Agriculture Reform Implementation Oversight Board minutes: 28 February 2025

Attendees and apologies

• Cabinet Secretary for Rural Affairs, Land Reform and Islands, Mairi Gougeon (Co-Chair)
• Martin Kennedy (Co-Chair)

Items and actions

Welcome: Agenda Item 1

Chair welcomed the Minister for Agriculture and Connectivity, her co-chair and members to the twelfth in-person meeting of the board, noted apologies and opened the floor to any comments ahead of the first substantive item.

Comments from members

• on the Whole Farm Plan (WFP) project, there was a plea to ensure that alternative audits for supply chain requirements would be considered to avoid unnecessary duplication of effort
• in addition, the wider use of data was raised. Officials noted a large set of complex questions associated with data, particularly data ownership, baselining/benchmarking and protecting the interests of farmers and crofters providing it
• government resources are such that this requires further thought, although it was pointed out that traceability of livestock has been part of regulatory data gathering from Government for a number of years
• officials said that data will be a key part of what technology is chosen, which processes are managed and what stakeholder engagement is undertaken. Ideally, there will be no repetition of data entry
• concerns regarding complexity and volume of data were raised and it was agreed that it is important to avoid creating something that is then open to a continual series of reviews or need to streamline
• data and the WFP go together, with a view to helping farmers and crofters make the right decisions
• government does not want to put a requirement on people which penalises them if they can’t undertake actions, rather than won’t
• collaboration with industry is critical and co-chair added that it needs to be industry-owned to form a Scottish picture, with MyHerdStats being a good start. Minister continued that on the ‘public money for public goods’ argument, the approach should be twofold – the ability for Scotland to sell a Scottish brand (national) and farmers and crofters to have their own negotiating position through data usage (individual)
• a member cautioned that the minutes from ARIOB meetings (and specifically from the November 2024 meeting of the Board) should reflect what the Board is trying to achieve, namely public money for public good
• delivering not only for farmers and crofters, but nature and climate
• A member urged all to be aware of farm assurance review published in January 2025
• from farmers’ perspectives, that review is about a fundamental reset of farm assurance and there are clear recommendations, including avoiding duplication or differentiation
• there was some discussion about the compatibility of retailer schemes, with a view offered that while they should be compatible, ultimately retailers often want a “point of difference”, which can lead to confusion
• farmers need alignment and the relationship between farmer and government has to take into account the supply chain
• if Government is paying for carbon audits, suppliers need to provide aggregated data for wider benefit. An action was taken to add the Data Strategy to the ARIOB’s workplan
• the proposed crofting roundtable was welcomed, with members reiterating the importance of crofters and small producers
• in relation to the Rural Affairs and Islands committee session (19 February 2025), one member voiced that statutory instruments are an important way of seeing policy detail, to ensure proper scrutiny and assessment. If stakeholder groups raise legitimate concerns, at any stage, these should be carefully considered
• in response, the Minister agreed, citing that the ARIOB should be airing issues in advance of such a session to avoid any misunderstandings or surprises
• both Minister and Chair reiterated their commitment to meaningful co-development, referencing the importance of working with the ARIOB and wider stakeholder organisations throughout the policy development process
• one member was disappointed with the 70/30 funding split (as announced by the First Minister at the NFU Scotland AGM) as well as the Enhanced Greening detail – signalling a slower pace than envisaged
• in response, Chair offered to meet with the member’s respective organisation but was clear that the split should be viewed as a starting point to provide the industry with some certainty, but it will likely move as the Agricultural Reform Programme progresses
• an update on Regions was requested, given it had been raised at a number of previous meetings
• one member opined that there had been no real progress on regionalisation since 2022, despite it being a fundamental building block of the framework. In response, officials replied that while this is a core component of the current system, there is evidence that the regions framework isn’t delivering against outcomes
• the ARIOB has a key role in shaping this, taking into account RPID views operationally
• the Just Transition Commission has raised concerns about the ARP, notably on the perceived disproportionate impact on small producers
• how are they being considered in policy development?
• on Enhanced Greening the removal of 2 of the 75% thresholds comes with risk
• in situations where 75% of total area is grassland, this could have a huge impact on some small units with limited options to introduce greening requirements because current options don’t fit all the regions
• would be useful to know the intervention logic on this given such potential for unintended consequences
• co-chair added that if there were a wider array of options, this wouldn’t be such an issue
• could there be scope for exemption of smaller producers when they are already delivering for biodiversity and local communities?
• in response, officials offered assurance that they are working with agents to create guidance to help people address EFA requirements, conscious of unintended consequences, with the aim being to minimise these and it is up to Government to make it work for individual farming businesses

Future operating model update: Agenda Item 2

Ahead of providing an update on progress, and in response to a request from members about what is meant by ‘North Star’ in the context of the model, officials replied that this should be seen as the high-level vision of where we’re trying to get to and what it will look like from both a farmer and (SG) staff point of view. The existing delivery model is primarily conditions-focused which links payments to specific eligibility or compliance criteria, so more geared towards the drivers of EU CAP without reflecting the drivers in the Vision for Agriculture. As we transition to a more dynamic and outcome-oriented approach we aim to explore alternative models that prioritise outcomes, encourage innovation, and align more closely with strategic goals.

A core set of principles will be developed to start fleshing out the system and one of those will be around simplification. Officials are creating a target operating model first with a view to transitioning from the current system.

The last meeting of the ARIOB looked at three potential future delivery options (conditions, measures and outcomes based). Since then, officials have used ARIOB feedback to build range of options with simplicity in mind, addressing monitoring challenges and ensuring smallholders are included.

Officials offered a plan and timeline for context:

• To carry out the work required to determine the best fit Delivery Model that will deliver Scottish agriculture policy, align with The Agriculture and Rural Communities (Scotland) Act 2024 and achieve the 5 strategic outcomes: high quality food production; thriving businesses; climate change; Nature Restoration; and Just Transition. Timeline: Spring 2026;
• To develop a new, affordable Target Operating Model for the organisation, that will enable the realisation of the chosen Delivery Model, and the key aims of the 4-tier framework: provision of income support; payments for environmental outcomes; and professional development support and advice. Timeline: Summer 2026;
• To identify and design the requisite organisational capabilities needed to underpin the Operating Model and services within. Timeline: Autumn 2026.

The options were reviewed and scored accordingly, being reduced to six: Conditions; Measures; Outcomes; Conditions and measures; Conditions and outcomes; Hybrid of all three.

In terms of other viewpoints, RESAS have advocated for 4 and 6, whilst the AAP favour 6. It was agreed that models need to be fully understood from the farmer’s perspective. What matters to them and what challenges are there?

All models need to enable an entry-level payment for agricultural activity while meeting minimum standards (delivering for nature and climate). In addition, it will require some form of targeted elective support which includes the offer of continuing professional development and advice. Officials then offered a brief overview of each of the models.

The Code of Practice has the potential to grow into a blueprint – particular to geography, size and types of land with a payments structure to suit. Ideally, in that scenario you might not have to apply for funding, it will be automated, including verification. Government focus will be on the changing way land is managed, but which includes a balance of regulation, Just Transition and income support.

Comments from members

• what we pay farmers and crofters is only one element of agricultural reform – the right balance has to be struck between payments and reform
• additional aspects such as supply chain, co-operation, knowledge sharing and innovation are arguably more important than this. These are the elements, it was argued, that will make more of a difference
• there was criticism around some of the language employed around user mindsets and personas as presented, particularly hobby farmers, which members agreed are often excellent businesses and are the very people to lead change
• additionally, each farm can have many different people, with different mindsets and approaches and such summaries don’t take into account family dynamics, labour issues and succession
• officials agreed, noting that it is very difficult to represent the sector fully in a summarised format and personas can be divisive. Officials will look to amend, but ultimately these are used to bring models to life and generate such debate
• another member was disappointed at the lack of progress since 2021 – what’s new and different since then other than the changes to the Scottish Suckler Beef Support Scheme (SSBSS)? This isn’t ambitious enough
• officials replied that this was about providing a basis of support and that there will be opportunities within Tiers 3 and 4 for encouraging innovation
• some of the outcomes will take years to bear fruit and may be thwarted by practical events. Co-chair added that the industry would be concerned about a heavy focus on outcomes when actions being taken can be wiped out by a weather event, for example
• the focus should be on measures. Officials agreed that what is required will be very clearly laid out – if you do what is being asked, you will receive support
• the possibility of remote verification in the future was widely welcomed
• however, compared to England where there are large margins and cover crops, we are not doing enough in Scotland to make a difference right now and that is putting our farmers and crofters at a disadvantage
• people are often not engaging because they are frustrated - the growing disconnect needs to be addressed
• warning was made that Government is in danger of being overly prescriptive
• the final model needs to be flexible and sustainable and that comes down to the degree of detail we’re asking from farms
• all farmers and crofters will carefully consider the financial impact on their business. Farmers and crofters need to feel empowered to work out how they achieve outcomes without the options being too narrow – make them feel part of the conversation
• this comes back to the data issue, where robust data will be required to make informed business decisions
• in terms of the next generation, this needs to be long-term to see the benefit (rather than year on year) and incorporate user feedback. Younger people and those new to the industry need to understand business impacts
• the outcomes piece is worth further discussion as it leads to the Climate Change Plan and Natural Environmental Bill
• technology will help monitor outcomes in the future. Challenges around outcomes – weather, climate change, scale/geography. Can do research in these areas
• agents were discussed, with an example given about the differing costs of carbon audit assistance – especially where you have a small amount of land
• the artificial inflation of prices through public money should be avoided. Intended funding recipients need to be protected and while consultants have a role to play, they are not the main players and farmers and crofters need to be given the tools to conduct carbon audits by themselves
• in response to how people interact with demands that sit outwith Government, officials suggested an online meeting on design principles which will provide examples of Target Operating Models that are different to what we currently have and can be strengthened through co-development, although compromise will be required
• an action was taken for the Secretariat to arrange

High Nature Value (HNV) working group: Agenda Item 3

A representative of the working group provided a short overview of the work they’ve done since the agreement to form at the last meeting of the ARIOB (November 2024). The group has met twice to agree on a way forward and reminded members that this is not about a payments scheme, rather how farming and crofting can further support nature.

Their proposal is to build on previous work through a sample of what farmers and crofters are already doing and the group are keen to receive consent from the wider Board to progress with the “ground truth” work.

A short history of HNV in both a European and Scottish context was provided to the Board, namely the fact that semi-natural habitats are important part of farming systems and for biodiversity. HNV is focused on high conservation habitats and it is the farming practices that keep them in good HNV condition. HNV farming is many and varied but with low intensity of farming and inputs and largely livestock based.

The Group would like to pilot reasonably quickly, simply and robustly to work out indicators and test with a range of farms and crofts, noting budgetary/resource limitations.

Comments from members

• members welcomed this work, noting its complexity with one mentioning, in reference to the associated paper, that stocking density and stocking rate are different, highlighting the importance of getting the terminology correct
• are there other metric certification standards beyond RSPB assessment?
• in future, mapping of HNV farms could train AI algorithms and LIDAR to pick out HNV across the whole of Scotland – automation to better achieve outcomes
• with concerns about livestock activity, what are the implications for HNV outcomes if significant changes in type and balance of livestock have taken place since 2013? This is an important component given discussions on livestock
• just because the area might be considered as demonstrating nature friendly farming, it doesn’t mean it’s in HNV condition
• the aim should be to collate good evidence of its condition in terms of nature
• how much of the diet of animals on the land is delivered by landholding in terms of pasture?
• in crofting context, anomalies could see businesses fall through gaps, but if careful about approach it can be captured
• one crofter on a common grazing can really skew the picture
• we need to establish the actual businesses that need to be supported by this work
• we must also map low-carbon farms as ineligible features missing. Ground truthing should take place across all counterfactuals – without that you don’t know what the alternative nature solutions are
• challenge in this is the activity element – what is defined as agricultural activity? Work can be done quickly to get to the point of having a useful metric for monitoring
• there was a warning that while there are farms that are doing good work, this is not about bringing those in who aren’t HNV and should not be an exercise to expand it
• however, future consideration must be given to how you support those farms

In terms of next steps, the representative of the group spoke of restricting the scope of the next phase – can we come up with parameters that provide a useful measure as to whether a farm is delivering for nature? What comes after is helping farms that are struggling so they can help deliver for nature. Can we define it in a way that makes sense for everyone?

In terms of timescales, the pilot may take up to a year. Chair noted broad agreement amongst the Board to the proposal and looked forward to a further update later in the year.

ARP Monitoring and Evaluation: Agenda Item 4

Officials gave an update from the previous presentation to the Board in 2024 on the ongoing Monitoring and Evaluation work as part of the ARP as the Programme aims to achieve the aforementioned five key outcomes as well as a number of sub-outcomes. This will be approached through an evaluation strategy utilising what’s known as “nested frameworks” to bring together different strands of evaluation relating to individual projects and interventions.

The team involved has undertaken stakeholder workshops at the beginning of 2025 which provided a helpful steer on where they need to refine the outcomes framework and early draft of the theory of change. Due to the complexity and multiplicity of projects within the Programme, a theory-based approach will ensure Government understands the logic and theory behind each intervention. In addition, Process, Impact and Value for Money evaluations will help determine whether individual interventions are working, and whether the combined effect of the projects is delivering the real world impacts. Officials confirmed that external evaluation is also important for fair assessments to avoid Government marking its own homework.

In opening the floor to members, the team asked where should our focus lie for evaluation questions? They also provided some focus areas to stimulate discussion.

Comments from members

• just Transition has a definition and where there are existing definitions, they should be used for consistency
• members were clear that while many businesses rely on subsidies, the collective aim needs to be an industry not simply “getting by”, but being profitable enough to reinvest in their businesses and secure succession in the longer term
• officials replied that the feedback from their workshop events was similar, that the role of farm payment importance varied across different types of businesses. Profitability will be included within evaluation questions in this area
• how practical is it to expect agriculture to reach Net Zero by itself? We are not on track for 2030, that needs to be addressed
• contributions of agri business to the wider economy needs to be reflected – upstream/downstream economics and the social fabric of communities
• some members felt that the evaluation questions/indicators needed to be framed better to be understood by farmers and crofters given areas of crossover
• officials agreed that a number of indicators interact across more than one of the outcomes and will reflect on the feedback received
• co-chair would like to see the terminology of ‘subsidies’ change to ‘support’ as not all support comes in the form of subsidies
• the EU approach to Monitoring and Evaluation can be helpful, rather than starting everything from scratch
• officials responded that a report is due to be published shortly on the approaches taken by the other administrations in the UK and EU and this will be reviewed
• Integrated land use is important for urban flood defence
• officials confirmed this is being considered when developing indicators, with one relating to extreme weather events, conscious of the nuance of flooding, as the member mentioned
• in response to a question around the flexibility of theory-based evaluation, it can account for unexpected events that happen over a longer period
• the monitoring framework reports over 5 years so can inform the bigger conversation

AAP response Integrated Pest Management and Impact of Pesticides and Veterinary Medicines on the environment.

Ahead of the substantive discussion, the AAP representative informed members that their feedback has been taken on board with regard to references within AAP papers, as well as clearer recommendations and consensus (where reached).

Pesticides and Veterinary Medicines in the environment, and Integrated Pest Management (IPM): Agenda Item 5

Integrated Pest Management

The AAP provided an update on strategies to increase the future uptake of IPM options, ways to utilise available data to demonstrate and maximise the benefits of IPM adoption, and methods to track the potential impact of greening measures on IPM uptake.

IPM is a sustainable approach to managing pests, weeds and diseases but adoption varies across Scotland, clearly related to factors such as farm type, size, region, soil types and crop. Regional differences reveal higher uptake in the east of Scotland, with farms primarily dedicated to arable production achieving higher IPM scores.

The Scottish IPM Assessment Plan is a tool designed to help farmers and growers in Scotland evaluate and improve their use of IPM practices, and is a recommended tool within Whole Farm Plan guidance. As of September 2023, over 2250 IPM plans have been completed but in terms of maximising adoption and impact, the AAP recommends.

Educating and training growers, engaging agricultural advisors, enhancing collaboration, promoting the environmental and economic benefits, integrating IPM into crop certification programmes, regularly reviewing progress and ensuring transparency in data collection and usage. This final point may also improve the benefits of overall IPM data collection for wider usage.

Comments from members

• a comment was made that it isn’t always true to say that reduced tillage increases reliance on grass weed herbicides
• there has been a huge reduction in pesticide use on farm, although there was an opposing view that while antibiotic usage has reduced, this is not as true of pesticides
• on transparency of data collection, one member mentioned arable farmers being contacted by the SASA (Science & Advice for Scottish Agriculture) for pesticide records – this needs to be linked to outcomes
• there was agreement that this needs to be joined up and that the pesticide survey sample size and detail could be improved upon, including public health considerations. What other factors within the business are barriers to uptake?
• the SAF (Single Application Form) will provide information on who has an IPM in place, officials should look at what else can be captured through that mechanism
• there was agreement that this would need to be done as simply as possible so as not expand the SAF into something unwieldy
• Scottish Agronomy are the experts in this area and should be involved

Pesticides and Veterinary Medicines in the environment

Pesticides and Veterinary medicines play an essential role in agriculture and animal health, but they can also have significant environmental impacts affecting soil, water, air, biodiversity. In addition, overuse of antibiotics in livestock farming can contribute to resistant bacteria affecting animals and humans. Climate change may amplify risks associated with use of pesticides and veterinary medicines. Mitigation strategies include prioritising biosecurity measures, Targeted Selective Treatment (TST) in livestock, and IPM in crops. The AAP also recommend improving national-level data collection as well as better knowledge-sharing across the sector.

Comments from members

• is there any data on how the dial has moved over the years? Pesticides and vet meds are now very expensive, in addition to accuracy improvements
• the AAP said that this is not an area with data behind it, although the aforementioned pesticides survey will contain some useful information
• one member hoped that such data collection could lead to a benchmarking where there is a clear incentive to reduce given the costs involved
• one member reflected that the paper wasn’t clear that this is a problem and the AAP representative agreed it should have been emphasised
• a member said that there is a real issue in terms of ecological impacts from pesticides and would have been good to see a mention of fungicides
• TST of animals is the gold standard, but this often doesn’t recognise that preventative measures may also have been taken
• there is anecdotal evidence that backs up the merits of different grazing strategies and Quality Meat Scotland (QMS) has recently completed an antimicrobial trial
• there was some discussion on gene editing, with a need to understand the potential costs and with one member hoping for a shift to precision breeding to ensure wider buy-in
• a suggestion was made that integrating livestock to arable practices and subsequent reduction in chemicals use is not researched and captured sufficiently
• also different grazing strategies and different plants can have positive impacts on animal health

Chair thanked members for their contributions and looked forward to the Board’s next meeting on 30 May 2025.