A guide to staying SFI compliant
Unlike more rigid support schemes of the past, the Sustainable Farming Incentive (SFI) is all about giving farmers greater flexibility to make actions work for their farm, while simultaneously delivering the public goods at the heart of the scheme.
A more supportive and pragmatic approach to compliance is promised, working with farmers to resolve issues, rather than punishing breaches with hefty fines.
However, farmers still have to prove compliance with the rules and the delivery of the SFI aims.
See also: Will vet assurance shake up third-party audits?
“Fundamentally, it is a public good scheme, so it’s perfectly reasonable the government will want to see evidence that what they’re paying farmers to do is being achieved,” says the Farm Consultancy Group’s Holly Greenman.
SFI compliance key points
- SFI agreements are managed online by the RPA
- Claimants must complete an annual declaration confirming SFI actions have been completed. The declaration is needed to release the final payment for that year
- Each SFI action has its own record-keeping requirements (see SFI handbook)
- Understand the aims of individual SFI actions to help determine what evidence to keep
- If a site visit is requested, farmers must provide their SFI agreement document and any records to show how each action has been completed, including receipts, invoices, pictures or other information, sorted by date
Less prescriptive
While schemes such as Countryside Stewardship (CS) had very clear guidance about what was required, by when, and what records to keep, the SFI is far less prescriptive.
Official guidance for many options simply states evidence “could include photographs and other documentation to show what you’ve done to complete this action”.
This openness can be both good and bad, Holly says.
“In one way, it’s great because more decisions are left to farmers, but equally, it’s harder to know you are doing everything properly when the guidance is left very open.”
For SFI options that are similar to the old CS, such as low input grassland or winter bird mixes, similar records are likely to be needed, says Holly.
“Beyond that, the key is to examine the aims of each SFI option carefully and decide what evidence and records you can keep to show you understand, and are achieving, those aims.
“Ultimately, are you confident that what you are proposing/doing can reliably meet the aims?”
Record keeping
Physical records, either hard copies or digital versions, to demonstrate key activities and impacts throughout the duration of the SFI agreement are vital.
This could include maps showing the location of options, invoices for seed or other inputs, contractor invoices, or stock records showing how many animals have grazed certain fields and when they were moved on and off.
Evie Price, head of stewardship and grants at compliance specialist CXCS, says that as with other capital grants, evidence must be kept for seven years from the SFI agreement’s end date, so up to a total of 10 years for a three-year agreement.
“That’s potentially a lot of information to gather and store, so it really pays to have an organised system in place.
“This requires time, but makes life easier in the long-run, especially if you have to go back and find information several years later.”
Recording everything digitally may be preferred to paper hard copies, but again systems and the organisation of digital folders still needs to be carefully thought through.
Specialist farm management packages can help do this, but a simple spreadsheet where you can record actions, dates, field observations, and so on is a good starting point, she says.
Another simple tool is to keep an SFI diary/calendar, to plan when specific tasks need to be done by, and note once completed, adds Holly.
“Any evidence you keep should be dated,” she says.
Digital photographs can often be date stamped and geotagged automatically, but another option is to share images via WhatsApp, which records the message date.
Take photos
Photographs taken at key stages through the duration of any option are valuable, and Defra offers guidance for taking and labelling photographs (see Annex A of the SFI Handbook).
For an option such as the multispecies winter cover (CSAM2), for example, farmers could take pictures of drilling, cover emerging, established plants over winter, and termination of the cover, along with a photo of the seed label.
Although not specifically required, it may also be worth photographing any bird species or other wildlife using the cover throughout the season, to help show it is delivering environmental benefits, and reinforce your awareness of the scheme’s objectives, Evie suggests.
It is also worth recording and photographing any particular problems, such as a seed mix or ley failing to establish, and the causes if possible (for example, waterlogged soil or pests).
“Under most options, you have the first 12 months to establish them, but some, such as winter birdseed, need to be established at a certain time, so if there is a problem that means you miss this establishment window, you need to notify the RPA [Rural Payments Agency] sooner rather than later to plan the best way forward.”
Map features
Mapping SFI options, ideally digitally, is valuable in demonstrating compliance and can help manage those options.
“Under previous Mid and Higher Tier stewardship schemes, farmers had to create environmental maps as part of the application process.
“It’s not mandatory for SFI, but the RPA does supply blank maps as part of the application, so it’s worth using those, or other maps, to record the locations of everything you’re doing,” says Evie.
“Maps are particularly useful for all hedgerow options, to provide a visual record of exactly where the hedges and/or hedgerow trees are that you are claiming for.”
She also recommends mapping to record location changes in any rotational SFI options from season-to-season to ensure compliance by maintaining the correct area of those options.
“The RPA recently updated guidance to state there will now be a rotational actions declaration, requiring agreement holders to show the locations of rotational options.”
Recording for the future
The amount of information farmers record will be down to personal preference, time and resources.
Collecting extra information now may seem unnecessary, but it could build a useful database should scheme requirements change, particularly if more focus is put on proving environmental benefits (for example, to wildlife, soils, carbon sequestration, and so on).
“Keeping good evidence is even more important given that the SFI is very flexible, so it makes sense to be well prepared with as thorough records as possible,” says Holly.
She advises considering the time needed for record-keeping and admin as another cost associated with each option, but says even when this is fully factored in, the costs are still outweighed by the returns.
An SFI management payment towards admin costs is available, at £40/ha in the first year for the first 50ha, reducing to £20/ha in subsequent years.
What are the consequences of non-compliance?
Defra can check compliance in various ways, including:
- Administrative checks on the nature and quality of supporting evidence
- Site visits (physical or by video call)
- Remote monitoring – for example, aerial photography and satellite imagery to monitor ground-cover, vegetation and soil erosion
- Checks on evidence supplied, such as a soil management plan or soil organic matter test results
- Reviewing the annual declaration
Defra field officers will offer advice and guidance to help resolve non-compliance issues where possible.
Where a breach is suspected, payments will not usually be withheld during investigation.
If non-compliance is confirmed, the action taken will depend on its nature and severity.
A resolution to meet scheme requirements may be suggested.
For more serious breaches, farmers may need to repay some or all of the money paid for the relevant agreement year.
Unlike previous schemes, no additional penalties will be applied.
Consequences could be more severe if the breach was intentional, negligent or reckless, or has happened more than once without good reason.
Example records to keep for popular SFI options |
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Winter bird food (CAHL2) or pollen and nectar (P&N) mix (CAHL1) |
Herbal leys (CSAM3) |
Hedgerow management options (CHRW 1-3) |
Copy of seed invoice and bag label |
Pictures of site preparation and drilling |
Map showing the location of hedges and relevant trees |
Pictures of site preparation and drilling |
Copies of relevant invoices (for example, seed, contractor work, etc) |
Note length, width and any large gaps – not essential for CHRW2 and CHRW3, but may be useful for future |
Invoices for contracting work |
Pictures of established ley, different species and areas of flowering plants in summer |
Record dates of cutting or other management |
Written record showing dates of key activities – for example, drilling, termination |
Stock grazing records, showing type and number of stock grazed, and dates moved on and off |
Photograph hedges and any notable features – note location of pictures on a map |
Pictures of established plants (for example, during flowering for P&N mixes, or winter seed heads of bird food) |
Field records showing inputs applied (if any) – utilise nutrient/ soil management plans |
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Pictures of birds, insects or other wildlife using the cover |
Note any benefits to soil health – for example, visual soil assessments or other tests |
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Map showing location and area of cover – use to identify location of any pictures |
Map showing location and area covered – also use to identify location of pictures or soil tests |
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