2020 period the Commission planned to spend 8.1 per cent of the European Union budget, some 86 billion euros, on biodiversity, and 77 per cent of that amount, 66 billion euros, was to come from the agricultural policy itself.

The auditors found three things wrong at once. The formulation of the strategy's agriculture target made progress hard to measure. The Commission's tracking of how much of the agricultural policy actually counted as biodiversity spending was unreliable. And the effect of direct payments, which are 70 per cent of European agriculture spending, on farmland biodiversity is limited where it is known at all, because the greening and cross-compliance requirements attached to them had potential that member states and the Commission met with low-impact options. The auditors add that member states relatively seldom use high-impact rural development measures, their two examples being result-based schemes and the ones the report calls dark green. A budget line can be relabelled as green without becoming green, and a supreme audit institution is the body most likely to notice.

Fisheries subsidies are the one case with a binding international rule

The World Trade Organization adopted its Agreement on Fisheries Subsidies by consensus at the twelfth Ministerial Conference in June 2022. It prohibits subsidies for illegal, unreported and unregulated fishing, for fishing overfished stocks, and for fishing on the unregulated high seas. Entry into force required two thirds of members to deposit instruments of acceptance, and that threshold was reached at a ceremony on 15 September 2025. The organisation describes it as the first WTO agreement with environmental sustainability at its core and only the second multilateral agreement concluded there since the institution was founded.

The magnitudes are modest next to agriculture and the framing is precise. The WTO puts subsidies to marine fishing activities at an estimated 35 billion dollars a year worldwide, of which around 22 billion are considered harmful and contributing to the depletion of marine stocks. It sets that against a stock assessment: 35.5 per cent of global fish stocks were overfished in 2021, against 10 per cent in 1974. Now put those two numbers together with the framework's. Twenty-two billion dollars is a little over four per cent of the reduction Target 18 asks for, and prohibiting it took a negotiated multilateral treaty, more than three years between adoption and entry into force, and the deposited acceptance of two thirds of the membership. That is what removing four per cent costs.

Ecological fiscal transfers run the money the other way

An ecological fiscal transfer works inside the ordinary machinery of intergovernmental finance. An environmental criterion is written into the rule that moves revenue from a national treasury to the tiers of government below it, and the money then follows the criterion. What varies between designs, and it varies more than the label suggests, is how exposed that rule is to the annual budget.

India built one into its main federal transfer. The Fifteenth Finance Commission set the criteria and weights for distributing the divisible pool of central taxes among the states, and assigned forest and ecology a weight of 10 per cent, alongside population at 15, area at 15, income distance at 45, demographic performance at 12.5 and tax and fiscal efforts at 2.5. The criterion is calculated from each state's share of the aggregate dense forest of all states. The Commission raised the weight from the 7.5 per cent its predecessor had assigned, on the reasoning that forest cover both provides ecological services to the country and imposes opportunity costs on the state maintaining it, and recorded that some states had asked for the criterion to be dropped altogether.

France added a smaller and more targeted version. Its support grant to communes for rural amenities, created in its present form in 2024, is a free-use operating grant paid to communes whose territory includes a protected area, among them regional natural parks, Natura 2000 sites and the adhesion zones of national parks. State communications describe its purpose as compensating the planning constraints that environmental protection imposes while recognising the environmental services those communes provide to the nation. The national envelope went from 42 million euros in 2023 to 100 million in 2024, and the initial budget law for 2025 raised it to 110 million, an increase of 68 million euros in two years. In one department, Loir-et-Cher, that meant 80 communes sharing 817,660 euros in 2023, 99 communes sharing 1,993,125 euros in 2024, and 101 communes sharing 2,192,161 euros in 2025.

The two sit very differently in a budget. India's criterion is a weight inside the formula that divides the central tax pool among the states, so it redirects money that would be distributed anyway and nothing has to be voted for it separately. France's is a dedicated grant whose envelope is fixed each year in the initial budget law. That is how it more than doubled between 2023 and 2025, and it is also how it could go back. Anyone citing the two together as a single durable instrument is citing a formula weight and an annual appropriation as though they were the same thing.

What they do share is that neither is conditional on an ecological result. A state receives its forest share for having dense forest, not for improving it, and a commune receives its grant for containing a protected area rather than for how the area is managed. The instrument rewards the presence of the thing rather than the care of it, which is a real limitation and also what keeps it cheap to administer.

The asymmetry in the dashboard is what to carry away from all this. Target 19's three headline indicators count levels of funding: international public, domestic public and private. Target 18's two count positive incentives in place and harmful support already removed. A government that has changed nothing therefore reports nothing on the larger of the two numbers, and reports it accurately. That is not a flaw anyone hid. It is what happens when the quantity a target aims at has to be assembled from sectoral estimates that governments do not produce for this purpose, and it is why the reform stories worth following are the ones with a treaty, an audit or a budget line behind them rather than a total.

Sources

Every figure, date and deal name above is drawn from one of the documents below. Each was fetched and cached on the retrieval date shown.

  1. Convention on Biological Diversity, decision 15/4, Kunming-Montreal Global Biodiversity Framework. Target 18 on identifying and reducing incentives harmful for biodiversity by at least 500 billion dollars per year by 2030, and Target 19 on mobilizing at least 200 billion dollars per year by 2030 https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-en.pdf Retrieved 2026-08-30
  2. Convention on Biological Diversity, decision 15/5, monitoring framework for the Kunming-Montreal Global Biodiversity Framework. Headline indicators 18.1 and 18.2 for Target 18, and D.1, D.2 and D.3 for Target 19 https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-05-en.pdf Retrieved 2026-08-30
  3. FAO, UNDP and UNEP (2021), A Multi-Billion-Dollar Opportunity: Repurposing agricultural support to transform food systems. The 88 country sample, the 2013 to 2018 average of almost 540 billion dollars of net producer support, its split between price incentives and fiscal subsidies, the separate 110 billion dollars of general services, the 1.8 trillion dollar projection for 2030 and the finding that most low income countries penalise rather than support producers https://www.fao.org/3/cb6562en/cb6562en.pdf Retrieved 2026-08-30
  4. European Court of Auditors, Special Report 13/2020, Biodiversity on farmland: CAP contribution has not halted the decline. The decline in farmland birds and grassland butterflies since 1990, the 86 billion and 66 billion euro planned biodiversity spending figures for 2014 to 2020, the unreliable tracking finding and the assessment of direct payments https://www.eca.europa.eu/Lists/ECADocuments/SR20_13/SR_Biodiversity_on_farmland_EN.pdf Retrieved 2026-08-30
  5. World Trade Organization, Fisheries subsidies. The topic page describing the Agreement on Fisheries Subsidies, its adoption at the twelfth Ministerial Conference in June 2022 and the two thirds acceptance threshold reached on 15 September 2025 https://www.wto.org/english/tratop_e/rulesneg_e/fish_e/fish_e.htm Retrieved 2026-08-30
  6. World Trade Organization news item, 15 September 2025, on entry into force. The three prohibitions, and the estimates of 35 billion dollars a year of marine fishing subsidies of which around 22 billion are considered harmful, alongside the overfished stock share for 2021 and 1974 https://www.wto.org/english/news_e/news25_e/fish_15sep25_e.htm Retrieved 2026-08-30
  7. Fifteenth Finance Commission of India, Finance Commission in COVID Times: Report for 2021-26, Volume I, Main Report. Table 1.3 on horizontal devolution criteria and weights, and paragraphs 6.46 to 6.48 on the forest and ecology criterion, its calculation from each state share of aggregate dense forest, and the increase from the 7.5 per cent weight set by the previous Commission https://fincomindia.nic.in/asset/doc/commission-reports/XVFC%20VOL%20I%20Main%20Report.pdf Retrieved 2026-08-30
  8. Prefecture of Loir-et-Cher, press release of 6 August 2025 on the attribution of the support grant to communes for rural amenities in 2025. The eligibility rule, the stated purpose, the national envelope for 2023, 2024 and 2025, and the departmental commune counts and amounts https://www.loir-et-cher.gouv.fr/Publications/Communiques-de-presse/Annee-2025/Attribution-de-la-dotation-de-soutien-aux-communes-pour-les-amenites-rurales-en-2025 Retrieved 2026-08-30