The Church of England’s largest investment body, the Church Commissioners, manages a portfolio worth £11.1 billion. This includes 108,000 acres of  English land, making it one of the largest landowners in the country. Over 82,000 acres of this land (around 76%) is farmland, most of it farmed commercially. (Of the rest, 21% is forestry, 3% is urban e.g. 1,300 residential and commercial properties in the Hyde Park Estate)

More than 100,000 people have now joined our call for the Commissioners to protect at least 30% of their land for nature by 2030, in line with the UK Government and the United Nations’ biodiversity targets.

For many, this isn’t just about land use; it’s a spiritual and moral issue. As Reverend Dr Clara Rushbrook has argued, Christians are called to care for creation. The Church has an opportunity and a responsibility to lead by example. Supporting tenant farmers to restore habitats and biodiversity is one way to live out this calling. But it’s also a way to protect the Church’s future financially and reputationally.

In this article, we explain four key risks the Church Commissioners face if they fail to meet 30×30, and what they can do to avoid them.

1. Missed financial opportunities

Much of the Commissioners’ farmland is dedicated to commercial agriculture, which is essentially farming for profit. But in today’s world, that’s becoming increasingly hard to sustain. Rising costs, changing subsidy systems, climate instability, and labour shortages have made traditional farming less profitable and more precarious.

That’s why a growing number of farmers are leading the way in the rewilding movement. The shift toward nature-based land management is not just environmentally sound – it can also boost farm incomes. For example, the Knepp Estate now makes an annual profit of £190,000 through nature-based tourism, conservation payments, and low-impact food production. Wild Ken Hill increased its income by 40% after rewilding 500 acres of arable land. 

A 2022 report from Savills (who act as local land agent for the Church Commissioners) reports that under certain schemes, rewilding could generate £562 per hectare per year, compared to £363 for an arable contract and £263 under a standard farm business tenancy.Yet the Church Commissioners, unlike the Crown Estate, have not announced any support for tenants wishing to explore rewilding or other regenerative practices. Nor have they publicly analysed the potential income benefit of rewilding 30% of their land. We encourage them to do so. They may find that rewilding isn’t just compatible with their investment and financial sustainability goals – it could enhance them.

2. Declining long-term land value

Biodiversity loss isn’t just a crisis for nature. It’s also a crisis for farming. Commercial agriculture, which dominates the Church Commissioners’ portfolio, is one of the leading drivers of biodiversity loss in the UK. It contributes to soil degradation, pollinator decline, water pollution, and the destruction of habitats that many species – and farming itself – depend on.

Despite producing food, farming is also one of the industries most vulnerable to biodiversity collapse.The UK Government’s 2024 Food Security Report states:

“The long-term decline in the UK’s natural capital is a pressing risk to UK food production… Climate change, nature loss and water insecurity pose significant risks to the ability of global food production to meet demand over the longer term.”

Similarly, the UN’s global report on Biodiversity for Food and Agriculture warns that:

“Biodiversity is indispensable to food security…” and: “Many key components of biodiversity… are in decline.”

Savills (who, as mentioned earlier, work as local agents for the Church Commissioners), recently wrote:

“The degradation of biodiversity poses significant risks to rural businesses, while opportunities lie in the provision of essential services and economic growth.”

In other words, without nature, there is no food. And without resilient ecosystems, the Church Commissioners’ farmland may become less productive and, ultimately, less valuable.

The Commissioners themselves recognise this in their approach to responsible investment:

“The Church Commissioners is dependent on social and environmental stability over the long term… climate change, nature and biodiversity loss and social inequality… are already being felt today.”

Supporting tenants to rewild not only diversifies income, it helps protect the underlying natural systems that farmland, and its market value, depend on.

3. Legal and policy non-compliance

The UK Government and UN have formally committed to the 30×30 pledge: to protect 30% of land and sea for nature by 2030. This commitment is enshrined in law through the Environment Act and reflected in national biodiversity frameworks.

Yet the Church Commissioners have declined to set out a pathway to meet this target… even after over 100,000 people urged them to act.

If UK policy evolves – as it likely will – to require large landowners to comply, the Church risks having to retrofit a strategy under pressure, rather than design a plan that works with and for their tenants proactively. 

Meanwhile, frameworks like the Taskforce on Nature-related Financial Disclosures (TNFD) and scrutiny from financial institutions such as the Bank of England are increasingly identifying biodiversity loss as a material financial risk.

Institutions that cannot demonstrate progress on biodiversity may fall behind on ESG benchmarks, fiduciary expectations, and investor confidence. The longer the Commissioners delay, the greater the risk of being out of step with emerging financial norms.

4. Reputational damage

The Commissioners’ own principles claim to be guided by the Fifth Mark of Mission:

“To strive to safeguard the integrity of creation, and sustain and renew the life of the earth.”

They’ve set goals for net zero and deforestation. But curiously, their statements say little about biodiversity protection on their vast landholdings.

This is not due to ignorance. As Bishop Graham Usher, the Church’s Bishop for Environment, told General Synod in 2024:

 “We are all too aware that this single island planet home of ours faces the twin interrelated crises of climate change and biodiversity loss […] We are one of the most nature-depleted countries in the world […] We need to act now to help the diversity of life on this single island planet home we share.”

In the same year Bishop Graham told BBC News that the Church could not expect others to enhance biodiversity if it did not do the same.

Christians across the UK are taking action on the environment. But these efforts are undermined if the Church’s own investment body is seen to be dragging its feet.

Other major landowners such as the National Trust, Crown Estate, Wildlife Trusts, and private estates are stepping up. The Church should be leading too. If not, it risks falling out of sync with its own values, congregations, and the public.

What the Church Commissioners should do

This is not a call for financial sacrifice. It’s a call for alignment with the Church Commissioners’ own values, mission, public statements, wishes of Church members, and UN and government requirements. We urge the Church Commissioners to:

Finally, we often get asked: can the Church Commissioners afford to rewild? There are longer answers to this, which we will come to publish soon. However, the short answer is: If farms that are losing money every year can rewild (and make more money doing so), then those with an £11billion (and ever-growing) investment fund which returns around 10% each year certainly can too. And as discussed, it could make them even richer than they already are.

As ever, we remain keen to collaborate with the Church Commissioners, and welcome the opportunity to discuss any of this further, should they or their investment or sustainability teams be interested to explore this.