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What a Biodiversity Stewardship or Conservation Agreement Requires You to Do About Feral Animals

Tristan

It depends on which agreement you hold and what your management plan says, and the difference is bigger than most landholders realise. A funded biodiversity stewardship or conservation agreement makes the management actions in your plan compulsory, requires an annual report within 14 days of the end of each reporting period, and makes your annual management payment conditional on both. Where your plan lists feral animal control as a funded management action, controlling feral animals is not optional and your payment depends on doing it. An unfunded conservation agreement or a wildlife refuge is different: the NSW Biodiversity Conservation Trust says it recommends you actively manage the conservation area, 'but it is not a legal requirement'. In every case the agreement defines 'Pest' broadly, as any member of the animal kingdom specified as a pest in your site's values report or declared under a pest control order, and in every case your general biosecurity duty and any pest control order still apply underneath the agreement. The right question is never 'do agreements require feral control', it is 'what does my management plan say'.

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 agreementWildlife refuge
Annual management paymentYes, to carry out agreed management actionsNo ongoing management paymentNo ongoing management payment
Management actionsCompulsory where listed in your planNot compelledNot compelled
Active management of the conservation areaRequired as set out in the planRecommended by the BCT, “but it is not a legal requirement”Recommended, not a legal requirement
Annual reportDue within 14 days of the end of each reporting periodNot the same compelled cycleNot the same compelled cycle
Annual site inspection by the BCTYes, on active agreementsNoNo
Payment withheld for non-completionYes, the BCT may withhold, delay, or not payNot applicableNot applicable
DurationIn-perpetuity, binding on all future ownersIn-perpetuity, binding on all future ownersStays in place if sold, but can be revoked by the landholder
Contractor invoices retained as evidenceYes, for funded management actionsNot requiredNot required
General biosecurity duty still appliesYesYesYes

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.

A herd of feral deer on NSW conservation country, one of the species that can fall within the pest definition in a biodiversity agreement

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.

  1. 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.
  2. 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.
  3. 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.
  4. 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).

Frequently Asked Questions

Does my biodiversity agreement require me to control feral animals?

Only where your management plan says so, which is why the honest answer is to go and read your plan. Biodiversity Conservation Trust agreements define 'Pest' and 'Pest Control' as operative terms and the management plan covers pests among other matters, so feral animal control is clearly enabled. But the funded management actions are set per site from that site's values report, not from a standard list, so feral control is a requirement on some agreements and not on others. Where your plan does list it as a funded management action, it is compulsory and your annual management payment is conditional on completing it. Be wary of anyone who tells you every agreement requires feral animal control, because the templates do not support that.

What counts as a 'pest' under a BCT agreement?

Broadly. The Biodiversity Conservation Trust's funded conservation agreement template defines a Pest as any member of the animal kingdom specified as a pest in the site's values report, or declared under a pest control order. Feral pigs, deer, foxes, wild dogs, rabbits, goats and cats can all sit inside that definition. The template also defines Pest Control as control using methods recommended by the BCT or another relevant NSW Government authority, which minimise damage to non-target native animals. That last clause matters on conservation land, because it rules out approaches that would put native species at risk and it shapes which methods are appropriate on your site.

What is the difference between a funded and an unfunded agreement?

It is the difference that decides nearly everything. A funded agreement, such as a biodiversity stewardship agreement or a funded conservation agreement, pays you an annual management payment to carry out agreed management actions, and those actions are compulsory. The BCT is entitled to withhold, delay, or not make payments where a funded action has not been completed by the due date or the annual report has not been received. An unfunded conservation agreement or a wildlife refuge carries no management payment and no compelled action list. The BCT's own guidance says it recommends you actively manage the conservation area you establish, 'but it is not a legal requirement'.

When is my annual report due and what happens if it is late?

For a funded agreement the annual report is due within 14 days of the end of each reporting period, which is a short window if you are assembling the record from scratch. The BCT manages active agreements by reviewing annual reports, undertaking annual site inspections, and making the annual management payment where the management actions have been completed. If the report has not been received or the actions have not been done, the BCT is entitled to withhold, delay, or not make the payment. There is also a formal review of the management plan every five years. Late reporting is more common than you might think: the NSW Audit Office found that in 2021 only 58 per cent of landholders with stewardship sites provided an annual report to the BCT.

Do wildlife refuges carry the same obligations?

No, and the differences are worth knowing before you compare yourself to a neighbour under a different instrument. A conservation agreement is in-perpetuity and binding on all future owners. A wildlife refuge remains in place if the property is sold but can be revoked by the landholder, and the BCT describes it as an entry-level option for people who want to protect biodiversity without entering a permanent agreement. Neither carries a compelled feral animal control obligation unless it comes with funded management actions. Your general biosecurity duty applies to both regardless.

Does my biosecurity duty still apply inside a conservation area?

Yes. The agreement sits on top of the statutory duty; it does not replace it. Both the stewardship agreement and the conservation agreement templates 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, meaning you must still comply with those inside the conservation area. So even if your management plan is silent on feral animals, you still carry the general biosecurity duty every NSW landholder carries, and a biosecurity direction issued for your district would still bind you.

Who pays for the pest control?

On a funded agreement, the funding is built into the arrangement. A biodiversity stewardship agreement carries a Total Fund Deposit intended to cover the costs of future land management activities, and the BCT makes annual payments to cover the agreed costs of those activities. Where pest control is one of the funded management actions in your plan, you have a funded budget line for it rather than an unbudgeted cost. On an unfunded agreement or a wildlife refuge there is no management payment, though Conservation Partners grants may be available to help with management. Pest control costs are also generally tax deductible for primary producers.

I bought a property with an agreement already on the title. What have I taken on?

Potentially quite a lot, and it is worth finding out early rather than at your first reporting deadline. Agreements entered into under the Biodiversity Conservation Act are registered on the land title and bind current and successive landowners, and biodiversity stewardship agreements continue in perpetuity. That means the management plan, the management actions, and the reporting obligations came with the property. Ask for a copy of the management plan and the site values report, work out whether the agreement is funded, and check when the reporting period ends and when the five-yearly plan review falls. If feral animal control is a funded action in that plan, it has been your obligation since settlement.

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