National Biodiversity Strategies and Action Plans (NBSAPs)
This Action Area covers:
• The entry points through which a biodiversity strategy can become part of fiscal and investment planning.
• How fiscal, regulatory, and disclosure levers can redirect private capital toward nature-positive outcomes.
Context and role of Ministries of Finance
Biodiversity policy is increasingly moving from an environmental ministry concern to a question for Ministries of Finance (MoFs). Over half of national output depends directly on ecosystems that are deteriorating (WEF, 2020). Agriculture relies on pollinators, fisheries on healthy ecosystems, cities on watersheds for their water, and many economies on nature-based tourism for foreign exchange. As these systems decline, productive capacity weakens, sovereign creditworthiness can suffer, and the costs of replacing lost ecosystem services and of climate-nature feedback loops eventually fall on the public balance sheet (see the Nature and Biodiversity thematic overview page).
National Biodiversity Strategies and Action Plans are the primary national instrument supporting nature-positive agendas
Through National Biodiversity Strategies and Action Plans (NBSAPs), Parties to the Convention on Biological Diversity translate the Kunming-Montreal Global Biodiversity Framework (GBF) to their domestic context and realities. They also underpin the associated National Biodiversity Finance Plans that turn commitments into costed, implementable pathways. Yet the finance-oriented elements of the Kunming-Montreal GBF remain among the least well addressed in the plans submitted so far. The Convention on Biological Diversity Secretariat’s review of 58 revised or updated NBSAPs found that barely half of submissions reflected each of the four finance targets: aligning financial flows, business disclosure, harmful-subsidy reform, and resource mobilization (CBD Secretariat, 2025a).
Since the Kunming-Montreal GBF was only adopted in 2022, most MoF engagement on biodiversity is recent; the examples in this Action Area largely document institutional design and early implementation rather than demonstrated outcomes at scale. However, this reflects the stage of the agenda rather than a gap in ambition, and the guidance below is emerging practice to be updated as results come through successive NBSAP and National Biodiversity Finance Plan cycles.
Achieving these nature goals requires alignment with the economy and government processes
MoFs are central to this alignment as they operate many of the policy levers that govern the economy and shape economic incentives, including public finance, regulatory, and economic policy tools. Their involvement makes it more likely that goals are achieved and that they are delivered in an economically efficient way. However, NBSAPs are not currently well integrated into the decision-making processes of governments and the private sector, and most countries have not linked them to theirdomestic growth, development, and industrial strategies (see Function 1, Shaping 21st century industrial and innovation strategies). MoFs need more involvement in the design and implementation of NBSAPs through cross-government collaboration,otherwise documents risk remaining aspirational without the necessary funding.
Private investment decisions dominate nature-positive or nature-negative outcomes
An MoFs’ ability to shape private capital allocation is a key part of the biodiversity finance toolkit. Fiscal, regulatory, and procurement levers—public expenditure, taxation, subsidies, financial-market regulation, and disclosure requirements for companies and financial institutions—determine whether NBSAPs translate into tangible outcomes or remain aspirational documents. The Kunming-Montreal GBF makes this opportunity concrete: Targets 14 (alignment of financial flows), 15 (business disclosure), 18 (reform of harmful incentives), and 19 (resource mobilization) are delivered through fiscal and regulatory architecture, which often rests in MoF and regulatory hands.
MoFs can take an integrated approach to climate, biodiversity, and sustainability in investment decisions
This avoids measures that deliver climate gains at the expense of both nature and public finances. In practice, this means screening climate investments for their biodiversity impacts. For example, bioenergy monocultures or planting exotic species of tree can damage existing ecosystems (and even reduce the carbon stored in them), undermining the very climate gains they aim to deliver (Pörtner et al., 2021). Conversely, nature-based solutions such as the protection of mangroves, peatlands, and forests can be more effective than “grey infrastructure” and deliver benefits across climate mitigation, adaptation, and biodiversity, provided they complement rather than replace ambitious emission reductions (ibid.).
Aligning NBSAPs with Nationally Determined Contributions (NDCs), National Adaptation Plans (NAPs), and Long-Term Low Emission Development Strategies (LT-LEDS), for example within a holistic SDG strategy, can make this integrated approach systematic (CBD Secretariat, 2025b). It ensures that climate investment pipelines defined under climate planning instruments are screened against biodiversity objectives from the outset, rather than addressed case by case after commitments are made.
MoFs have several concrete entry points to support the design and implementation of NBSAPs
They can work with the lead agency, such as the Ministry of Environment, by leading or supporting the following processes as appropriate.
Costing biodiversity commitments and developing National Biodiversity Finance Plans
First, National Biodiversity Finance Plans identify the financing needed to implement NBSAP commitments and set out how resources will be mobilized from public budgets, private finance, international support, and policy reforms. They typically include biodiversity expenditure reviews, finance gap assessments, financing instruments, and implementation roadmaps. Costing translates national biodiversity targets into credible, implementable pathways by clarifying the scale of resources required, the biodiversity finance gap, and the mix of public, private, and international sources needed to close it. It also makes visible the cost of inaction, including contingent liabilities from disaster response, food insecurity, and infrastructure damage, providing a clear fiscal justification for biodiversity investment.
This work underpins the development of associated National Biodiversity Finance Plans, which translate NBSAP commitments into costed, time-bound financing roadmaps aligned with the national budget cycle. Natural capital accounting is a key entry point for this. (Uganda’s MoF, for example, is working to quantify its national biodiversity finance gap and identify private-sector entry points. To replicate these approaches, the UNDP BIOFIN Workbook 2024: Finance for Nature provides a standard methodological framework for countries to conduct these financial needs assessments and design National Biodiversity Finance Plans (UNDP BIOFIN, 2024).
Integrating NBSAP commitments into core public financial management systems
Second, translating NBSAP targets into public expenditure requires embedding biodiversity objectives into the instruments through which MoFs allocate and track resources. Biodiversity budget tagging enables MoFs to identify budget allocations contributing to NBSAP objectives. It extends the climate tagging logic to nature by tracking expenditures that conserve, restore, or sustainably use ecosystems, supporting monitoring and accountability (see Function 2, Using the budget to drive transformation in all sectors of the economy). France has applied green budgeting since 2020, tagging all budgetary and tax expenditures according to their environmental impacts.
Mainstreaming biodiversity across sectors
Third, NBSAP implementation requires action across multiple sectors simultaneously. MoFs are well placed to drive coherence by embedding biodiversity criteria into the fiscal and regulatory frameworks that govern each sector, including land-use planning, infrastructure, disaster risk reduction, coastal management, and circular economy strategies. Sectoral nature-positive transition pathways offer a structured, government-led instrument for this: by mapping how each sector should transform and when, they help MoFs prioritize policies and incentives, align limited fiscal resources with biodiversity targets, and give the private sector the long-term clarity needed to crowd in capital (BfN et al., 2026).
Reforming biodiversity-harmful subsidies
Fourth, governments spend approximately US$2.4tn annually on support that incentivizes ecosystem degradation, particularly in agriculture, fisheries, fossil fuels, and infrastructure, such as subsidies that encourage overfishing, deforestation, or excessive fertilizer use (UNEP, 2026). Kunming-Montreal GBF Target 18 calls on governments to identify incentives harmful to biodiversity and contribute to a collective global goal of reducing them by at least US$500bn per year by 2030. Savings can either relieve the budget (reducing the tax or debt burden) or be recycled into nature-positive investments and targeted transition support for vulnerable groups (see Function 2, Carbon taxes and pricing, subsidy reform, and frontiers in environmental taxation). For practical guidance on execution, Finance for Nature Positive: Building a Working Model documents operational models for this redeployment (UNEP FI and Finance for Biodiversity Foundation, 2024).
Establishing regulatory frameworks for biodiversity-related disclosure
Fifth, regulatory frameworks are one mechanism through which MoFs can help convert biodiversity information into standardized, comparable disclosure that feeds national NBSAP targets rather than standalone sustainability reporting. This work is often done alongside financial regulators and central banks who typically hold direct rule-making authority over corporate disclosure. France’s Article 29 of the Energy-Climate Law demonstrates how a legislative disclosure mandate creates the regulatory environment to which private institutions then respond. It requires all financial institutions to report biodiversity-related risks and impacts on a double materiality basis.
The European Union’s interlocking Corporate Sustainability Reporting Directive, Taxonomy, and European Sustainability Reporting Standards frameworks make the same point at scale: coherent regulation sustained across multiple legislative cycles produces the private-sector alignment that quality biodiversity disclosure practices illustrate. For MoFs designing national disclosure frameworks, sequencing and coherence across instruments matter more than the ambition of any single measure. Aligning national disclosure requirements with the standards of the International Sustainability Standards Board of the International Financial Reporting Standards Foundation helps avoid contradictions, duplication and double reporting (IFRS,2026). UNEP FI’s Accountability for Nature (2025) and Recommendations from Voluntary Nature-Related Reporting Frameworks (2024) provide the necessary framework comparisons (See Function 3, Using financial sector policy to mobilize private capital for the transition).
Mobilizing private finance through dedicated instruments and markets
Sixth, a core MoF role is to act as market enabler for private nature-related investment. Sovereign nature bonds and blended-finance structures that channel private capital are covered in Function 3, Debt financing for investment in sustainable infrastructure and Driving innovations in financing models, including blended finance; beyond these, MoFs can create markets directly.
Market-creating regulation examples include the United Kingdom’s Biodiversity Net Gain rule. It requires new developments to deliver a measurable 10% increase in biodiversity value, with any shortfall met by purchasing units from landowners who restore habitat elsewhere. This creates private demand for biodiversity outcomes and finances habitat creation without public expenditure (Defra, 2024; GFI, 2024). Targeted tax incentives work through the same enabling logic: South Africa’s Biodiversity Management Agreements, for instance, tie a tax deduction to an approved biodiversity management plan, rewarding private stewardship at lower fiscal cost than direct spending (DFFE, 2021).
Barriers to action and ways to overcome them
Despite the recognition of MoFs’ relevance to climate action, several barriers continue to limit their ability to contribute effectively to the development and strengthening of climate plans. While there are distinct challenges depending on the context, a number of common constraints and solutions emerge across countries. The barriers below therefore affect all four Action Areas in Function 1, Participating in the development and implementation of climate and related strategies, rather than any single one.
Limited institutional coordination
Weak coordination between MoFs and Ministries of Environment or other designated lead agencies often results in delayed or narrowly scoped involvement of the MoF in climate planning processes. When planning and finance ministries are excluded from drafting and brought in only to validate finished work, they can neither own the strategy nor coordinate its implementation (World Bank, 2026).
Approach
Strengthen governance and coordination arrangements as a whole-of-government approach. Clear governance structures are critical to ensuring timely and meaningful participation of all relevant institutions throughout the climate planning process. In many cases, countries have already set up governance structures dedicated to NDC delivery, which can also be used for LT-LEDS and NAPs (see Capability 2, Coordination and collaboration for whole-of-economy climate action). These typically include a steering committee to provide political leadership and strategic direction; technical committee(s) to guide analysis, coordinate data, and ensure outputs respond to the needs of different ministries; and a core group responsible for day-to-day coordination.
Climate (Finance) Units and Country Platforms have proven to be effective mechanisms for strengthening inter-institutional coordination, particularly between MoFs, Ministries of Environment, line ministries, private sector, and other relevant sectoral stakeholders (see Capability 1, Formalizing governance structures and organizational set-up and Function 3, Leveraging international climate finance and reforming the global financial architecture).
Capacity and data constraints
Many MoFs face shortages in both human and technical capacity, including the tools and expertise to systematically analyze the links between climate change, economic performance, and fiscal outcomes. A survey conducted by the Coalition of Finance Ministers for Climate Action found that 78% of MoFs identify limited data availability as major constraint to advancing climate‑related analytical work (CFMCA, 2025a).
For NBSAPs specifically, indicators that directly measure biodiversity outcomes (such as ecosystem condition, species abundance, restoration areas, or biodiversity footprints) remain limited in mainstream financial decision-making, and biodiversity value is largely absent from GDP accounting, tax base projections, and medium-term expenditure frameworks (UNEP FI, 2024a).
Approach
Invest in capacity, data, and analytical tools. To engage effectively in climate planning processes, MoFs require sufficient human and technical capacity, underpinned by robust data systems and analytical tools (see Capability 3, Enhancing economic decision-making tools and data-driven analysis). This includes strengthening their ability to assess climate related risks, costs and benefits, and macrofiscal impacts as well as developing systems to monitor progress and track climate finance flows.
Investments in monitoring, reporting, and verification frameworks can enhance transparency, accountability, and evidence-based decision-making. Embedded advisory support models, which place climate finance experts within MoFs, have proven effective in facilitating knowledge transfer and sustaining capacity gains beyond the duration of technical assistance (Caldwell et al, 2022; see Function 1, Shaping 21st century industrial and innovation strategies, Function 2, Reforming fiscal policies and Function 3, Financing the transition through reforming the financial system and instruments).
Social dimensions are considered too late
Social and labor market implications are often identified too late in the planning cycle, largely due to lack of coordination with ministries responsible for labor, skills, social protection, and enterprise development. Climate plans may be technically sound but difficult to implement where workers, enterprises, and affected communities have not been engaged, where skills constraints are not anticipated, or where compensation and support measures are not costed.
Approach
Include social and labor-market analysis at the formulation stage. This can be addressed by working with Ministries of Labor and supported by structured engagement with social partners. Workers’ and employers’ organizations can provide early information on sectoral employment exposure, skills gaps, business preparedness, compliance costs, value-chain disruption, and informal-work realities. This improves the assumptions used in climate planning and helps ensure that compensation, training, enterprise support, and social protection measures are designed before implementation bottlenecks or opposition emerge (ILO, 2025).
Weak accountability and feedback mechanisms
Many countries lack robust processes and tools, such as monitoring, reporting, and verification systems and climate finance tracking frameworks, that integrate accountability, learning, and systematic feedback into the revision and strengthening of climate plans, particularly for adaptation finance.
Approach
Institutionalize monitoring, reporting, and verification systems and climate finance tracking frameworks, and build the feedback loops that connect them back into plan revision. Established public financial management instruments—climate budget tagging and tracking, disaster budget tagging, climate public expenditure and institutional reviews, and Public Expenditure and Financial Accountability Climate assessments—can be extended beyond NAPs to LT-LEDS, NDCs, and NBSAPs, so that evidence on what is and is not working feeds systematically into successive rounds of planning.
Constraints in accessing climate finance
The complexity of the global climate finance architecture requires significant technical expertise and administrative capacity, posing particular challenges for smaller MoFs and those in Small Island Developing States (UN-OHRLLS, 2022). For biodiversity finance, an additional constraint is the weakness of market signals: financial institutions still treat biodiversity primarily as a source of risk rather than as an opportunity for value creation, and the role of the private sector in achieving biodiversity targets is less clearly defined than for netzero targets, limiting capital allocation to nature-positive activities (UNEP FI, 2024a).
Approach
Develop climate finance and investment strategies, including within broader growth, development or Sustainable Development Goals strategies(see Function 1, Greening national development and sector strategies). MoFs are well placed to lead the development of climate finance and investment strategies that translate climate priorities into actionable and credible financing plans. This includes identifying domestic budgetary resources, coordinating public investment, improving enabling environments, mobilizing private capital, and improving access to international climate finance. The NDC Partnership and Green Climate Fund’s Climate Investment Planning and Mobilization Framework provides a structured, country-driven approach to institutional coordination, investment prioritization, and public-private financing (NDC Partnership, 2025).
Political economy pressures on engagement
MoFs face institutional disincentives to deep engagement in climate planning that go beyond capacity gaps: the political cost of quantifying fiscal constraints on NDC ambitions; the risk of conflict with sectoral ministries that carry stronger political weight; and the short horizons that electoral cycles impose on long-term strategy work (see Box F1a(i).1; World Bank, 2023).
Approach
MoFs can navigate these dynamics directly. On interministerial coordination, an MoF can use its center-of-government position to make climate objectives a condition of the budget and financing processes it manages.
On subsidy and pricing reform, sequencing compensation and social protection payments ahead of price increases—and reporting both the reform and the compensation transparently in public finance documents—builds the public trust needed to sustain the coalition behind reform (see Function 2, Transforming economic incentives through carbon pricing, subsidy reform and other fiscal policy measures).
Regarding electoral cycles, embedding commitments in legal and institutional frameworks and linking milestones to financing conditions with development partners allows commitments to persist across administrations. For example, Costa Rica is trying to write its Long-Term Low Emission Development Strategy, the National Decarbonization Plan, into national law (World Bank, 2023).
Several global initiatives can support countries with the development and implementation of NDCs, NAPs, and LT-LEDS
These initiatives provide technical assistance, financing support, capacity building, and platforms for peer learning. The NDC Partnership, the NAP Global Network and the 2050 Pathways Platform provide country-tailored technical assistance, peer exchange, and financing support across NDCs, NAPs, and LT-LEDS, respectively. UNDP BIOFIN does the same for the financial side of NBSAPs.
The Initiative for Climate Action Transparency strengthens the tracking and reporting side through its Climate Finance Transparency Framework. The Country Platform Hub supports governments in designing and operationalizing country platforms that align national climate and development priorities with financing strategies and investor engagement, and the ILO is supporting countries with leveraging NDCs as a vehicle of a just transition (see also Function 3, Setting up country platforms).
Opportunities for action
It is beneficial for MoFs to treat active engagement in national climate and biodiversity planning as institutional responsibility, working in close collaboration with the relevant agencies on all four instruments. The following opportunities jointly cover all four Action Areas discussed in Function 1, Participating in the development and implementation of climate and related strategies.
Early engagement enables MoFs to embed fiscal, macroeconomic, and investment considerations from the outset. They can shapecredible, implementable plans rather than merely validating or financing plans that have already been designed without them. MoFscan use their center-of-government position and convening power to improve coherence across LT-LEDS, NDCs, NBSAPs, and NAPs.
Modeling and developing scenarios can help assess the impacts of climate change as well as cost mitigation and adaptation policies.This includes transition-enabling measures such as reskilling, active labor-market policies, social protection, enterprise preparedness,and regional diversification where relevant.
This includes:
- Integrating climate action into national and sectoral development plans to improve alignment with wider economic priorities and maximize their impact (OECD, 2025b; see Function 1, Reforming economic strategy through shaping national development and climate plans).
- Translating climate planning instruments into actionable, credible climate finance and investment strategies, identifying domestic resources, sequencing public investments, mobilizing private capital, and improving access to international climate finance. This includes helping prepare project pipelines and strengthening the enabling environment for climate investments (see Function 1, Reforming economic strategy through shaping national development and climate plans).
- Translating commitments into budgets and medium-term expenditure frameworks, as well as other key MoFs levers such as fiscal policies, public procurement, and debt management (See Function 2, Reforming fiscal policies and Function 3, Financing the transition through reforming the financial system and instruments).
- Developing financing strategies and mobilizing funding (see Function 3, Financing the transition through reforming the financial system and instruments).
Strengthen monitoring and accountability, including by improving tracking of climate and biodiversity finance and expenditures to understand whether strategies are successful in mobilizing finance and feeding insights into successive revisions.
Focus on being included in relevant processes and increasing engagement over time as expertise and experience deepen. MoFs with limited staff and data have typically begun with the analytical entry points closest to existing budget and planning processes and widened engagement as capacity grows.
Real-world examples
A range of case studies highlight the successful engagement of MoFs in different stages of the NBSAPs process. Most are recent and document institutional design and initial implementation; evidence on results at scale is still emerging.
Chile
The MoF established a Natural Capital Committee in 2023 as a whole-of-government advisory body to the President, which also included the Ministries of Environment and Economy, to embed natural capital into national economic strategy. The MoF subsequently launched the Taxonomy of Environmentally Sustainable Economic Activities, providing investors with standardized criteria for identifying environmentally sustainable activities.
A Taxonomy Permanent Technical Expertise Committee, yet to be established, will develop technical screening criteria for biodiversity conservation and restoration, with financial regulators anticipated to publish an implementation roadmap and initiate pilot projects. The sequencing (institutional mandate, measurement framework, market signal) offers a replicable model for MoFs seeking to build biodiversity into economic strategy rather than treating it as a sectoral afterthought(Krushelnytska et al. 2023).
Mexico
The MoF participated in the Kunming-Montreal GBF Fund negotiations and is working with line ministries on updating the National Biodiversity Strategy to incorporate Kunming-Montreal GBF targets. The MoF published its Sustainable Taxonomy in March 2023, covering six environmental objectives including biodiversity conservation and ecosystem restoration, alongside five social objectives. It subsequently integrated it into Mexico’s Sovereign Sustainable Finance Reference Framework, making biodiversity conservation among the eligible categories for sovereign financing.
By making borrowing eligibility contingent on biodiversity classification, the MoF converted a taxonomic instrument into a fiscal signal with direct consequences for how Mexico accesses international capital markets. Mexico’s MoF estimates that 13.6tnMexican pesos (approximately US$800bn) will need to be mobilized between 2023 and 2030, making the framework’s role in unlocking Environmental, Social, and Governance-labeled international financing operationally significant (CFMCA, 2025b).
The Philippines
The MoF anchored NBSAP implementation directly in budget architecture through a multilateral development bank operation. As executing agency, it leads delivery by placing fiscal authority at the center rather than an environmental mandate alone.Strengthened planning, budgeting, and investment in natural capital are core objectives that support the Philippine Biodiversity Strategy and Action Plan 2015-2028. It responds to a stark, quantified gap: implementing the Philippine Biodiversity Strategy and Action Plan is estimated to require around US$530m annually against current biodiversity spending of roughly US$100m (a financing gap of over 80%), which the Department of Finance-led reforms are designed to begin closing. The Philippines illustrates how MoF-led, multilateral development bank-supported policy reform can embed NBSAP commitments within national budget and public investment systems (ADB, 2025).
Brazil
By actively mobilizing the private sector, including financial institutions and businesses, Brazil supports its NBSAP and aligns it with the Kunming-Montreal GBF. Published in late 2025, the updated NBSAP emphasizes the need to strengthen private sector involvement to develop financial mechanisms for biodiversity. This approach aims to engage the corporate sector in implementing actions that contribute to nature-based solutions and sustainable development. The NBSAP allocates governance and coordination responsibilities almost entirely on the Ministry of Environment and Climate Change, with the Action Plan’s implementation depending on the leadership and collaboration of 50 Ministries and other agencies. The MoF is responsible fordefining mechanisms to finance actions and coordinating partnerships and sources of funding.
Uganda
This country’s experience shows that Natural Capital Accounting can be developed and applied effectively in a low-income, climate-vulnerable country when it is anchored in national priorities and implemented in a phased manner. By starting with a limited number of high-impact accounts and gradually expanding coverage, Uganda has been able to generate policy-relevant insights despite capacity and data constraints. The results have revealed both the scale of natural capital’s contribution to the economy and the risks posed by its depletion, strengthening the case for integrating environmental considerations into fiscal and economic decision-making (see full case study, forthcoming).
UNEP FI (Jessica Smith, Johan Lopez, Katy Baker), WWF (Karen Ellis), FfB Foundation (Jasmine Khatri; Natacha Boric, Emine Isciel, Sonya Likhtman), ADB (Bethany Cosgrave), AFD (Julien Calas).
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Department of Forestry, Fisheries and the Environment [DFFE] (2021) Biodiversity management agreements and corresponding tax incentives concluded with landowners for the implementation of the biodiversity management plans for the southern black rhinoceros and African lion in Limpopo. Pretoria: Department of Forestry, Fisheries and the Environment.
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