The Scottish Government published the draft of its new Climate Change Plan (CCP) on 6 November 2025. This is a statutory requirement under the Climate Change (Scotland) Act 2009 (as amended). Publishing the draft has kicked off 120 days of parliamentary scrutiny, as required by the legislation.
This Plan outlines how the Government intends to meet its carbon budgets across all sectors. It covers the period 2026-2040 with the goal of being ‘net zero’ in carbon emissions by 2045. Net zero is the point when emissions entering the atmosphere are balanced by removals out of the atmosphere.
Scrutiny of the draft CCP is a cross-parliamentary effort, reflecting the fact that climate change impacts across all sectors, with the Net Zero, Energy and Transport (NZET) Committee taking the lead.
This blog explores the Scottish Government’s policies and proposals in the agriculture chapter in the new draft CCP. It draws on information received through the NZET Committee’s call for views ahead of the new draft CCP (a summary of views on the agriculture chapter is published). It also compares the chapter with the May 2025 advice to the Scottish Government on meeting its carbon budgets published by the Climate Change Committee (CCC), statutory advisor on climate change to the UK and devolved governments.
This blog is published in two parts. The second part discusses the ‘Land use, land use change and forestry’ (LULUCF) chapter of the draft CCP.
For more blogs on other topics relating to the draft CCP, visit the SPICe Hub on the Plan.
Overview
The CCC considers agriculture to be ‘largely devolved’. Between 1990 and 2023 there has been a 13% reduction in emissions in the sector. According to the CCC, emissions reductions in agriculture (up to 2022) are due to a decline in livestock numbers from 1990 to the mid-2010s as well as reductions in emissions from soils.
The largest sources of emissions within the agricultural sectors are (from SRUC research which uses 2018 figures):
- ‘Enteric methane’ (i.e. digestive emissions from grazing animals), which accounts for just under half of Scottish agricultural emissions,
- manure management (approximately 14%),
- emissions from mobile machinery (e.g. tractors, approx 10%), and
- emissions from inorganic fertilisers (approx 8%).
Since the Climate Change Plan Update (CCPu) in 2020, headline emissions from agriculture have not changed significantly. The CCPu projected that agricultural emissions would be 7.0 MtCO2e in 2020 and that agricultural emissions would fall to 6.3 MtCO2e by 2023. The actual figure in 2020, published in the 2022 emissions inventory, was 7.4 MtCO2e, and emissions in 2023 (our most recent figures) are estimated to be 7.5 MtCO2e, 1.2 MtCO2e higher than the CCPu anticipated.
It is important to recognise that activities that absorb carbon from the atmosphere (known as ‘sequestering’ carbon) such as tree planting and peatland restoration, and the effort and investment that this requires, have occurred on farms and crofts, but these are reported in the land use, land use change and forestry (LULUCF) sector. The Scottish Government recognises this overlap in the CCP. Splitting the chapters up in this way follows international conventions for reporting greenhouse gas emissions. A SPICe blog published in July 2024 breaks down emissions in these two sectors in more detail.
As an overview, policies and proposals in the draft CCP include:
- Promoting low carbon farming measures through a new agricultural support scheme,
- Proposals around technological advancements such as lower emissions tractors and alternative fertilisers,
- Commitments around providing advice,
- Policies which reference existing regulatory and eligibility changes, such as precision application of slurry, the recently introduced requirements for whole farm plans, and changes to requirements around protecting wetlands on farm,
- The recently launched Future Farming Investment Scheme, which provides capital grants for low-carbon, business efficiency and nature-related investments,
- Policies and proposals to improve efficiency and welfare and reduce emissions in the livestock sector, and
- Policies around trees on farms.
The rest of this blog focuses on some of these measures in more detail.
Key policy drivers in the new draft CCP
The Scottish Government identifies three “key policy drivers” for agriculture. Two of these are technically ‘proposals’, rather than ‘policies’. This means that they are at an earlier stage of development, are less specific and are not, or not fully, costed.
The two new key ‘proposals’ are to:
- Reduce emissions from non-road mobile machinery (e.g. tractors) by “investigating and promoting efficiencies, alternative fuels and technological developments and providing knowledge exchange, guidance and advice”, and
- Investigate technologies for alternative, improved or more efficient fertilisers and “encourage uptake where appropriate”, increase understanding of nitrification and urease inhibitors[1]
These two areas make up around 20% of Scottish agricultural emissions. However, there is little detail in the draft CCP on what the Scottish Government will do to deliver these commitments.
The draft CCP references ongoing work with other governments of the UK to “review and reform…the existing fertilisers regulatory framework” to “enable a broader range of fertilising products to be regulated” with the potential to be less harmful than traditional mineral fertilisers.
The draft CCP details, in the Energy Supply chapter, an aim to decarbonise non-road mobile machinery by at least 80% by 2040. This includes machinery in multiple sectors and Annex 3 notes that the exact reduction in each sector is unknown. For agricultural machinery an assumption has been made of 50% of new purchases being alternatively fuelled by 2040. There is little detail provided on how this will be achieved.
The key driver of emissions reductions that is officially a ‘policy’ is the commitment to continue the delivery of the Agricultural Reform Route Map which has been ongoing since 2023. This policy, and relatedly, the commitment to publish the first ‘Rural Support Plan’ in winter 2025, outlining plans for agricultural support schemes, are existing steps in a long process to reform agricultural policy following the EU referendum in 2016.
Most of the respondents to the NZET Committee’s call for views highlighted that the ongoing reform of agricultural policy and funding is key to ensuring that the agricultural sector is able to reduce emissions.
In the technical information set out in Annex 3 the Scottish Government states that –
“the primary driver of emissions reductions from the baseline in agriculture will come from the Agricultural Reform Programme which is being designed to incentivise the uptake of climate change mitigation measures”.
The Scottish Government has not broken down estimated emissions reductions for any of the policies or proposals in the agriculture chapter; they estimate that the combined emissions impact of CCP policies and proposals in the next carbon budget (2026-30) will be 0.1 MtCO2e with larger impacts expected in later budgets (1.3 MtCO2e in 2031-35 and 3.5 MtCO2e in 2036-41).
The supporting information in Annex 3 sets out several assumptions that have been made in calculating these emissions savings:
- That there will be a 45% uptake of low-carbon farming measures,
- That the majority of measures are to be implemented from 2030 and take 10 years to reach peak uptake levels.
However, the draft CCP states that the –
“45% level of uptake [of low carbon farming measures] will be extremely challenging for the sector to achieve. The approach has been presented to the Academic Advisory Panel [a group of academics who are supporting the Scottish Government’s agricultural policy development] who determined it may be beyond an achievable level of mitigation for the sector. As the Agricultural Reform Programme develops and policy mechanisms become clearer these assumptions will need to be revisited” (emphasis added).
There is no discussion of contingency should this level of uptake not be achievable. It therefore appears that delivering the emissions reductions in this chapter may be at risk.
There is little information in the plan on how uptake of low-carbon farming measures will be ensured, either through incentives or regulation. It is assumed that more detail will be available in the upcoming Rural Support Plan and as specific support schemes are rolled out.
As this is a major policy area which is, to a large extent, still being developed, it is very difficult to scrutinise to what extent this programme (and therefore the draft CCP’s plans for agriculture) will actually result in the desired emissions reductions. However, it is worth remembering that in 2021 the EU Court of Auditors evaluated climate change mitigation and adaptation impacts of the 2014-2020 Common Agricultural Policy (CAP; the legacy of which largely remains in place in Scotland as schemes are still to be replaced). It found that while the European Commission had attributed over a quarter of the CAP budget to climate change mitigation and adaptation, this spending had little impact on agricultural emissions EU-wide.
It therefore seems likely that there will need to be evidence of meaningful changes to agricultural support in the upcoming Rural Support Plan, to have confidence that the Scottish Government’s plans will deliver the emissions savings set out in the draft CCP.
Comparing the draft CCP with the CCC’s advice
The CCC’s balanced pathway assumes deeper emissions reductions for agriculture, in large part because it assumes a reduction in livestock numbers alongside a reduction in meat and dairy consumption to avoid imports increasing to make up for lower domestic production (this is known as offshoring). The chart below shows the differences in the five-year carbon budgets in the CCC’s pathway compared to the draft CCP:
The question of livestock numbers is a controversial area with opposing views received in the NZET’s call for views. After the CCC’s advice was published in May 2025, the Scottish Government came out clearly in a statement in June 2025 stating it would not introduce policies to reduce livestock numbers. The draft CCP therefore includes several policies and proposals to improve efficiency and reduce emissions from existing livestock production but does not address the question of overall production.
Speaking to the NZET Committee in September 2025, the CCC said:
“In our pathway, we look first of all at measures that can be achieved without reducing livestock numbers, which would deliver about half of the emissions reduction in agriculture that we expect to see. However, the other half of the emissions reduction involves a roughly 26 per cent reduction in livestock numbers by 2035 and a 36 per cent reduction by 2045. If you were not to deliver those reductions, that would add about a megatonne—1 million tonnes—of emissions to the Scottish emissions pathway compared with what we have published… an increase in the sector’s emissions of about 20 per cent…in addition, you would lose some of the land that our modelling assumes is freed up for things such as peatland restoration and tree planting, which would have a knock-on impact on emissions that would go beyond that 1 million tonnes, but we have not quantified that.”
The CCC was clear that “it is for the Scottish Government to decide exactly how it wants to deliver the emissions reduction to meet carbon budgets”; in other words, this is a policy choice that the Scottish Government is free to make. However, as the CCC put it, not introducing policies on livestock reduction will “leave a gap that would need to be filled”.
Policy integration
Several respondents to the NZET Committee’s call for views highlighted the need for integrating agricultural policies with other areas, such as tree planting and peatland restoration, and the wider food system.
A number of respondents raised the importance of trees on farms. For example, NatureScot highlighted that more attention should be paid to agroforestry and hedgerows, proposing setting a target for hedgerow and agroforestry expansion according to CCC recommendations. They note that the Agricultural Reform Programme and Forestry Grant Scheme should be used to increase the incentivisation of agroforestry.
The draft CCP does include a proposal to update and develop mechanisms to better support trees on farms through future agricultural support and the Forestry Grant Scheme. However, there are no specific targets on agroforestry and hedgerows.
The RESPECT project raised a similar point in the call for views about a need to support sustainable agricultural management of peatlands. There is a proposal in the LULUCF chapter to continue work to develop incentives, guidance and advice on peatland stewardship within the new agricultural support framework. Again, for both of these areas, it is only when we see the details of these new schemes that it will be possible to assess ambition and potential emissions reductions.
Finally, a couple of respondents highlighted a desire to see links made with nutrition and the wider food system, by, for example, aligning agricultural measures with dietary health outcomes and supporting farmers to produce more horticultural crops and legumes. The draft CCP, like previous CCPs, does not provide any context or wider commentary on the food system beyond agricultural production.
Just transition
There is a greater focus on a ‘just transition’ to net zero in this draft CCP, following new requirements in the Climate Change (Emissions Reductions Targets) (Scotland) Act 2019.
Ensuring a just transition means, among other things, that the costs and benefits of climate change are fairly distributed, that everyone plays their part to mitigate and adapt to climate change, and that inequalities are addressed, and negative impacts minimised along the way.
To monitor progress towards these goals, the draft CCP includes a set of ‘just transition indicators’ which “aim to give an indication of whether we are achieving a just transition alongside progress on our emissions reduction pathways”.
There are two land-use related indicators – the number of hectares of peatland restored or woodland planted per year. In addition, indicators in relation to fuel poverty and transport affordability will be broken down by urban and rural classifications.
However, there appear to be no indicators which specifically assess the just transition in the agricultural sector or for rural communities more widely.
The Scottish Government recognises that some of the indicators are incomplete, stating that
“a project is currently underway to develop a more comprehensive just transition M&E [monitoring and evaluation] framework through a staged process of evidence review, stakeholder engagement and cocreation.”
Will it be enough?
As ever, this is the key question. And based on the information provided in the CCP, this is not possible to answer without more information.
As Committees come to scrutinise the CCP, it is worth remembering the CCC’s four ‘priority recommendations’ for agriculture and land use in its most recent progress report to the Scottish Parliament in March 2024:
- Provide incentives and address barriers for farmers and land and estate managers to diversify land use and management at a range of scales into woodland creation, peatland restoration, agroforestry, and renewable energy. These policies need to support and empower rural communities to deliver these changes.
- Ensure that funding and incentives are set at the correct level to deliver the scale-up in tree planting that is needed this decade.
- Provide long-term certainty on public funding for farming practices and technologies to reduce emissions from managing crops and livestock. As part of this, ensure low-regret and low-cost measures are taken up through baseline regulations or minimum requirements in the new agricultural support mechanisms (for example actions to deliver resource protection, enhance nature, and build resilience), especially when they can deliver efficiency improvements.
- Support a shift in average meat and dairy consumption towards lower-carbon foods. The most promising levers include replacing a small amount of meat and dairy content in pre-prepared meals with plant whole foods or alternative proteins; increasing choice and availability of lower-carbon foods in public procurement, restaurants, and supermarkets; and supporting novel alternative proteins with improved taste and texture.
However, the real question is whether the whole plan adds up to meet Scotland’s carbon budgets in a credible way that is likely to take Scotland to net zero by 2045. In the agriculture sector (and in the LULUCF sector, as Part 2 of this blog series will discuss), the ambition in the draft CCP appears to be lower than the CCC’s balanced pathway expects. The key question is where the difference is made up, and whether it is realistic and equitable for other sectors to take on more emissions reductions as a result.
Anna Brand, Senior Researcher
Featured image by Professor Ed Hawkins, University of Reading.
[1] Chemicals which reduce emissions and losses and improve efficiency of fertilisers.