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Blog by Deputy CEO/Director of Policy Jonnie Hall.
It’s been no time since the close of the Single Application Form (SAF) window on 15 May, wrapping up applications for the key direct support schemes that underpin most farms and crofts across Scotland. For 2025, there were one or two new things we had to consider, such as the Whole Farm Plan requiring 90 percent of Basic Payment Scheme applicants to meet two out of five needs.
But no sooner had the SAF window closed before another ‘Dear Customer’ letter hit doormats of every agricultural business in June.
That letter is important – don’t bin it, read it.
In essence, it set out changes to BPS requirements that will come into effect from 1 January 2026 – the most significant being the introduction of ‘Enhanced Greening’.
What is ‘Enhanced Greening’ and why is it important?
Greening isn’t new.
The reality is, all BPS claimants already have mandatory Greening requirements - and have done so since major Common Agricultural Policy (CAP) reforms were implemented in 2015. Delivered mainly through Ecological Focus Areas (EFAs), Greening is a top-up to BPS payments for undertaking management practices that help environmental outcomes.
The annual Greening budget, £142 million, augments the BPS budget of £282 million. The Scottish Government is now building on the current Greening approach to deliver the new Tier 2 (Enhanced Greening) direct support payments with more conditions attached for more farmers and crofters. The Enhanced Greening requirements mean that more farm businesses will have to actively manage EFAs on arable land in return for the 30 percent of their BPS payments that make up this Greening element.
What’s changing for 2026?
Some 3,700 farm businesses are currently required to undertake EFA requirements, and typically, they must manage five percent arable land using options such as fallow land, buffer strips, nitrogen-fixing crops, catch crops, green cover, agroforestry, and hedges.
The Scottish Government made it clear it intends to increase the number of agricultural businesses contributing to Greening and increase the area managed under EFAs. The initial step is the removal of the so-called, “75 percent exemption rules” – meaning that from 2026, anyone with more than 15 hectares of arable land, including temporary grass, must meet EFA requirements.
As a result, from next year, some 2,300 more businesses will have to manage EFAs for the first time. These will tend to be larger grass-based livestock units that also have more than 15 hectares of arable land – including temporary grass.
While the EFA percentage will remain at five percent for 2026, the Scottish Government’s intention is then for it to increase to seven percent for 2027.
In addition, the guidance for six of the existing seven EFA options has also been updated and four new EFA options have been added – including low input grassland, herb and legume rich pastures, unharvested crops, and alternative agro-forestry.
My instinct tells me that based on the 15 hectares or more of arable land threshold alone, the proportion of BPS claimants required to manage EFAs in 2026 will increase from about 20 percent to about 33 percent.
It follows that in 2026, some two-thirds of farms and crofts will receive their Enhanced Greening payments with no EFA requirements – largely made up by the fact that over a third of all those claiming BPS having no arable land.
While the move to Enhanced Greening has been trailed by the Scottish Government for some time, we must insist on a pragmatic and common-sense approach to be taken for those undertaking EFAs for the first time.
The changes for 2026 must not compromise either business viability or food production.
Over the past few years, BPS and Greening budgets have eroded in real terms, Therefore, all implications of adding further conditions to existing support measures must be fully accounted for – we cannot afford any unintended consequences.
That then introduces another dimension beyond any specific implications of Enhanced Greening for individual businesses and sectors. This a dimension that I’m concerned about.
It goes back to BPS and Greening budgets – the mainstays of direct support for Scottish agriculture and which are critical to the viability of all too many individual businesses.
What we’re calling for:
As we move into the new four-tier framework of future support, the Scottish Government must uphold existing commitments on direct support and its allocation.
First, as set out by the then First Minister at our AGM in 2024, at least 70 percent of total funding should be delivered as ‘direct’ support through the new Tiers 1 and 2.
Second, as set out by the First Minister at our AGM in 2025, at least 70 percent of that direct support should initially be allocated as Tier 1 base payments from 2026 onwards as the replacement for BPS, with the remaining 30 percent to go into Tier 2 under Enhanced Greening.
We also need both the current and the next Scottish Government to unequivocally commit to a real terms increase in the overall direct support budget.
As we move increasingly towards more conditions being attached to direct support payments a real terms increase on overall direct support funding, with a majority allocated to Tier 1 support to underpin the viability farms and crofts, is entirely justified.
For me, more strings attached to direct support whilst funding continues to decline in real terms would set Scottish agriculture on an extreme cliff edge. Ultimately, it could result in an abject failure to meet any aspirations to deliver on those stated and shared priorities around food, climate, nature and people.