DCCEEW – Implementing Australia’s Strategy for Nature 2024-2030

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RIAA supports the strategy’s ambition but notes that its current form lacks the specificity needed for effective execution. To ensure meaningful outcomes, RIAA recommends clearer mechanisms, defined timelines, and actionable steps, alongside stronger coordination across government levels and inclusive stakeholder engagement.

As nature conservation gains prominence among commercial stakeholders, it will simultaneously present both risks and opportunities for investors. Given the significant dependence that companies, industries and economies have on the services nature provides, the degradation of nature will prompt structural shifts in economies, compelling governments to heighten measures for managing increasingly scarce resources. These developments will have ripple effects across investment portfolios, influencing access to resources and associated costs, that can ultimately impact economic development. There is a growing trend towards nature-friendly business models among both corporate and retail consumers, a trend likely to intensify in the face of climate change, given the importance of healthy and thriving ecosystems to mitigating climate change. It creates an opportunity for investments in restoration, conservation, and sustainable solutions to enhance natural areas and increase biodiversity.

RIAA’s submission provides overall comments on the implementation plan and has been informed by our Nature Working Group, the Working Group’s External Reference Group as well as its by its previous submissions to:

RIAA thanks the members of RIAA’s Nature Working Group who contributed to this submission.

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General comments

Strengthen implementation and accountability mechanisms

RIAA welcomes the ambition and intent of the strategy and recognises its potential to guide national efforts in nature protection and restoration. However, the current draft remains overly aspirational and lacks the specificity required to be a true implementation plan for the strategy. The absence of clearly defined mechanisms, timelines, and actionable steps limits the strategy’s ability to drive meaningful outcomes. While we appreciate the consultation process as a valuable starting point, we encourage further clarity on how the proposed outcomes will be operationalised and measured in practice. This includes better explaining how restoration efforts and progress will be measured, particularly in alignment with frameworks such as the Taskforce on Nature-related Financial Disclosures (TNFD) and broader biodiversity market, and developing nature-positive sector pathways with clear timelines, ideally by 2028, to provide greater certainty and direction for investors.

We see value in incorporating structured planning, clearly defined targets, and cost estimation to better understand the scale of investment required. Ensuring that the implementation team is adequately resourced will be essential to delivering the strategy effectively and maintaining momentum overtime.

Greater governance and policy coherence

RIAA recognises the importance of strong coordination between all levels of government to ensure the effective implementation of the Strategy. Greater clarity around the respective roles and responsibilities of Federal and State Governments would enhance policy coherence and delivery. There is also value in strengthening communication and transparency in stakeholder engagement, particularly in how governments engage with civil society and the investment sectors. RIAA supports a co-design approach that meaningfully involves these stakeholders from the outset, helping to build a more inclusive and effective governance framework.

Unlocking the role of finance in nature-positive outcomes

RIAA submits that the implementation plan needs to more strongly reflect the critical role that investors and financial institutions play in enabling outcomes that support the protection and restoration of nature. At present, the role of investors is limited to referencing other Government initiatives on page 13 of the discussion paper. Investors will be a key stakeholder in the implementation of the Strategy.

Investors are increasingly understanding the significance, urgency and materiality of nature risk to their portfolio companies. RIAA’s 2024 Australian Responsible Investment Benchmark Report found that natural capital is emerging as an increasingly popular positive screening theme for Australian investors, with 34% of survey respondents screening for biodiversity preservation and conservation, while climate change-related issues continue to be a priority. Investors are increasingly engaging with investee companies on nature-related issues, with 62% of investors engaging with companies on biodiversity/nature conservation and 48%on natural capital issues. This indicates that investors would welcome a regulatory environment that better protects companies and the economy against nature risk.

In addition to clarifying the role of the private sector, RIAA encourages the Government considers expanding the mandates of institutions such as the Clean Energy Finance Corporation (CEFC) and the Australian Renewable Energy Agency (ARENA) to include nature-related investments. This would constitute an efficient and effective lever which the Government has control. Reviewing policy settings that affect broader investment structures – such as philanthropic trusts and private ancillary funds – could help unlock more diverse forms of capital.

Embedding First Nations leadership in nature-positive action

RIAA strongly supports the principle of First Nations self-determination and the central role of community-led approaches in caring for Country and advancing nature repair. Wherever possible, First Nations communities should be empowered to lead and own projects, ensuring that their knowledge systems, priorities, and rights are embedded in the design and delivery of nature-related initiatives.

We also see an opportunity to enhance existing frameworks to better support First Nations participation, particularly in relation to funding access and the co-design of investment mechanisms. Recognising the scale of capital required for nature-positive transitions is essential, as is building the capacity of both investors and First Nations communities to engage meaningfully. Noting that nature markets follow the development of carbon markets, more explicit integration of lessons learned from the work undertaken in relation to carbon markets and existing First Nations-led mechanisms would strengthen the implementation of the Strategy. There is also a clear need for more accessible and culturally appropriate forums to enable meaningful engagement of First Nations communities in nature markets.

See work related to the Dhawura Ngilan Business and Investor Initiative as an example of a First Nations led initiative.

Recommendations

To support the successful implementation of the Strategy, RIAA recommends the following actions:

‍Establish clear timelines for mandatory nature-related disclosures by 2028, aligned with the International Sustainability Standards Board (ISSB).‍
Undertake economy-wide nature risk assessments in accordance with the Network for Greening the Financial System (NGFS) guidelines to better understand systemic risks and opportunities.‍
Expand the mandates of public finance institutions such as the Clean Energy Finance Corporation (CEFC) and the Australian Renewable Energy Agency (ARENA) to explicitly include nature-related investments.‍
Create inclusive and culturally appropriate forums to enable meaningful participation of First Nations communities, civil society and investors in the development and implementation of the Strategy.‍
Leverage existing mechanisms and insights from carbon markets and First Nations-led initiatives to inform the design of effective and equitable nature markets.
Enhance transparency and consistency in government engagement and decision-making processes to build trust and ensure accountability.