In June 2025, the Secretary of State issued updated guidance for the Environment Agency (EA) on how to regulate the Farming Rules for Water (FRfW). While the rules themselves have not changed, the guidance sets out how the EA will interpret, monitor and enforce them over the coming years. The revised approach tightens expectations around matching fertiliser and manure applications to genuine crop and soil need. The guidance is due for review by September 2028 at the latest.
Crop & soil need
Under the updated interpretation, any application of fertiliser or organic manure must be supported by a clear crop and soil need. The RB209 manual remains the main reference point for determining appropriate application rates, and the EA will continue to use it when assessing compliance.
There is some flexibility, where a FACTS Qualified Advisor can provide justification for applications that fall outside RB209 recommendations, and the EA will take this into account during inspections.
Timing & nutrient requirements
The EA has reinforced that nitrogen applications must closely match crop requirement at the time of application. When organic materials contain nitrogen, there must be a demonstrated need for nitrogen as well as for any other major nutrients they contain and supply, such as phosphate or potash.
Farmers should also ensure that phosphate and potash applications are balanced across the cropping rotation. Inputs should be managed to avoid nutrient build-up above target levels.
When justification will be required
The EA has highlighted several situations where it will expect clear justification for nutrient applications. These include autumn applications of organic manures to arable crops other than winter oilseed rape, and applications made before planting cover crops. In both cases, inspectors will look for evidence that the timing and nutrient contribution meet a defined crop and soil need.
EA enforcement approach
The EA has confirmed that it will generally begin with advice and guidance for minor or first-time breaches. However, more serious or repeated breaches – particularly those posing a pollution risk – may lead to enforcement action. Every case will continue to be assessed on an individual basis.
How CXCS can help
At CXCS, our FACTS qualified advisors are ready to support you in understanding and complying with the Farming Rules for Water. For further help or guidance, contact our Agricultural Compliance team on 01981 590514.