Photo by Arnaud Mariat
First Minister John Swinney used the Programme for Government 2026 to 2031, published on 1 September, to confirm plans to fold several of Scotland’s environmental regulators into a single body, prompting swift but carefully worded responses from the organisations affected, and sharper questions from MSPs and unions in the days since.
A single environment body
Setting out the Programme to Holyrood, Swinney described the coming five years as “the most radical reshaping of public services since the establishment of the Scottish Parliament”, arguing the public sector must ask what the needs of citizens are rather than defaulting to existing structures and systems. He confirmed that the Scottish Environment Protection Agency, NatureScot, Zero Waste Scotland and potentially Scottish Forestry will be brought together into a single overarching environment body, telling MSPs the aim was to remove unnecessary barriers and make environmental interventions more impactful. The Programme did not specify which functions of each body will carry over, and Swinney indicated other relevant organisations could be drawn in as proposals develop. He framed the wider reform effort around a simple principle: “No problem in Scotland is solved by one public body, or one policy choice.”
SEPA confirmed the proposal in a statement to staff issued the same afternoon, with chief executive Nicole Paterson saying the agency was “committed to working with Scottish Government and the other national bodies” as the new body is developed over the coming months, while continuing to support staff through the transition. Water Magazine’s report on the statement noted that SEPA had already been working towards strategic transformation in line with the government’s reform ambitions, and that further detail on the structure and operation of the proposed body had yet to be set out. SEPA chair Lisa Tennant, meanwhile, pointed to the agency’s three decades of service and pledged to work with government and fellow board chairs to protect service quality while the reforms are taken forward.
Zero Waste Scotland gave a fuller account of the mechanics in its own statement, describing the new organisation as one designed to integrate the expertise and authority of its constituent parts to deliver better outcomes for people, nature and the economy. Chief executive Ciaran McGuigan said the organisation “recognises and supports the principle of Public Service Reform in Scotland”, adding that its work on the circular economy would continue at pace with the full support of the Scottish Government while the new body is consulted on and built. Board chair Dominic Fry acknowledged that structures may change but argued the underlying task, building a circular economy that supports climate resilience, remains constant, and said the board was committed to helping shape the new organisation alongside its “sister organisations”. For Zero Waste Scotland, which only completed its own transition from company to executive non-departmental public body in April 2025, the merger represents a second major reorganisation in as many years.
Costs, jobs and questions of scale
By the time the three chief executives appeared before Holyrood’s climate action committee two days later, the tone had sharpened. NatureScot’s chief executive Nick Halfhide told MSPs his organisation was preparing for transition but stressed it was “very early days”, with a great deal of planning still to do. He said the 2029 timeline for the new body was aspirational, and that resourcing the change properly, both for the mechanics of the merger and for staff going through it, would matter as much as hitting the date, adding: “To state the obvious, we want this to be a huge success.” He also flagged that funding would be needed from the Scottish Government to deliver the merger, despite savings being the driving rationale behind it.
Paterson told the same committee that a single environmental body could make protections more impactful and strengthen environmental delivery, and said the response from SEPA’s roughly 1,250 staff had, in her early impression, landed better than she had anticipated, while acknowledging each individual would need to make their own decision about their future. McGuigan told MSPs that Zero Waste Scotland would strongly support the reforms but was candid about the uncertainty over the new body’s exact shape and what it would mean for individuals, warning that the execution challenges involved in change of this scale would be real. Trade unions have reacted with anger, warning that jobs are likely to be cut as the merger proceeds, according to the Scotsman’s report on the committee session.
The backdrop is a Scottish Government budget shortfall approaching £5 billion by the end of the decade. Swinney has repeated his commitment to no compulsory redundancies, while accepting that public sector headcount, including among more senior civil servants, will need to fall. Stephen Boyd, director of IPPR Scotland, cautioned MSPs on the Public Service Reform Committee that public service reform is likely to be the defining issue of this Parliament, but warned that expectations of what consolidating public bodies can achieve can be “wildly optimistic“.
Part of a wider reform wave
The environment merger sits within a much broader restructuring exercise. As BBC Scotland’s political editor Glenn Campbell has noted, the Programme also envisages replacing Scotland’s 14 territorial health boards with two, a possible single cultural body, and a push towards regional public service delivery built on models like the Glasgow City Region, alongside a reduction in the number of Scotland’s 32 local authorities. Swinney has argued some councils are “too small to be strategic” and others too big to be local, and has set a three-month timetable for talks with local government on the shape of reform ahead of the Scottish budget. The Programme also proposes folding the Scottish Food Commission and the Scottish Pubs Code Adjudicator into Food Standards Scotland while maintaining their independent scrutiny functions, and commits the government to reviewing all remaining public bodies not otherwise mentioned for efficiency and potential merger.
Unfinished circular economy business
The timing raises practical questions for work already under way. Zero Waste Scotland’s Circular Economy Strategy, published in March 2026, named five priority sectors and gave the organisation a year to produce a roadmap for each, overseen by industry mission boards over a five-year delivery period; roadmaps for the built environment and energy infrastructure have already been published, with bioeconomy and textiles due in 2027. That work, along with ministers’ commitments to set national circular economy targets, establish a Deposit Return Scheme for drinks containers, and introduce a new statutory code of practice for household waste recycling, depends on capacity currently split between Zero Waste Scotland and SEPA, and will now need to be carried through a reorganisation whose scope remains undefined.
Marine and coastal commitments in the wider Programme
Beyond the institutional reshuffle, the climate and nature chapter of the Programme contains several commitments of direct relevance to marine policy. The government has pledged to consult on fisheries management measures for inshore marine protected areas and priority marine features during 2026-27, and to establish a Scottish Marine Recovery Fund alongside a strategic environmental compensation mechanism intended to secure investment in the marine environment while helping to speed up offshore wind deployment. A further £14 million is earmarked for a Coastal Change Adaptation fund by the end of the Parliament, to help local authorities plan for rising sea levels and publish coastal adaptation plans, on top of an additional £15 million for flood mitigation more broadly.
Food campaigners see a gap
Not every response to the Programme was as measured. Nourish Scotland, the food justice charity, published a pointed critique arguing that food and farming had barely featured. In a blog post titled “Do not look for the Good Food Nation, for it is not there,” policy officer Anna Chworow wrote that readers would need a big magnifying glass to find any meaningful proposals for food. She welcomed the expansion of free school meals and a new national breakfast club offer from August 2027, but criticised what she called business as usual for agriculture and fishing, noting only a plan to consult on marine protected areas and priority marine features on the fisheries side. She also flagged the incorporation of the Scottish Food Commission into Food Standards Scotland as a demotion for the watchdog before it had properly begun its work.
What happens next
For the marine sector, the practical question is less about the headline pledges than about how regulatory continuity will be maintained while SEPA, NatureScot and Zero Waste Scotland are consolidated, with staff at all three organisations now waiting to see how consultation on the new body’s design, due later this autumn, translates into detail on functions, jobs and cost.