Steph Emmerson (FCG WhiteAvon)

Please note this article was written before DEFRA’s announcement of new SFI launching in June.

I was asked the other day by a friend what my predictions would be for 2026.  My answer at the time was vague, win the lottery, a new shiny Landover, etc., etc.  But it struck me as a good opportunity to put some of those thoughts down more formally, particularly around what the next phase of the Sustainable Farming Incentive (SFI) scheme may look like.

This is not complete guesswork.  I would like to think that my many years of experience working with policy schemes gives a reasonable understanding of what tends to work well, what does not, and perhaps most importantly, what government departments are likely to do when faced with budget pressure, political scrutiny, and competing priorities.  I have also considered Dame Angela Eagle’s comments following her talk at the DEFRA Committee meeting last year, which provided some useful signals about direction of travel.

1. When Will the New SFI Open?

According to Dame Angela Eagle, the expectation is that the new scheme will “open” in April 2026.  On the face of it, that sounds relatively clear-cut.  However, I think there are two important caveats hidden within that statement.

The first is the meaning of the word open.  My prediction is that April 2026 will not represent a full, universal opening of the scheme to all applicants.  Instead, it is more likely to be a phased or restricted launch.  In particular, I anticipate priority access being given to:

This would mirror previous approaches, allowing Defra to manage demand, cashflow, and administrative pressure while still claiming progress against delivery timelines.

The second caveat is the timing itself.  While April 2026 has been mentioned, it is worth remembering that the original language used around the new scheme was “summer 2026.”  Historically, when government says “summer,” the reality often drifts later rather than earlier.  For that reason, my expectation is that widespread access is more likely to fall around July 2026 rather than April.

In short, April 2026 may mark the start of the process, but not the point at which most farmers can realistically expect to submit an application.

2. Application Size Caps Will Remain but Evolve

Last year saw the introduction of caps on application sizes, a move that caused understandable concern across the sector.  My prediction is that these caps will remain in some form under the new SFI, but they are unlikely to stay as restrictive as they are currently.

The rationale for retaining a cap is clear.  Around 25% of total SFI payments currently go to just 4% of farms.  That statistic alone makes it politically difficult for Defra to justify a completely uncapped system, particularly in the current funding climate.

That said, the existing caps are arguably too blunt an instrument.  They risk discouraging environmental delivery at scale and penalising businesses that are well placed to deliver outcomes efficiently over large areas.

I therefore expect a compromise approach.  Caps are likely to remain, particularly on very large, farmed areas, but at higher thresholds than we see now, and potentially structured in a more nuanced way.

3. A Return to Maximum Option Areas per Holding

I also predict a return to limiting how much of each option can be delivered per holding, rather than allowing unlimited uptake across an entire farm.

We now have a much stronger evidence base showing that environmental benefits often plateau beyond a certain point.  For example, a defined area of wild bird seed mix per 100 hectares is known to deliver measurable benefits.  Beyond that threshold, the additional environmental gain is limited, while the cost to the scheme continues to rise.

For that reason, I expect the reintroduction of maximum hectare limits per option, potentially structured around “packages” or bundles of actions.  This would allow Defra to steer delivery toward what is known to work, while preventing over-concentration of a single option on large holdings simply because it is financially attractive.

This approach would also align with previous stewardship schemes, where packages were used to encourage balanced delivery rather than option stacking.  While this may reduce flexibility for some businesses, it reflects a growing focus on outcomes rather than sheer area entered.

4. A Stronger Focus on Measurement, Evidence, and Outcomes

Finally, if all of the above is to work, it must be measurable and evidence-led.  I expect a renewed emphasis on record keeping, evidence collection, and crucially demonstrating outcomes.

This does not necessarily mean more inspections, but it does mean clearer expectations around what evidence is required, how it is stored, and how outcomes are reported.  Data, photos, maps, and management records will become increasingly important, not just for compliance, but for justifying the scheme politically.

There also needs to be far more confidence in “telling the story” Of what SFI is delivering.  That means properly capturing outcomes and being willing to talk about them – both within government and publicly.  If the scheme cannot clearly demonstrate value for money and tangible environmental gains, it will remain vulnerable to budget cuts and redesign.

Final Thoughts

If there is one consistent lesson from past policy schemes, it is that change rarely comes as a clean break.  The new SFI in 2026 is likely to be an evolution rather than a revolution shaped as much by budgetary reality and political optics as by environmental ambition.

A phased opening, continued caps, limits on option areas, and a stronger evidence base all fit with what we have seen before.  Whether this strikes the right balance between fairness, flexibility, and delivery remains to be seen but the direction of travel feels increasingly clear.

As ever the devil will be in the detail, and this will matter far more than the headlines!

To discuss further then please do not hesitate to contact Steph at stephemmerson@fcgagric.com or your local FCG Office.