Agriculture Reform Implementation Oversight Board minutes: Interim ARIOB – Permanent Grassland (Enhanced): 4 December 2025

Attendees and apologies

Chair and Mr Fairlie - Minister for Agriculture and Connectivity

Items and actions

Chair welcomed the Minister for Agriculture and Connectivity and assembled members to an interim meeting of the ARIOB. The single-topic agenda meeting focused on Permanent Grassland, and the transition from current greening measures to future models, particularly the role of Permanent Grassland Requirements (PGRS) within the broader agricultural policy framework.

Officials opened by providing a summary of the work, and it was explained that what was being presented was a framework, outlining the proposed measures, but without any decisions on the weighting of those options, or indicative dates. Officials posed a series of open-ended questions to members, namely whether the work should continue to be developed, where the focus should be moving forward, and whether this approach is appropriate and reasonable.

Comments from members

• a member asked if greening is transitional, what is it a transition to? Difficult to judge if changes are useful unless we know the destination we are trying to get to
• the question of what proportion of those farms with arable/TGRS EFA that would also have PGRS EFA was posed
• it was suggested that as TGRS is rotational, it likely has more impact on climate and biodiversity aims than PGRS
• a member queried whether impact assessments for climate and biodiversity have been completed
• it was noted that there is a possibility that most of the new TGRS EFA entrants, will also be PGRS EFA entrants
• members raised concerns over potential lengthy timelines (i.e. the possibility of 3 years to introduce PGRS options)
• a suggestion was put forward that 10% space for nature is achievable if appropriate weightings are given to RGR / woodlands / gorse (and other ineligible features) alongside the EFA options for delivery, which could then account for some of the land cover that EFA does not account for
• it was noted that some people can already largely comply depending on locality and prevalence of hedges
• a comment followed the above, namely that it is important to think about the management and quality of those habitats not just their extent and presence (not all hedges are alike in quality, for example)
• similarly, it was noted that not all PGRS is equalpart of the challenge – despite it often being talked about generically, it is known that some PGRS can deliver different outcomes than more heavily grazed PGRS
• a suggestion was put forward for using an AECS / Organic threshold for "equivalence"
• questions were raised on whether greening and PGRS can effectively support Tier 2 objectives
• a perceived possible imbalance was noted: arable farmers already comply, while beef and rough grazing farmers could face new burdens
• a member highlighted agent capacity and complexity of compliance
• a member highlighted potential conflicts with existing AECS contracts
• there was a proposal for phased implementation by farm size to reduce burden, starting with larger producers, and moving to smaller and medium-sized producers later on
• it was noted that measures will not work the same across the whole country, that some measures will work better in some regions than others, and within that, can any given measure work on a farm or croft? Measures need to be broad enough for all regions and farm systems (re: TGRS). Regional weightings may be the most useful, but hard for IT implementation
• there was a plea for clarity on how long transitional measures will remain in place
• a member highlighted the need to have the measures seen as fair and balanced, not privileging or penalising anyone
• weighting EFAs (Ecological Focus Areas) was discussed alongside the idea of incorporating features like hedges, margins, and wetlands to achieve meaningful benefits
• it was noted that current greening is seen as a short-term mechanism, but risks becoming the default model without clear communication of the future 4-tier system
• there was discussion around EFA percentages and flexibility through weighting
• a member put forward the idea of habitat mapping and connectivity (e.g., corridors between woodlands) suggested for better outcomes
• a member queried what proportion of those farms with arable/TGRS EFA would also have PGRS EFA

Comments from officials

• officials noted from the outset that this work will have greater clarity and focus with the finalisation of the Future Operating Model, due in early 2026
• tier 2 (Enhanced) must align with Tier 1 (Base) payments

• work is to be done on refining the options, and the resulting guidance, including the issue of differing dates for producers across the country. Only once this has been done can dates be confirmed
• officials noted that both agents and others within the industry see this as a big change, and therefore it was recognised that people need to be ‘brought along’ with the changes
• engagement with external bodies such as NatureScot is ongoing
• a balance needs to be struck between achieving policy outcomes, and getting correct weightings for possible options
• officials noted that whilst additional benefits could be realised from changes to permanent grassland, this is not to say that current practises have no benefits
• it was recognised that changes cannot become a ‘box-ticking’ exercise that results in payments without meaningful changes in practises, and any changes need to be fair, reasonable, and sustainable
• officials noted that EFA fallow is not proposed in PGRS
• responding to the final query from members, officials confirmed that between 37-40% of new PGRS farms will have arable EFA, depending on which one of the 15ha, 25ha, or 50ha thresholds are used