The NFF’s original submission in November 2025 raised significant concerns about the restriction of projects to selected IBRA subregions in eastern and south-western Australia. The NFF argued that this substantially constrained participation, particularly across northern Australia and grazing and native-pasture landscapes, and recommended consideration of percentage-based eligibility or case-by-case assessment for otherwise suitable projects.
The exposure draft does not materially address this concern. While more vegetation types and condition states may now be eligible within that footprint, opportunities remain unavailable across large areas of Australia where farmers actively manage native vegetation.
The NFF’s full submission can be viewed here.