In June 2024, the European Parliament passed one of its most ambitious nature restoration laws: Regulation (EU) 2024/1991, widely known as the Nature Restoration Act1. This regulation is part of the European Green Deal and stands as a crucial tool to advance climate neutrality, biodiversity preservation, and ecosystem resilience. With this law, the European Union reinforces its commitment to restoring degraded ecosystems.
At Hub-Terra, we have closely followed the development of this law, tailoring our services to help clients meet new environmental requirements and leverage the opportunities presented by this regulation. In 2023, in our publication on the European Council’s progress in this area, we discussed key aspects of this regulation within the framework of the complex negotiations that ultimately led to its approval. Today, Regulation (EU) 2024/1991 stands as a legal reality for the conservation and restoration of European ecosystems. This article dives deeper into the key points of the new regulation, highlighting its main obligations and potential challenges.
The regulation is structured into six chapters covering topics ranging from restoration objectives to monitoring mechanisms, national plans, and the delegated powers granted to the European Commission.
Restoration Objectives of Regulation (EU) 2024/1991
Regulations are binding legislative acts that apply in full across all EU Member States, as established by Article 288 of the Treaty on the Functioning of the EU (TFEU). Unlike directives, which allow countries flexibility in implementing goals, regulations impose direct obligations and do not require transposition into national law. Regulation (EU) 2024/1991 exemplifies this rigidity by establishing a mandatory framework for ecosystem restoration across the EU. However, it includes some room for adaptation, allowing Member States to adjust their national, regional, and local strategies, providing a degree of flexibility in its implementation, as discussed below.
This balance between regulatory structure and flexibility may be key to ensuring effective implementation across diverse ecological and socioeconomic territories, while also opening an interesting debate on how this will unfold across the EU.
The Nature Restoration Law recognizes the interconnection between biodiversity and climate action. Biodiversity restoration is not only an environmental goal but also a key strategy for climate change mitigation. Healthy ecosystems such as forests, peatlands, and wetlands act as natural carbon sinks, helping to reduce greenhouse gas emissions. By restoring these ecosystems, the regulation strengthens the EU’s capacity to meet its climate neutrality goals by 2050.
Chapter II of Regulation (EU) 2024/1991 sets specific targets for restoring degraded ecosystems, including terrestrial, marine, agricultural, forest, and urban ecosystems. These targets follow a progressive approach, with milestones set for 2030, 2040, and 2050. As Member States advance toward restoration, they must implement a range of measures to enhance biodiversity and the carbon-absorbing capacity of ecosystems, thereby contributing to both climate and conservation goals.
Article 4 mandates the restoration of terrestrial, coastal, and freshwater habitats (detailed in Annex I), with targets for 30% in good condition by 2030, 60% by 2040, and 90% by 2050, prioritizing areas protected under the Natura 2000 network. Additional measures focus on restoring areas where habitats have disappeared to reach favorable baseline conditions. Moreover, the regulation mandates that restoration actions must improve ecological connectivity by promoting interconnection between habitats and prohibit any significant deterioration of restored areas, except in exceptional circumstances, such as projects of overriding public interest or climate change. This article presents a significant challenge: flexibility to exclude habitats covering more than 3% of European territory from the targets introduces some ambiguity, as it may be difficult to justify these exclusions without compromising biogeographical conservation. Moreover, achieving 90% restoration by 2050, given limited resources and climate pressures, poses a notable difficulty, especially in priority areas like Natura 2000 zones.
Article 5, which regulates the restoration of marine ecosystems, also sets ambitious goals to restore 30% of marine habitats by 2030, 60% by 2040, and 90% by 2050, focusing on specific marine habitat groups detailed in Annex II. As with terrestrial ecosystems, this article underscores synergy with other regulations, including the Habitats Directive (92/43/EEC)2 and the Birds Directive (2009/147/EC)3, emphasizing the Member States’ obligations to restore protected species habitats to reach sufficient quality and quantity (Annex III for marine habitats).
As with terrestrial ecosystems, measures are required to improve the ecological connectivity of marine habitats, ensuring a favorable conservation status. Justified exceptions in cases of natural disasters or projects of overriding public interest are also considered for the marine environment. While marine ecosystem restoration is essential for ocean health, the option for Member States to justify lower percentages through national plans introduces a level of flexibility that could be seen as a reduction of commitments. Furthermore, restoring marine habitats, such as seabeds, is a technically complex task that requires significant investment and the development of specific technologies, which will undoubtedly challenge effective implementation.
Articles 6 and 7 address exemptions for renewable energy and national defense projects, considering them to be of “overriding public interest.” This permits such projects to be exempted from the no-deterioration obligations, provided that proper environmental assessments are conducted. However, this provision raises controversy: exempting alternative solutions that may be less harmful could create conflicts between the development of energy infrastructure and habitat restoration, negatively impacting ecosystems. Additionally, the concept of “overriding public interest” is ambiguous and open to subjective interpretation, which could lead to prioritizing energy or defense projects over environmental commitments. Despite this, the text allows Member States to restrict or limit exemptions related to renewable energy under conditions justified in their integrated national energy and climate plans (Regulation (EU) 2018/1999)4.
An innovative aspect of the regulation is its focus on urban ecosystems, which cover 22% of the Union’s surface area (Article 8). The regulation sets a goal to prevent net loss of green spaces and tree cover in urban areas by 2030 to ensure environmental sustainability in cities. From 2031 onwards, Member States must promote a progressive increase in urban green spaces and tree cover, ensuring that these improvements are integrated into buildings and infrastructure and measured every six years. The main challenge here lies in the lack of details on how these initiatives will be funded, especially in a context of accelerated urban growth where the integration of green spaces may conflict with development pressures.
The restoration of natural river connectivity and floodplain functions, covered in Article 9, is an important goal for river ecosystem recovery. However, removing artificial barriers that impede river connectivity presents complex problems, as many of these barriers serve socio-economic purposes such as flood protection or hydroelectric power generation. Deciding which barriers to remove and how to manage adjacent floodplains will be another major challenge, likely to be both costly and potentially contentious.
Article 10 focuses on restoring pollinator populations, an essential action for biodiversity and agriculture. Member States must implement effective measures to halt their decline by 2030, and from that point onwards, ensure a growth trend until satisfactory levels are reached. However, monitoring these populations faces a temporary limitation, as the Commission will not adopt a standardized scientific method for monitoring until 2025, leaving a gap in Member States’ capacity to implement effective monitoring measures before the 2030 deadline.
For agricultural ecosystems (Article 11), particular emphasis is placed on the rewetting of peatlands, which significantly contributes to greenhouse gas emission reductions. States are required to restore a progressive percentage of agricultural land (30% by 2030, 40% by 2040, 50% by 2050) and improve key biodiversity indicators, such as butterfly diversity and organic carbon stocks in soils (Annex IV). The regulation also establishes an index summarizing population trends of common birds in agricultural lands to assess biodiversity in Europe’s agricultural ecosystems (Annex V). This composite index measures the relative abundance variation rate of farmland birds in each Member State, with a reference baseline year and trend values over several years. In Spain, the index is calculated using a set of 24 species, including Alauda arvensis and Passer domesticus.
On the other hand, forest ecosystems also have specific restoration targets (Article 12). States must improve at least six of the seven key forest biodiversity indicators defined in Annex VI, such as dead wood volume, forest connectivity, carbon stocks, and tree species diversity. Furthermore, the regulation promotes planting an additional 3 billion trees across the European Union by 2030, contributing to restoration and climate resilience goals.
Nonetheless, these provisions present both opportunities and challenges. In the case of agricultural soils, peatland rewetting is voluntary for private landowners, which may limit the impact of these measures unless suitable incentives are offered. The biodiversity indicators also raise questions, such as reliance on previous studies and external guidelines, like those from the IPCC, regarding method updates and long-term data comparability. Additionally, the implementation of these indicators may vary across Member States, creating difficulties in the consistent evaluation of agricultural biodiversity. Similarly, measuring farmland biodiversity through the common bird index faces similar challenges, as species selection may not represent the local reality in some countries. This could affect monitoring effectiveness in Member States facing greater structural challenges in maintaining farmland bird populations.
Regarding forest restoration, improving indicators such as dead wood volume or forest connectivity is a technical task that requires long-term monitoring, potentially complicating implementation and measurement, in addition to the constant risks posed by forest fires.
Finally, Article 13 introduces an ambitious goal to plant an additional 3 billion trees across the EU by 2030. Planting must adhere to ecological principles, prioritizing native species, in addition to species diversity and age structure. Although symbolic and well-intentioned, this commitment raises questions about long-term funding and coordination among Member States to ensure trees are planted in suitable areas. Moreover, while the regulation prioritizes the use of native species, it permits non-native species under certain conditions, which could open the door to unsustainable practices if not carefully monitored.
National Restoration Plans
Chapter III of Regulation (EU) 2024/1991 sets out the responsibilities and process for Member States to develop their National Restoration Plans. These plans must be submitted by September 1, 2026 (Art. 16) and will be evaluated by the European Commission within six months. This evaluation process includes an analysis to ensure the plans meet the regulation’s objectives, such as restoring 25,000 km of rivers and planting an additional 3 billion trees by 2030. The Commission may provide feedback on the plans, and States must respond to this feedback by making necessary adjustments (Art. 17). This process may lead to delays and tensions in implementation, as the Commission’s feedback may require substantial revisions to initial plans, thereby slowing execution.
Hub-Terra collaborates with public entities at the state, regional, and local levels in developing strategic plans, providing technical guidance to ensure that national restoration plans comply with the regulation’s requirements. With expertise in geospatial analysis and conservation planning, we offer comprehensive support in identifying priority areas and integrating biodiversity goals across key sectors such as agriculture and forestry. This approach enables administrations to effectively meet regulatory obligations while aligning with their regional contexts.
To develop these plans, states must conduct thorough studies and detailed assessments of the current state of their habitats and species (Art. 14). This requires considerable technical effort, as the process demands the use of updated scientific data, precise mapping, and monitoring methodologies, which may be challenging in ecosystems with limited data or where further research is needed to understand their current condition. The plan’s content must be comprehensive, including the quantification of areas to be restored, specific measures for each ecosystem, and biodiversity indicators to assess progress. Member States must also justify exceptions when it is not possible to reach a habitat’s reference area or when restoration is reduced (Art. 15). Throughout the process, Member States may develop additional methodologies to monitor critical areas, such as agricultural and forest lands, and implement voluntary restoration measures for degraded agricultural soils and peatlands, prioritizing ecological connectivity and landscape biodiversity. At Hub-Terra, we already integrate technologies such as remote sensing and spatial modeling into our projects, allowing us to provide science-based, accurate solutions for the restoration and monitoring of key ecosystems.
Regarding the definition of restoration measures, Annex VII of the regulation provides examples that Member States may include in their plans. These measures range from wetland restoration and invasive species removal to river renaturalization and reforestation with native species. Although these measures are optional, they offer clear guidance for States to tailor their restoration strategies to local conditions and priority ecosystems.
On the other hand, each Member State must coordinate its restoration actions with other EU policies, such as the Common Agricultural Policy (CAP) and the Common Fisheries Policy (CFP)5, ensuring that restoration measures align with other relevant regulations (such as the Habitats and Birds Directives). Additionally, Member States should promote cooperation with key stakeholders, such as farmers and fishers, through support schemes and encourage synergies between energy infrastructure and restoration projects. Integrating restoration measures with other EU policies, such as CAP and CFP, and coordinating with local and regional actors are crucial for successful restoration, though this will represent a significant technical and political challenge. Additionally, plans must include adequate funding mechanisms and strategies to incentivize the participation of agricultural and fisheries sectors in restoration, which adds another layer of complexity.
Marine ecosystem restoration is particularly complex, as it requires international coordination and joint measures with other Member States within the framework of the Common Fisheries Policy (Art. 18). This requirement may create difficulties, especially if agreements are not reached within the set deadlines. Should joint recommendations not be timely, the Commission may intervene, which could introduce tensions between Member States and the Commission, particularly concerning the management of their marine areas.
Finally, it is worth noting that national plans will be periodically reviewed. According to Article 19, revisions will take place in 2032, 2042, and every ten years thereafter. This review process is tied to the continuous monitoring of progress and compliance with intermediate objectives. When progress is insufficient, Member States will need to review and adjust their plans, which may involve implementing additional measures. This review process, while necessary, may be challenging to maintain effectively in the long term, particularly for countries with limited resources. Additionally, if the Commission determines that progress is insufficient, it may request an early review of the plan, which puts additional pressure on States to meet deadlines and objectives.
Monitoring, Evaluation, Delegated Powers, and Implementation
Monitoring and reporting are essential pillars for the implementation of Regulation (EU) 2024/1991, with Chapter IV specifically dedicated to this area (Arts. 20 and 21). These provisions require Member States to implement advanced monitoring systems, utilizing technologies such as Geographic Information Systems (GIS), remote sensing, and artificial intelligence, to assess progress in ecosystem restoration. This monitoring must be coordinated with other EU directives, including the Habitats Directive and the Marine Strategy Framework Directive67, and will be introduced in phases starting in 2024, with regular intervals for different key indicators. Additionally, progress reports must be public and accessible, in accordance with Directive 2007/2/EC8, promoting transparency and allowing for the adjustment of measures based on the results obtained.
Member States are required to submit their initial reports to the European Commission by June 30, 2028, and every three years thereafter. Beginning in 2031, reports will be submitted every six years and will include data on restored areas, deteriorated zones, removed river barriers, and advances in the restoration of agricultural, forest, marine, and urban ecosystems. The European Environment Agency (EEA) will assist the Commission in data evaluation, ensuring continuous and consistent oversight across the European Union.
In addition, Chapter V of the Regulation grants the European Commission the power to amend Annexes I to VII through delegated acts, allowing for adjustments based on scientific and technical advances. This includes the possibility of modifying habitat classifications, marine species, biodiversity indicators for agricultural, forest, and common bird ecosystems, as well as restoration measures detailed in the annexes. This flexibility is essential to ensure that restoration policies remain up-to-date and respond to emerging conservation needs.
However, the Commission’s authority to amend these annexes also presents challenges. Although flexibility is beneficial in adapting to scientific progress, it could introduce some uncertainty for Member States, which would need to continually adjust their national policies to align with new classifications and indicators. Additionally, the potential for frequent modifications could complicate the long-term implementation of restoration measures, especially in countries with limited administrative capacity.
Article 23 further establishes conditions for the exercise of delegated powers, granted for an initial five-year period and automatically renewable, ensuring continuity for the Commission in the regulation’s implementation. However, both the European Parliament and the Council may revoke these powers at any time, introducing potential instability in the regulation’s continuity. Additionally, the Commission must consult experts from Member States before adopting any delegated act and simultaneously notify the Parliament and the Council. Delegated acts will only enter into force if no objections are raised within a two-month period, which may be extended.
To achieve effective monitoring and facilitate result reporting, Hub-Terra has integrated state-of-the-art remote sensing technologies and GIS into its services. These tools allow our clients to conduct detailed ecosystem monitoring and prepare comprehensive reports that meet the regulatory standards. With a precise and adaptable methodology tailored to each ecosystem’s conditions, we support administrations in their monitoring tasks, ensuring continuous and real-time progress evaluation.
Challenges and Political Dimension
The adoption of Regulation (EU) 2024/1991 has sparked intense debate, particularly among agricultural sectors and some Member States. This regulation poses significant challenges but also offers opportunities to align conservation policies with socio-economic goals, especially through its connection with the Common Agricultural Policy (CAP). In this context, Regulation (EU) 2021/21159, a crucial part of the CAP, serves as a strategic ally by establishing guidelines for making agriculture more sustainable through integrating biodiversity and climate adaptation into national strategic plans. Annex IV of the Restoration Regulation complements this vision, using the CAP Indicator I.21 to assess how diverse landscape features on agricultural land impact biodiversity.
Regarding national restoration plans, their effective implementation will largely depend on each Member State’s ability to mobilize resources, coordinate actions across key sectors, and encourage active participation from local communities and stakeholders in land management. In countries with limited economic and technical resources, the administrative burden of developing detailed plans—encompassing everything from area quantification to justification for exceptions—may present a significant obstacle. The necessity of integrating restoration measures with other sectoral policies, such as the CAP and the Common Fisheries Policy (CFP), adds another layer of complexity and requires coordinated, data-driven planning. To help meet these regulatory demands, Hub-Terra provides guidance to public administrations in interpreting the regulation’s provisions and aligning with other sectoral policies like the CAP and CFP. Our team assists local and regional authorities in managing exceptions and adapting scientific methodologies to the specific characteristics of each region, optimizing restoration plan implementation and ensuring the integration of socio-economic and environmental interests.
As mentioned earlier, the regulation allows Member States to apply exceptions for certain habitats and restoration areas if their inclusion is deemed unfeasible or ineffective. Transparency in these decisions will be crucial, as a lack of clarity could lead to criticism or conflict if the European Commission finds the justifications insufficient. Furthermore, the Commission’s ongoing supervision and ability to demand additional reviews in cases of insufficient progress could be seen as excessive intervention by some sectors, especially where local realities differ from the EU’s expectations.
Another contentious issue is the variability in data availability and quality across Member States, which could create disparities in the implementation of restoration plans. Using accurate scientific methodologies and data is essential to meet the regulation’s objectives, yet in ecosystems where such data is limited or inconsistent, Member States may face significant challenges in designing and justifying their strategies.
The complexities of adopting Delegated Acts are also notable in this context. Chapter V of the regulation grants the European Commission the authority to modify Annexes I to VII via Delegated Acts to adjust habitat classifications and biodiversity indicators as scientific and technical knowledge progresses. While this flexibility ensures that policies remain up-to-date, it also introduces uncertainty, as Member States must continually adapt to potential changes in essential elements such as habitat categories and biodiversity metrics. However, this delegated authority is not without oversight: both the European Parliament and the Council have the power to revoke the Commission’s authority at any time, which may create discontinuities in implementation and potentially slow down decision-making.
The adoption process for Delegated Acts follows a committee procedure, supported by experts and regulated under Regulation (EU) 182/201110. While standard in EU legislation, this process adds bureaucracy. The involvement of multiple actors and the need for simultaneous consultation and notification can delay decisions, impacting the Commission’s ability to respond swiftly to environmental challenges. This risk is particularly relevant in the current context, where both the climate crisis and biodiversity loss call for agile and effective measures.
Finally, it is worth noting that the implementation challenges are not limited to exception management and adopting Delegated Acts. Member States must allocate considerable resources to ensure restored areas remain in good condition, which may prove particularly demanding in highly vulnerable ecosystems or rural areas with low management capacity. Additionally, the need to harmonize restoration measures with energy infrastructure and renewable energy policies may create conflicts of interest, especially if exemptions for projects of overriding public interest, such as renewable energy or national defense, interfere with ecological restoration goals.
In summary, implementing national restoration plans, while representing a significant step forward in restoring biodiversity and meeting the EU’s climate commitments, faces technical, political, and administrative challenges that require rigorous planning tailored to local realities. Only through effective collaboration between Member States and the Commission, and with the support of the involved communities and sectors, can these barriers be overcome to achieve the ambitious goals of this regulation.
Conclusion
Regulation (EU) 2024/1991 marks a new phase in EU environmental policy, making nature restoration a priority not only for biodiversity conservation but also as a critical tool for climate change mitigation. As national restoration plans are implemented and measures are adopted at the local level, it will be essential to stay abreast of scientific and technological advances to meet the ambitious targets set for 2050.
Ultimately, national restoration plans are a key tool for Member States to ensure the effective restoration of their ecosystems. However, as previous environmental regulations have shown, success will hinge on each country’s ability to mobilize the necessary resources, coordinate actions across sectors, and secure meaningful participation from local communities.
If you are interested in understanding how to adapt the restoration requirements to the specific conditions of your territory, Hub-Terra offers tailored solutions in ecosystem restoration, geospatial monitoring, and environmental management consultancy. Contact us to explore how we can support your organization in developing effective restoration strategies and implementing the requirements of Regulation (EU) 2024/1991.
- Regulation (EU) 2024/1991 of the European Parlament and of the Council of 24 June 2024 on nature restoration and amending Regulation (EU) 2022/869. OJ L 1991, of 29 July 2024: 1-93. ↩︎
- Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora. OJ L 206, of 22 June 1992: 7-50. ↩︎
- Directive 2009/147/EC of the European Parlament and of the Council of 30 November 2009 on the conservation of wild birds. OJ L 20, of 26 January 2010: 7-25 ↩︎
- Regulation (EU) 2018/1999 on the governance of the energy union and climate action. OJ L 328, of 21 December 2018: 1-77 ↩︎
- Regulation (EU) No 1380/2013 of the European Parlament and of the Council of 11 December 2013 on the Common Fisheries Policy, amending Council Regulations (EC) No 1954/2003 and (EC) No 1224/2009 and repealing Council Regulations (EC) No 2371/2002 and (EC) No 639/2004 and Council Decision 2004/585/EC. OJ L 354, of 28 December 2013: 22-61. ↩︎
- Directive 2008/56/EC — EU action in the field of marine environmental policy. OJ L 164, of 25 June 2008: 19-40. ↩︎
- Among other applicable regulations, the following can be cited: (1) Regulation (EU) 2018/841 of the European Parliament and of the Council of 30 May 2018 on the inclusion of greenhouse gas emissions and removals from land use, land-use change, and forestry in the climate and energy framework up to 2030, and amending Regulation (EU) No 525/2013 and Decision No 529/2013/EU. OJ L 156, 19 June 2018: 1-25. (2) Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy. OJ L 327, 22 December 2000: 1-73. ↩︎
- Directive 2007/2/EC establishing an infrastructure for spatial information in the European Community. OJ L 108, of 25 April 2007: 1-14. ↩︎
- Regulation (EU) 2021/2115 of the European Parlament and of the Council of 2 December 2021 establishing rules on support for strategic plans to be drawn up by Member States under the common agricultural policy (CAP Strategic Plans) and financed by the European Agricultural Guarantee Fund (EAGF) and by the European Agricultural Fund for Rural Development (EAFRD) and repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013. OJ L 435, of 6 December 2021: 1-186. ↩︎
- Regulation (EU) No 182/2011 of the European Parlament and of the Council of 16 February 2011 laying down the rules and general principles concerning mechanisms for control by Member States of the Commission’s exercise of implementing powers. OJ L 55, of 26 February 2011: 13-20 ↩︎
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