1. What is an Environmental Compensation Plan and who does the 2026 Manual apply to?
The Environmental Compensation Plan is the instrument through which the holder of an environmental license defines how it will compensate the impacts caused by its project on the biotic environment: flora, fauna, vegetation cover and landscape context. It is not a mitigation measure or a restoration measure for the impacted area. It is an additional compensatory obligation to be implemented in ecologically equivalent areas.
The 2026 Manual, adopted through Resolution 0305, applies mandatorily to:
Holders of projects, works or activities subject to environmental licensing before ANLA or the Regional Environmental Authorities.
Holders of single-use forest harvesting permits for natural forests.
Projects requiring temporary or permanent removal of areas from national or regional forest reserve status.
2026 update: the Manual also incorporates single-use forest harvesting permits for protective forest plantations and protective-productive forest plantations, a category that was not included in the 2018 Manual.
2. Key changes compared to the 2018 Manual
The 2026 Manual is not a cosmetic revision of the previous one. It introduces technical and procedural changes that directly affect how the Compensation Plan is designed, approved and implemented. These are the most relevant changes for environmental license holders.
2.1 Economic equivalencies are now allowed in large urban centers
The 2018 Manual expressly prohibited economic equivalencies as a compensation mechanism. The 2026 Manual expressly allows them, provided they correspond to compensations subject to evaluation and approval by the environmental authorities of large urban centers, such as DAGMA, DADEP or District and Municipal Environmental Secretariats.
This creates a practical alternative for projects located in urban contexts where the availability of ecologically equivalent areas is limited.
2.2 Six geographic ranges to define where compensation must be implemented
The 2018 Manual established two levels of geographic prioritization: the hydrographic subzone and the hydrographic zone where the project is developed. The 2026 Manual expands this to six geographic ranges with progressive additional factors:
|
Geographic range |
Additional factor |
|
1. Project area of influence |
Compensation Factor —CF— without addition |
|
2. Project hydrographic subzone |
CF + 0.3 |
|
3. Project hydrographic zone |
CF + 0.6 |
|
4. Area of influence, different biome |
CF + 0.9 |
|
5. Hydrographic subzone, different biome |
CF + 0.9 |
|
6. Protected areas within the national territory |
CF + 1.2 |
The logic is clear: the farther the compensation is from the impacted area, the more hectares must be compensated. The license holder has an incentive to identify ecologically equivalent areas within its own area of influence before seeking alternatives in more distant hydrographic zones.
2.3 Early implementation of the Compensation Plan
The 2026 Manual introduces the concept of early implementation, allowing the license holder to propose the partial or total implementation of the hectares to be compensated before the impact occurs, provided the full plan has been approved when the environmental instrument is granted or modified.
This is especially useful for projects with tight construction schedules, as it allows compensation activities to be advanced before ANLA requires them to be reported in the ICA.
2.4 New mandatory content for the Compensation Plan
The plan must now be much more detailed. In addition to defining what, how much, where and how compensation will be implemented, the 2026 Manual requires:
Compensation zoning at a scale of 1:25,000 or more detailed, identifying the potential supply of ecologically equivalent areas and the possible application of compensation actions in each area.
An additionality analysis, comparing the current scenario of the compensation area with the projected scenario once compensation measures are implemented.
Community participation support, with evidence that the communities located in the project’s area of influence were informed and participated in the definition of the plan.
2.5 The authority approves the zoning, not the individual properties
The 2026 Manual clarifies an issue that often created confusion in practice: ANLA and the Regional Environmental Authorities approve the potential compensation zoning, not specific properties.
This means that the license holder has flexibility to select specific properties within the approved zoning, without needing a new approval for each property, as long as the selected areas remain within the authorized geographic zone and ecosystem.
2.6 New grounds for modifying the Compensation Plan
The 2018 Manual established three modification scenarios: change of property, change of term up to 30%, and change of actions. The 2026 Manual redefines the cases that require a decision by the environmental authority:
Change in the compensation zoning approved in the environmental instrument.
Change in the plan’s objectives, goals and indicators.
Change in the total implementation term of the plan.
Important: the authority now has a maximum term of two months to decide on modification requests, reducing uncertainty for the license holder when planning project schedules.
3. How the Compensation Plan connects with the PMA and the ICA
The Compensation Plan does not exist in isolation. It must be integrated with two other environmental management instruments that the license holder must manage consistently.
Environmental Management Plan —PMA—
The PMA defines the measures for the prevention, mitigation, correction and compensation of project impacts. The Compensation Plan is the compensatory component of the PMA for impacts on the biotic environment.
Both instruments must be consistent in their goals and schedules. For example, if the PMA establishes that compensation begins in year two of the project, the Compensation Plan must have identified properties and approved zoning before that date.
Environmental Compliance Report —ICA—
The ICA is the periodic reporting mechanism submitted to the environmental authority regarding compliance with the obligations established in the environmental license, including compensation obligations.
Under the 2026 Manual, the license holder must report in each ICA:
Progress in the implementation of the plan, comparing compensated hectares against committed hectares.
The status of approved zoning and properties under negotiation or implementation.
Compliance with the additionality analysis and community participation requirements.
Delayed compensation implementation against the approved schedule is one of the most frequent observations made by ANLA when reviewing ICAs.
Corporación Bioparque, through its platform www.informesverdes.com, specialized in the preparation of Environmental Compliance Reports —ICA—, presents a complementary analysis of the new 2026 Compensation Manual.
4. Most frequent errors in the implementation of the Compensation Plan
Corporación Bioparque’s experience advising environmental license holders shows that compensation problems usually arise not during the formulation of the plan, but during its implementation. These are the errors that most frequently generate observations from environmental authorities:
Outdated compensation zoning. The plan was approved with zoning that no longer reflects the current status of the territory: properties may have changed ownership, vegetation cover may have changed or areas may have been declared protected. Zoning must remain current throughout project implementation.
Compensation schedules disconnected from construction schedules. Compensation is often scheduled for the end of the project, even when the obligation may arise from the first phases of forest intervention. This generates non-compliance in the first ICA reporting periods.
Lack of additionality analysis. Under the 2026 Manual, this analysis is mandatory. License holders that formulated their plans under the 2018 Manual and have not updated them may be reporting compensation without this component, which may be observed by the authority.
Selection of areas without documented community participation. The new Manual requires participation support. License holders that select compensation properties without this documentation are exposed to objections from communities in the area of influence.
Confusing restoration of the impacted area with compensation. Restoration of the area affected by the project is a PMA obligation. Compensation is an additional obligation to be implemented in different areas. Reporting restoration of the project area as compensation is an error that ANLA detects and observes.
5. Illustrative cases by project type
Mining project — permanent removal from forest reserve status
A mining project with the permanent removal of 120 hectares from forest reserve status had to compensate within the same reserve. Under the 2026 Manual, the authority requires compensation for permanent removal to be implemented within the same forest reserve from which the area was removed, except in exceptional cases.
The license holder identified degraded areas within the reserve and proposed beginning implementation under the early implementation mechanism before construction started. This allowed the project to report compensation progress from the first ICA.
Road infrastructure project — compensation in an urban area
An urban road project requiring tree removal and impacts on vegetation cover in a metropolitan area had no ecologically equivalent areas available within its area of influence.
Under the 2018 Manual, this situation did not have a clear solution. Under the 2026 Manual, the urban environmental authority may approve an economic equivalency to finance the restoration of a connectivity corridor defined by the authority, with monitoring indicators incorporated into the annual ICA.
6. Concrete steps for license holders with plans approved under the 2018 Manual
If your project has a Compensation Plan approved under the 2018 Manual, these are the actions you should evaluate before submitting your next ICA:
Review whether the approved compensation zoning meets the level of detail required by the 2026 Manual, at a scale of 1:25,000 or more detailed. If it does not, manage the update before the authority.
Verify whether the plan includes an additionality analysis. If not, incorporate it in the next update of the plan or in the next ICA as a technical annex.
Review the plan’s implementation schedules against the actual project execution schedule. Identify whether there is a risk of non-compliance in the next reporting period.
Document community participation in the selection and management of compensation areas. If this documentation does not exist or is incomplete, begin the engagement process and keep formal records.
Evaluate whether the early implementation mechanism applies to your project and whether it is convenient to propose compensation progress before the originally approved deadlines.
If your project has compensation obligations due to removal from forest reserve status, verify that the selected areas are located within the same reserve, as required by the 2026 Manual.
Corporación Bioparque supports environmental license holders in the formulation, update and implementation of Compensation Plans under the 2026 Manual, as well as in the preparation of Environmental Compliance Reports —ICA— with the technical support required by ANLA and the Regional Environmental Authorities.
Contact us at corporacionbioparque.org for an initial review of your current Compensation Plan.