The Short Answer
If you own land in NSW under a Biodiversity Conservation Trust agreement, at some point you have probably asked whether you are actually required to do anything about feral pigs, deer, foxes, or wild dogs on the site.
The answer is that it depends on which agreement you hold and what your management plan says, and the gap between those two situations is much wider than most landholders expect. On one side sits a funded agreement, where the management actions are compulsory, the annual report is due within 14 days, and your payment depends on both. On the other sits an unfunded agreement or a wildlife refuge, where active management is recommended rather than required, in the Trust’s own words.
Nobody publishes that distinction plainly, which is why so many agreement holders are either doing more than they need to or, more often, quietly missing something that is genuinely required of them. This guide sets it out against the operative agreement wording, so you can work out which side of the line your site sits on.
One thing worth saying at the top: this is general information about how these agreements are structured, not advice about your particular agreement. Your management plan and your site values report are the documents that decide your position, and if you cannot find them, the Trust can.
What “Pest” Means in Your Agreement
Start with the definition, because it is broader than people assume.
The Biodiversity Conservation Trust’s funded conservation agreement template defines a Pest as any member of the animal kingdom that is specified as a pest in the site’s values report, or declared under a pest control order. It defines Pest Control as the control of a pest using methods recommended by the Trust or another relevant NSW Government authority, which minimise damage to non-target native animals.
Two things follow from that.
First, the door is wide open on species. Feral pigs, deer, foxes, wild dogs, rabbits, goats and cats can all fall inside that definition where your site’s values report names them. This is not a narrow, technical category.
Second, the method is constrained in a way it is not on ordinary farmland. Control has to minimise damage to non-target native animals, which is the whole point on a site holding protected biodiversity values. That shapes what is appropriate, and it is the reason a control programme on conservation land should look different from one designed purely around production loss.
Funded Versus Unfunded: The Distinction That Decides Everything
Here is the comparison the government publishes across several separate pages and nobody assembles in one place.
| Funded agreement (biodiversity stewardship or funded conservation agreement) | Unfunded conservation agreement | Wildlife refuge | |
|---|---|---|---|
| Annual management payment | Yes, to carry out agreed management actions | No ongoing management payment | No ongoing management payment |
| Management actions | Compulsory where listed in your plan | Not compelled | Not compelled |
| Active management of the conservation area | Required as set out in the plan | Recommended by the BCT, “but it is not a legal requirement” | Recommended, not a legal requirement |
| Annual report | Due within 14 days of the end of each reporting period | Not the same compelled cycle | Not the same compelled cycle |
| Annual site inspection by the BCT | Yes, on active agreements | No | No |
| Payment withheld for non-completion | Yes, the BCT may withhold, delay, or not pay | Not applicable | Not applicable |
| Duration | In-perpetuity, binding on all future owners | In-perpetuity, binding on all future owners | Stays in place if sold, but can be revoked by the landholder |
| Contractor invoices retained as evidence | Yes, for funded management actions | Not required | Not required |
| General biosecurity duty still applies | Yes | Yes | Yes |
If your agreement is in the first column and your plan lists feral animal control, this is a real, dated, money-attached obligation. If it is in the second or third, the Trust is asking rather than requiring, and your binding obligation about feral animals comes from the Biosecurity Act instead.
What a Funded Agreement Actually Compels
For landholders in that first column, it is worth being precise about the mechanics, because the compulsion is not vague.
The management actions are compulsory. Under the funded conservation agreement template, the owner’s reporting and monitoring obligations are compulsory. Under the biodiversity stewardship agreement template, the landowner must comply with the management plan, including carrying out all management actions, and that obligation continues in perpetuity. It survives even the cancellation of the biodiversity credits generated by the site.
The report is due within 14 days. The annual report must reach the Trust within 14 days of the end of each reporting period. That is a tight window for assembling a year of activity, and it is the single most common place agreement holders come unstuck.
The payment is conditional on both. The Trust manages active agreements by reviewing annual reports, undertaking annual site inspections and, where management actions have been completed, making the annual management payment to the landholder. Where a funded action has not been completed by the relevant date, or the annual report has not been received, the Trust is entitled to withhold, delay, or not make any payments.
The invoices are part of the evidence. Funded owners must retain receipts and invoices for capital works or the use of contractors in completing funded management actions. If you engage someone to do feral animal control as a funded action, their invoice is not just your accounting record. It is part of the evidence the agreement requires you to hold.
The plan is reviewed every five years. There is a formal review of the management plan on a five-yearly cycle, which is the natural point at which what your site actually requires can change.
What an Unfunded Agreement or Wildlife Refuge Asks of You
If you hold an unfunded conservation agreement or a wildlife refuge, the position is genuinely different, and it is worth knowing so you neither over-worry nor assume you are off the hook.
The Trust’s guidance on conservation partners agreements and wildlife refuges puts it directly: it recommends that you actively manage the conservation area you establish, “but it is not a legal requirement”. The commitments that do bind you are mostly about what you will not do, such as avoiding clearing, grazing and subdivision, and avoiding activities that threaten the native species the area protects.
The duration also differs in a way that matters if you are weighing options or reading a title. A conservation agreement is in-perpetuity and binding on all future owners. A wildlife refuge stays in place if the property is sold but can be revoked by the landholder, which is why the Trust describes it as the entry-level option for people who want to protect biodiversity without entering a permanent agreement.
What does not differ is the statutory duty. More on that below.
The Reporting Reality Check
It would be easy to read all of the above and assume the obligations are so clearly set out that everybody meets them. The audit evidence says otherwise.
The Audit Office of New South Wales reviewed the effectiveness of the Biodiversity Offsets Scheme in 2022 and found that in 2021, 58 per cent of landholders with biodiversity stewardship sites provided an annual report to the Trust. Which means more than four in ten did not, on a compulsory obligation with money attached.
The same audit found that over 90 per cent of the stewardship sites current at that time did not contain ecological monitoring requirements, largely because the Trust only began including them in agreements in March 2021, and that at January 2022 around 40 per cent of the 226 stewardship agreements then in existence had not sold enough credits to be in active management. Those figures are a few years old now and the Trust’s practice has moved on, so read them as a picture of that period rather than of today.
The point that survives is simpler. The reporting obligation is real, it is dated, it is tied to your payment, and a large minority of holders have historically not met it. If you are going to be caught out anywhere, that is the spot.
Your Biosecurity Duty Still Applies Underneath
Whatever your agreement says or does not say about feral animals, one obligation applies to your land regardless.
Under the Biosecurity Act 2015, every person who deals with a biosecurity risk, and who knows or ought reasonably to know about it, has a general biosecurity duty to prevent, eliminate, or minimise that risk so far as is reasonably practicable. Owning land carrying feral pigs, deer, foxes, or wild dogs puts you inside it. Our guide on what reasonable steps actually means works through how that applies in practice.
The agreement templates are explicit that this sits underneath. Both make the agreement subordinate to a pest control order under the Local Land Services Act 2013 and to biosecurity control orders and directions under the Biosecurity Act 2015, so you must comply with those even within the conservation area. Your agreement is a layer on top of the statutory floor, not a replacement for it.
That floor moved in July 2026. The NSW Government announced its first General Biosecurity Direction for feral pig control, covering every public and private landholder in the Walgett region and requiring participation in a coordinated control programme, with penalties of up to $220,000 for individuals and $440,000 for corporations, including government agencies. The pilot is scheduled to run from November 2026 to 30 June 2027 and the government has said it may extend the approach elsewhere if it works. It is the first time the Act has been used this way for pigs or deer.
We will not oversell it. It covers one region, it had not commenced at the time of writing, and no NSW landholder has been prosecuted for failing to control feral animals. But it establishes that a biosecurity direction can compel feral animal control across all tenures in a district, and a direction of that kind would reach your conservation area as readily as your neighbour’s cropping paddock.
How to Work Out Where You Stand
Four steps, in order.
- Get your management plan and your site values report. These are the documents that answer the question. If you inherited the agreement with the property and have never seen them, contact the Biodiversity Conservation Trust and ask.
- Establish whether the agreement is funded. Are you receiving an annual management payment for agreed management actions? That single question puts you in the first column of the table above or the second.
- Read the management actions list for pests. Is feral animal control listed as a management action, and is it funded? If yes, it is compulsory and your payment is conditional on it. If it is absent, your obligation about feral animals comes from the Biosecurity Act rather than from the agreement.
- Check your dates. When does your reporting period end, when is the 14-day report due, and when does the five-yearly plan review fall? Work backwards from those dates, because assembling a year of evidence inside a fortnight is where good intentions come apart.
How We Help
We built the Annual Stewardship and Compliance Program for landholders in this position: people who need the feral animal work done properly and need to be able to show it was.
It runs an initial property assessment read against your management plan, a scheduled year-round control programme timed to your plan and to the district’s coordinated windows, ongoing monitoring with trail cameras and periodic thermal drone surveys, and an annual written report documenting what was found, what was done, when, and with what result, together with the contractor invoice you are separately required to retain. It is structured so the record is assembled through the year rather than in the fortnight after your reporting period closes.
What we do not sell is a compliance guarantee, and we would be cautious of anyone who offers you one. Whether you have met a contractual or legal obligation is a matter for you and the relevant authority, not something a contractor can promise on your behalf. What is genuinely within our control is the pest management work, done to a professional standard, and the documented evidence that it was done. That is what we sell.
If your site is one you do not live on, our Absentee-Owner Monitoring retainer is the lighter-touch starting point and steps up into the full programme cleanly. And because feral animals cross tenure boundaries, our guide on coordinated neighbour programmes explains why control on a conservation site works best aligned with the district rather than run in isolation.
Carry an obligation you have to be able to prove you met? Get in touch with a copy of your management plan and we will tell you what it actually asks of you.
Sources consulted: NSW Biodiversity Conservation Trust, funded Conservation Agreement template (June 2025), Attachment 1 Dictionary and Attachment 3; Biodiversity Stewardship Agreement template (April 2023), clauses 3 to 5 and Attachments 2 and 4; NSW Government, Frequently asked questions about our Conservation Partners Agreements and Wildlife Refuges; NSW Government, Biodiversity offsets program outcomes and What we do (BCT); environment.nsw.gov.au, Biodiversity stewardship agreements and Total Fund Deposit and discount rate; Audit Office of New South Wales, Effectiveness of the Biodiversity Offsets Scheme (30 August 2022); NSW State of the Environment 2024, Protected areas and conservation; Biosecurity Act 2015 (NSW), sections 16 and 22; Local Land Services Act 2013 (NSW); reporting on the Walgett General Biosecurity Direction in The Land (11 August 2026), Region Riverina (1 August 2026) and Yahoo News Australia (24 July 2026).