Bhutan

National Biodiversity Strategy and Action Plan

Southern AsiaApplies through 2030Source: National Biodiversity Strategy and Action Plan (NBSAP 5)

1. Overview

Bhutan's National Biodiversity Strategy and Action Plan (NBSAP 5) sets out 20 national commitments* mapped to the 23 targets of the Kunming-Montreal Global Biodiversity Framework, supported by 40 strategies and 133 actions [§103][§105]. The plan was developed through consultations coordinated by the National Biodiversity Centre (NBC) between June 2023 and April 2025, validated through regional consultations across all 20 Dzongkhags involving local governments, sectoral agencies, community-based organisations, the private sector, and monastic bodies [§103].

The strategy is organised around a vision of "a happy and resilient Bhutan, living in harmony with nature by valuing mountain biodiversity" and a mission centred on conserving mountain biodiversity through a holistic approach [§101]. Mountain biodiversity functions as the organising identity, distinguishing Bhutan's NBSAP from lowland- or marine-oriented plans and shaping climate commitments around treeline advance, high-altitude disease vectors, and glacial lake outburst floods rather than sea-level rise.

Of the 20 national commitments, one — restoring at least 10% of degraded areas — qualifies as a measurable commitment with a quantitative threshold. The remaining 19 are directional aspirations. National commitment 19 (resource mobilisation) carries a 2025 deadline; all others target 2030. The NBSAP contains no costed implementation plan; a Resource Mobilisation Plan is under preparation [§155].

Bhutan already protects 52% of its territory and constitutionally mandates at least 60% forest cover in perpetuity. Its NBSAP builds on a carbon-negative baseline and a proven conservation finance architecture — including the world's first environmental endowment fund and Asia's first Project Finance for Permanence initiative — to address pressures from human-wildlife conflict, invasive species, climate-driven ecological shifts, and the financing risks of graduating from Least Developed Country status.

Sources:

§101 — Chapter 4 > 4.1 Vision and 4.2 Mission
§103 — 4.4 NBSAP 2025 Development Process
§105 — 4.6 Bhutan's NBSAP Targets aligned with KMGBF
§155 — 5.5 Resource Mobilization

2. Ecological Context

Bhutan spans 38,394 sq. km in the Eastern Himalayas, with altitudinal variation from 100 to over 7,500 metres generating six agro-ecological zones and constituting 7.6% of the Himalayan Biodiversity Hotspot [§17]. Forests cover 69.7% of the land area, ranging from subtropical lowlands to alpine fir and juniper-rhododendron zones [§17][§20]. The country has documented 11,248 species, including 5,390 seed plant species (98% native), 129 mammals, 736 birds, 158 herpetofauna, and 125 freshwater fish [§17][§26–§31]. Tigers and snow leopards coexist in the same landscape — described as "a rare ecological phenomenon globally" [§27]. Five major river basins and 567 glacial lakes, 17 of which are classified as potentially dangerous, define the freshwater system [§21].

The principal pressures interact across elevation gradients. Land conversion allocated 3,273 ha of State Reserved Forest in 2023, and forest loss within protected areas averaged approximately 4,675 ha annually between 2016 and 2022 [§71]. Forest fires affected 28,000 ha across 261 incidents between 2020 and 2024, with frequency nearly tripling from 26 incidents in 2020 to 72 in 2023 [§72]. A total of 136 alien plant species have been documented, with nine listed among the world's 100 worst invasive alien species [§77]. Farmers lose an estimated 30% of annual crop production to wildlife, with 233 human-wildlife conflict cases recorded in 2023 [§78][§87].

Bhutan remains carbon negative — 2022 emissions of 1.74 million metric tonnes CO₂e against 11.45 million metric tonnes sequestered [§80]. However, treelines are advancing approximately one metre per year, the country recorded its highest-ever temperature at 40°C in 2024, and mosquitoes were observed at 4,800 metres above sea level [§80]. Solid waste generation averages 172 metric tonnes per day [§79].

Sources:

§17 — Introduction
§20 — I. Forest Ecosystem > A. Ecosystem Diversity
§21 — II. Aquatic Ecosystem
§26–§31 — Species diversity sections
§71 — 2.1 Direct Threats > A. Land Use Conversion
§72 — B. Forest Fire
§77 — G. Invasive Alien Species
§78 — H. Human-Wildlife Conflict
§79 — I. Pollution
§80 — 2.2 Indirect Threats > A. Climate Change and Biodiversity
§87 — 3.4 Human-Wildlife Co-existence

Gross National Happiness and the Constitutional Conservation Mandate

Article 5 of the Constitution of the Kingdom of Bhutan (2008) mandates that a minimum of 60% of the country's land area be maintained under forest cover in perpetuity — a provision first established through the National Forest Policy of 1974 [§18]. This constitutional floor, combined with a protected area network covering 52% of national territory, means Bhutan's baseline already surpasses the GBF's 30×30 target. The NBSAP does not set a standalone protected area expansion commitment; instead, it focuses on management effectiveness and spatial planning beyond existing boundaries [§108].

The Gross National Happiness (GNH) philosophy shapes the economic framing of the strategy. The Economic Development Policy of 2016 promotes a green economy under the "Brand Bhutan" initiative, positioning environmental conservation as a driver of economic growth [§41]. The Tourism Policy of 2019 follows a "High Value, Low Volume" approach [§41]. The NBSAP's vision of "a happy and resilient Bhutan" and the Gelephu Mindfulness City — a planned development integrating ecological corridors, green infrastructure, and water-sensitive urban design — reflect this alignment of biodiversity conservation with GNH-derived development planning [§101][§130].

The constitutional mandate, GNH framing, and carbon-negative status collectively form the structural logic behind Bhutan's approach: conservation is not an add-on to development policy but a constitutional obligation and economic strategy.

Sources:

§18 — 1.2 Bhutan's Conservation History
§41 — Biodiversity Related Policies
§101 — Chapter 4 > 4.1 Vision and 4.2 Mission
§108 — Target 1 Strategies and Actions
§130 — Target 12 Strategies and Actions

3. National Commitments and GBF Alignment

Bhutan's 20 national commitments are grouped below by theme. Each subsection states the commitment, its GBF Target mapping, key delivery instruments, and measurability classification.

Conditions of Nature

National commitment 1 — Spatial planning: "Plan and manage all areas to reduce biodiversity loss" (GBF Targets 1 and 3). Instruments include updating the National Land Use Zoning (NLUZ) system, developing management plans for protected areas and OECMs with effectiveness assessed via METT+, instituting river rangers and SMART patrolling for freshwater biodiversity, and developing at least one river basin management plan [§108]. The 2024 National Tiger Survey found more tigers outside protected areas than within, directly motivating the spatial planning approach. Directional aspiration — "all areas" is universal but no quantitative threshold defines "managed."

National commitment 2 — Ecosystem restoration: "Ensure at least 10% of degraded areas are brought under effective restoration" (GBF Target 2). Actions include instituting a multi-sectoral restoration committee, developing restoration guidelines covering rangeland, and baseline mapping of degraded areas [§110]. Baseline mapping is acknowledged as not yet complete; the 10% target cannot currently be converted to hectares. Measurable commitment — quantitative threshold (10%) with a 2030 deadline.

National commitment 4 — Species recovery and genetic diversity: "Maintain the population of threatened species, conserve genetic diversity and manage human-wildlife conflict" (GBF Target 4). Instruments span three sub-strategies: updating the National Red List (which does not yet exist), developing conservation action plans for at least two threatened species, strengthening the White-bellied Heron conservation breeding programme, expanding biorepositories and genebanks, and initiating germplasm conservation of key wildlife species [§114]. Directional aspiration — "maintain" without population thresholds.

National commitment 6 — Invasive alien species: "Manage invasive alien species to minimize their impacts on biodiversity" (GBF Target 6). Actions include reviewing legislation, developing SOPs for IAS pathway management, conducting research, and maintaining the IAS database [§118]. The previous NBSAP's IAS target received the lowest achievement score at 35% [§57]. Directional aspiration — no quantified reduction target.

Pressures

National commitment 5 — Sustainable harvest: "Ensure safe and legal harvesting of wild species" (GBF Targets 5 and 9). Instruments include resource assessment of species used in traditional medicine (Sowa Rigpa), domestication trials, and amendment of the Forest and Nature Conservation Rules and Regulations 2023 [§116]. Directional aspiration.

National commitment 7 — Pollution reduction: "Ensure reduction in pollution to minimize threats to biodiversity" (GBF Target 7). Actions focus on identifying pollutants, updating Environmental Standards 2020, annual compliance monitoring, and gap assessment of waste management facilities [§120]. Directional aspiration — no quantified reduction targets for nutrients, pesticides, or plastics.

National commitment 8 — Climate and biodiversity: "Minimize the adverse impacts of climate change on biodiversity and build resilience" (GBF Target 8). Bhutan's carbon-negative status (1.74 Mt CO₂e emitted vs 11.45 Mt CO₂e sequestered, 2022) provides the baseline [§80]. Actions include research on climate impacts on mountain biodiversity, at least one international symposium on mountain biodiversity and health, upscaling afforestation, strengthening forest fire prevention, and pursuing REDD+ initiatives [§122]. Directional aspiration.

Tools and Solutions

National commitment 10 — Agriculture, forestry, and fisheries: "Ensure that areas under agriculture, livestock, fisheries, and forestry are managed sustainably for food security and livelihood" (GBF Target 10). The most action-dense commitment (18 actions across five strategies), covering Sustainable Land Management, Good Agricultural Practices guidelines, precision livestock farming, index-based crop and livestock insurance, community forest management plans, and community-based fisheries [§126]. Directional aspiration — "managed sustainably" without area or yield thresholds.

National commitment 11 — Ecosystem services: "Maintain and enhance nature's contribution to people" (GBF Targets 11 and 14). Key instruments include implementing at least two nature-based solutions and the National Implementation Plan for the System of Environmental-Economic Accounting (SEEA) in Bhutan (2024–2029) [§128]. A 2013 study estimated ecosystem services at USD 15.5 billion annually; no national update has followed [§98]. Directional aspiration.

National commitment 12 — Urban biodiversity: "Enhance and/or plan green and blue spaces in urban areas" (GBF Target 12). Actions include developing the City Biodiversity Index in at least two Thromdes and revising Building Codes to incorporate green and blue spaces [§130]. Directional aspiration.

National commitment 13 — Genetic resources and ABS: "Increase the sharing of benefits from genetic resources, digital sequence information and traditional knowledge" (GBF Target 13). Bhutan's 14 executed ABS agreements and 14 ABS products represent the country's strongest implementation track record, with the previous NBSAP's ABS target scoring 93.8% achievement [§94][§57]. New actions include establishing a Bhutan ABS Clearing House Mechanism and developing a strategy for the ABS Fund [§132]. Directional aspiration — "increase" without baseline or quantum.

National commitment 16 — Sustainable consumption: "Promote sustainable consumption and production to reduce waste" (GBF Targets 15 and 16). Instruments include Extended Producer Responsibility, Public-Private Partnerships in waste management, and R&D on post-production waste reduction [§138]. Directional aspiration.

Implementation and Enablers

National commitment 3 — Inclusive participation: "Strengthen inclusive participation in biodiversity-related decision-making processes" (GBF Target 22). Actions include developing guidelines for participation across diverse genders and groups, and establishing a monitoring mechanism [§105]. Directional aspiration.

National commitment 9 — Data and information: "Ensure that information and knowledge related to biodiversity are available and accessible" (GBF Target 21). Instruments include establishing a national GBIF node, upgrading the Bhutan Biodiversity Portal, and developing SOPs for data collation and publication [§124]. Directional aspiration.

National commitment 14 — Mainstreaming: "Enhance mainstreaming and integration of NBSAP into national, sectoral, and local plans" (GBF Target 14). Includes alignment of NDC 3.0 with the NBSAP and sector-specific workshops to identify entry points [§134]. Directional aspiration.

National commitment 15 — Gender equality: "Ensure gender equality and gender-responsive approach in biodiversity actions" (GBF Target 23). A full-cycle approach: gender analysis, action plan development, implementation, and assessment [§136]. Women constitute 73.6% of the rural workforce [§136]. Directional aspiration.

National commitment 17 — Biosafety: "Strengthen implementation of biosafety measures" (GBF Target 17). Two actions: ratification of the Nagoya-Kuala Lumpur Supplementary Protocol and revision of the Biosafety Act 2015, which prohibits all activities involving GMOs in reproducible form [§140]. Directional aspiration.

National commitment 18 — Harmful subsidies: "Strategic interventions on incentives are streamlined to safeguard biodiversity" (GBF Target 18). An assessment-first approach: no subsidies are yet identified as harmful; all four actions focus on assessment, prioritisation, and M&E framework development [§105]. Directional aspiration.

National commitment 19 — Finance mobilisation: "Resources to support implementation of NBSAP are mobilized" (GBF Target 19). Deadline: 2025. Actions include donor mapping, finance gap assessment, and developing a Resource Mobilisation Plan. No quantified funding target [§144]. Directional aspiration.

National commitment 20 — Capacity and technology: "Strengthen capacity building, promote technology transfer, and facilitate technical and scientific cooperation" (GBF Target 20). Received the highest priority score in the national consultation exercise. Supported by 13 targeted awareness programmes, 12 capacity-building interventions, and three scientific cooperation priorities [§146]. Directional aspiration.

Sources:

§57 — 1.8 Review of Past NBSAP
§80 — 2.2 Indirect Threats > A. Climate Change
§94 — 3.10 Access and Benefit Sharing
§98 — 3.14 Recognizing the Value of Ecosystem Services
§105 — 4.6 NBSAP Targets aligned with KMGBF
§108–§146 — 4.7 Target-specific Strategies and Actions

4. Delivery Architecture

Legislation

The Forest and Nature Conservation Act of Bhutan 2023 governs forest, wildlife, and natural resource protection [§42]. The Biodiversity Act of Bhutan 2022, with Rules and Regulations adopted in 2023, regulates access to genetic resources and traditional knowledge [§42][§94]. The Biosafety Act of Bhutan 2015 prohibits activities involving GMOs in reproducible form, aligned with the Cartagena Protocol [§42]. Supporting statutes cover water (2011), waste (2009), environment (2007), land (2007), livestock (2001), environmental assessment (2000), seeds (2000), pesticides (2000), and plant quarantine (1993) [§42].

Conservation Finance

The Bhutan Trust Fund for Environmental Conservation (BTFEC), established in 1992 with initial capitalisation of USD 21 million, is the world's first environmental endowment fund [§18][§56]. Bhutan for Life (BFL), launched in 2018 as Asia's first Project Finance for Permanence initiative, secures long-term funding for protected areas and community-based conservation [§18][§56]. A dedicated ABS Fund has been established under the Biodiversity Act framework [§94]. The NBSAP proposes diversifying financing through biodiversity bonds, carbon markets, green taxation, ecosystem service fees, and eco-tourism revenue models [§96].

Institutional Arrangements

Nine named policies provide the cross-sectoral framework, including the Food and Nutrition Security Policy (2023), Climate Change Policy (2020), Tourism Policy (2019, "High Value, Low Volume"), Economic Development Policy (2016, "Brand Bhutan"), ABS Policy (2015), National Forest Policy (2011), and Biosecurity Policy (2010) [§41]. Seven non-government organisations contribute to implementation, including the Royal Society for Protection of Nature (RSPN), WWF-Bhutan, and the Bhutan Ecological Society [§56]. Bhutan is party to 19 regional and international environmental agreements, including the CBD (1995), CITES (2002), the Nagoya Protocol (2013), and the Paris Agreement (2017) [§43].

Sources:

§18 — 1.2 Bhutan's Conservation History
§41 — Biodiversity Related Policies
§42 — Biodiversity Related Legislation
§43 — 1.6 International Cooperation
§56 — Non-Government Agencies
§94 — 3.10 Access and Benefit Sharing
§96 — 3.12 Funding for Biodiversity Conservation

Human-Wildlife Conflict and Coexistence

Human-wildlife conflict is a structural challenge woven through multiple national commitments and sources. Agriculture employs 41.7% of the workforce [§25], and farmers lose an estimated 19–43% of annual crop production to wildlife depending on proximity to forest edges, averaging approximately 30% [§78]. In 2023, the Department of Forests and Park Services recorded 233 HWC cases, with nearly half involving crop depredation by wild boars, monkeys, deer, elephants, bears, and tigers [§87].

The NBSAP addresses HWC through a dedicated sub-strategy under national commitment 4, with actions including updating the HWC hotspot map, developing holistic management plans for strategic hotspot areas, implementing innovative protection interventions, and instituting a crop and livestock insurance scheme at the national level [§114]. An index-based crop and livestock insurance scheme under national commitment 10 provides a parallel instrument [§126]. A One Health programme linking biodiversity conservation with human and animal health is to be strengthened [§114].

The underlying spatial dynamic is notable: the 2024 National Tiger Survey recorded more tigers outside protected areas than within [§108], meaning that coexistence rather than separation defines the management challenge. For a country where over 52% of territory is already protected, the frontier of conservation policy lies in the agricultural and settlement landscapes where people and wildlife share space.

Sources:

§25 — III. Agricultural Ecosystem
§78 — H. Human-Wildlife Conflict
§87 — 3.4 Human-Wildlife Co-existence
§108 — Target 1 Strategies and Actions
§114 — Target 4 Strategies and Actions
§126 — Target 10 Strategies and Actions

5. Monitoring and Accountability

The National Biodiversity Centre (NBC), designated as the National Focal Point under the Biodiversity Act 2022, coordinates NBSAP implementation [§151]. A National Coordination Committee, comprising heads of relevant stakeholder agencies with the NBC head as member secretary, will oversee implementation [§151]. A permanent NBSAP coordination, monitoring and evaluation unit is to be established at NBC, supported by a Technical Working Committee (TWC) with representation from lead agencies identified in the Division of Responsibility Framework [§151][§152].

The M&E framework (Annexure 4) outlines indicators for each action, with baseline data, targets, means of verification, and reporting frequencies [§153]. Evaluation reports are submitted to the National Coordination Committee for endorsement and serve as the basis for national reporting to the CBD [§153]. The Department of Environment and Climate Change (DECC), as the CBD National Focal Point, fulfils reporting obligations [§153]. The Clearing House Mechanism, housed within DECC, serves as the platform for updating NBSAP implementation status [§154].

The review of the previous NBSAP (2014) identified the absence of a formal national coordination mechanism as a key gap, resulting in "fragmented implementation across agencies" [§59]. Achievement scores ranged from 93.8% (ABS) to 35% (invasive alien species), with an average of 62.73% [§57]. The current NBSAP's institutional architecture — the National Coordination Committee, dedicated M&E unit, and Division of Responsibility Framework — addresses these findings directly.

Sources:

§57 — 1.8 Review of Past NBSAP
§59 — Weak Institutional Coordination and Governance
§151 — 5.1 National Coordination Mechanism
§152 — 5.2 Division of Responsibility Framework
§153 — 5.3 Monitoring, Evaluation and Reporting
§154 — 5.4 Clearing House Mechanism

6. Finance and Resource Mobilisation

Between 1980 and 2019, approximately 249 biodiversity conservation projects received funding totalling around USD 239.4 million [§96]. Two cornerstone institutions anchor conservation financing: BTFEC (1992, USD 21 million initial capitalisation) and Bhutan for Life (2018), described above [§18][§56].

Despite these foundations, a review of the previous NBSAP found that a dedicated BTFEC funding mechanism for NBSAP implementation "was never established," REDD+ strategies were formulated "without securing financial commitments," and Payment for Ecosystem Services was "piloted only in the water sector" [§67]. Bhutan's graduation from Least Developed Country status "poses future risks, as concessional financing and donor support may become increasingly limited" [§96].

The NBSAP contains no total budget or costed implementation plan. National commitment 19 commits to mobilising resources by 2025 but sets no quantified funding target. Actions include donor mapping, a biodiversity and environmental finance gap assessment, and developing a Resource Mobilisation Plan — under preparation and expected by end of 2025 [§144][§155]. Proposed innovative financing mechanisms include the Bhutan carbon market, biodiversity credits, wildlife credits, green bonds, PES, and bioprospecting [§144].

A preliminary study estimates ecosystem services at USD 15.5 billion annually (2013); no national update has followed [§36][§98]. The NBSAP notes that nature's contributions remain "underrepresented in GDP and national planning" [§98]. The SEEA implementation plan (2024–2029) is intended to address this gap.

Sources:

§18 — 1.2 Bhutan's Conservation History
§36 — 1.4 Values of Biodiversity and Ecosystems
§56 — Non-Government Agencies
§67 — Conservation Financing Deficiencies
§96 — 3.12 Funding for Biodiversity Conservation
§98 — 3.14 Recognizing the Value of Ecosystem Services
§144 — Target 19 Strategies and Actions
§155 — 5.5 Resource Mobilization

7. GBF Target Coverage

Target 1: Spatial planning — Addressed

National commitment 1 commits to planning and managing all areas to reduce biodiversity loss. Key instruments include updating the National Land Use Zoning system, incorporating spatial biodiversity data, SMART patrolling and river rangers for freshwater systems, and developing at least one river basin management plan. Management effectiveness of protected areas and OECMs is to be assessed via METT+. The 2024 National Tiger Survey's finding of more tigers outside protected areas than within directly motivates the spatial planning approach.

Target 2: Ecosystem restoration — Addressed

National commitment 2 sets a quantitative threshold: at least 10% of degraded areas under effective restoration by 2030. A multi-sectoral restoration committee is to be established, with rangeland explicitly included alongside other degraded areas. Baseline mapping of degraded areas is acknowledged as not yet complete.

Target 3: Protected areas (30×30) — Addressed

The NBSAP does not set a standalone 30×30 commitment because Bhutan's protected area network already covers 52% of national territory, and the Constitution mandates at least 60% forest cover in perpetuity. Actions under national commitment 1 focus on updating management plans for protected areas and OECMs and assessing management effectiveness. Bhutan for Life secures long-term protected area funding. Three Ramsar sites collectively cover approximately 1,225 hectares.

Target 4: Species recovery — Addressed

National commitment 4 covers threatened species conservation, genetic diversity, and human-wildlife conflict under three sub-strategies. Actions include updating the National Red List (which does not yet exist), developing species-specific conservation action plans for at least two threatened species, and strengthening the White-bellied Heron conservation breeding programme. The National Plant Genebank holds 429 rice landraces, 151 maize, 86 finger millet, and 62 sweet buckwheat accessions. Approximately 230 crop wild relative species are documented.

Target 5: Sustainable harvest — Addressed

National commitment 5 addresses safe and legal harvesting of wild species, with specific attention to species used in traditional medicine (Sowa Rigpa). Actions include resource assessments, domestication trials, amendment of the FNCRR 2023, and community-based management plans. Forestry offences totalled 1,318 in 2023.

Target 6: Invasive alien species — Addressed

National commitment 6 commits to managing IAS to minimise impacts. The NBSAP documents 136 alien plant species, with nine on the world's 100 worst list, and five alien fish species in the Amochhu River. Actions focus on legislative review, SOPs for pathway management, research, and database maintenance. No quantified reduction target is set. The previous NBSAP scored 35% on this target — the lowest of all.

Target 7: Pollution reduction — Addressed

National commitment 7 addresses pollution through identifying major biodiversity-affecting pollutants, updating Environmental Standards 2020, annual compliance monitoring, and waste facility gap assessments. Solid waste generation averages 172 metric tonnes per day. No quantified reduction targets for nutrients, pesticides, or plastics are set.

Target 8: Climate and biodiversity — Addressed

National commitment 8 addresses climate impacts on mountain biodiversity specifically. Actions include research on treeline advance and high-altitude disease vectors, at least one international symposium, afforestation and reforestation programmes, and forest fire prevention. Regional and international collaborations for climate financing, carbon trading, and REDD+ are also identified.

Target 9: Wild species use — Mentioned

GBF Target 9 does not have a standalone national commitment but is partially addressed through national commitment 5, which the NBSAP maps to both GBF Targets 5 and 9. Actions relevant to Target 9 include resource assessments of economically important wild species used in Sowa Rigpa and community-based management plans for sustainable harvesting. The NBSAP does not specifically frame actions around benefits for vulnerable populations as Target 9 envisions.

Target 10: Agriculture / forestry — Addressed

National commitment 10 is the most action-dense, with 18 actions spanning agriculture, livestock, forestry, and fisheries. Instruments include Sustainable Land Management, Good Agricultural Practices guidelines, precision livestock farming, index-based crop and livestock insurance, the Agromet Decision Support System, management plans for Community Forests and Forest Management Units, and community-based fisheries programmes.

Target 11: Ecosystem services (NbS) — Addressed

National commitment 11 commits to at least two nature-based solutions and implementation of the SEEA (2024–2029) to mainstream ecosystem service values into national accounting. Soil microbe isolation for biofertiliser production is included as an NbS action.

Target 12: Urban biodiversity — Addressed

National commitment 12 commits to green and blue spaces in Thromdes, the City Biodiversity Index in at least two municipalities, Building Code revision, and an inventory of existing urban green and blue spaces. The Gelephu Mindfulness City is cited as a model for biodiversity-inclusive urban design.

Target 13: Genetic resources / ABS — Addressed

National commitment 13 addresses benefit-sharing from genetic resources, DSI, and traditional knowledge. Bhutan has executed 14 ABS agreements leading to 14 products — the highest-scoring target (93.8%) in the previous NBSAP review. New instruments include a Bhutan ABS Clearing House Mechanism, branding and certification of bioprospecting products, and strategies for both the ABS Fund and traditional knowledge protection. DSI is mentioned in the target text but governance mechanisms are not elaborated.

Target 14: Mainstreaming — Addressed

National commitment 14 commits to endorsing the NBSAP as the national guiding document, sector-specific workshops, and aligning NDC 3.0 with the NBSAP. The SEEA implementation under national commitment 11 and Building Code revision under national commitment 12 also contribute.

Target 15: Business disclosure — Mentioned

The NBSAP maps national commitment 16 to both GBF Targets 15 and 16 in its Annexure, but the content addresses sustainable consumption and waste reduction, not business disclosure or reporting requirements. A targeted private sector consultation was held in Phuentsholing in March 2025, but no strategies or actions require businesses to assess, disclose, or reduce biodiversity-related risks.

Target 16: Sustainable consumption — Addressed

National commitment 16 commits to promoting sustainable consumption and production through Extended Producer Responsibility, Public-Private Partnerships in waste management, and R&D on waste reduction technologies. No quantified food waste reduction target is set.

Target 17: Biosafety — Addressed

National commitment 17 commits to ratification of the Nagoya-Kuala Lumpur Supplementary Protocol and revision of the Biosafety Act 2015. The Act currently prohibits all activities involving GMOs in reproducible form. This commitment contains two actions — the fewest of any national commitment.

Target 18: Harmful subsidies — Addressed

National commitment 18 takes an assessment-first approach: no subsidies are yet identified as harmful. Actions focus on a comprehensive impact assessment, identification and prioritisation of adverse incentives, assessment of at least one prioritised subsidy, and developing an M&E framework for tracking subsidy impacts over time.

Target 19: Finance mobilisation — Addressed

National commitment 19 carries a 2025 deadline — the earliest of all commitments. Actions include donor mapping, a biodiversity and environmental finance gap assessment, and developing a Resource Mobilisation Plan. No quantified funding target is set. The NBSAP proposes diversified financing through the Bhutan carbon market, biodiversity credits, wildlife credits, green bonds, PES, and bioprospecting. LDC graduation is identified as a risk to concessional financing access.

Target 20: Capacity and technology — Addressed

National commitment 20 received the highest priority score in the national consultation exercise. It is supported by 13 targeted awareness programmes, 12 capacity-building interventions (including CRISPR-Cas9 technology training), and three scientific cooperation priorities. A technology hub for information exchange and institutional partnerships in the region are planned.

Target 21: Data and information — Addressed

National commitment 9 commits to establishing a national GBIF node, upgrading the Bhutan Biodiversity Portal as a centralised multi-platform data repository, updating Bhutan Biodiversity Statistics, and developing SOPs for data management. Data fragmentation across institutions is identified as the key challenge.

Target 22: Inclusive participation — Addressed

National commitment 3 commits to developing guidelines for inclusive participation across diverse genders and groups, and establishing a monitoring mechanism for participation in biodiversity-related decision-making. The NBSAP itself was developed through consultations across all 20 Dzongkhags.

Target 23: Gender equality — Addressed

National commitment 15 — introduced for the first time in this NBSAP edition — commits to a full cycle of gender analysis, action plan development, implementation, and assessment. Women constitute 73.6% of the rural workforce and 52.5% of the agricultural workforce. The National Gender Equality Policy 2020 provides the existing policy foundation.