Environmental Defenders Office welcomes the opportunity to comment on the Draft Biodiversity Conservation Amendment (Biodiversity Offset Scheme) Regulation 2026 and accompanying Consultation Paper dated June 2026. Changes made by the Biodiversity Conservation Amendment (Biodiversity Offsets Scheme) Act 2024 and proposed in the draft Regulation have, generally, sought to address concerns about the scheme, including in relation to its operation in practice, and its ability to deliver biodiversity offsets that deliver genuine outcomes for the environment. In general, EDO supports many of the changes that have been made or proposed.  However, despite the recent amendments, we have ongoing concerns about the overreliance on biodiversity offsets generally, particularly where there is a risk that biodiversity offsets will not adequately compensate for the impacts of development and drive further ecological decline. Our submission discusses key areas of ongoing concern, indicates proposals we support and makes recommendations for the draft Regulation to further strengthen the Biodiversity Offsets Scheme.