Who owns SA’s wildlife? Hunting quotas and the quiet rewriting of our biodiversity compact

Something important is happening to South Africa’s wildlife policy and governance. It is being rewritten. Almost none of it is being announced.

It is happening incrementally, through government notices, regulatory amendments and decisions presented as technical administration. Each may look unremarkable on its own. Together they raise one question: Is South Africa converting its biodiversity from a public trust asset into a private commercial one, held for the benefit of privileged landowners and foreign trophy hunters?

The latest development should concern every South African, whether they support trophy hunting or oppose it.

On 31 August 2026 the government published Government Notice 7867 in the Government Gazette, setting South Africa’s 2026 and 2027 CITES export quota allocations for elephant, rhinoceros and leopard hunting trophies. The intention was gazetted in February 2026 by Willie Aucamp, the then environment minister, since replaced by David Maynier.

The notice permits the export of trophies from up to 150 elephants a year. The black rhino quota is 11 trophies in each of 2026 and 2027, and the leopard quota is 11 in 2026 and 10 in 2027. February’s proposal was higher, at 12 black rhino and 11 leopard each year. The reduction is marginal and beside the point. The question is what evidence supports any number at all.

Remarkably, the leopard hunting quota was published just three days after the draft National Leopard Conservation Strategy and Action Plan was released for public comment on 28 August 2026. This is not an administrative coincidence. It is a revealing sequence of priorities. A government that invites the public to comment on how leopards should be conserved cannot, three days later, allocate those same animals to the hunting industry without having absorbed a single substantive submission. The incongruity is glaring and deliberate: the conservation strategy is presented for show, while the commercial quotas are delivered as fact. Public participation is reduced to theatre.

These are not numbers on a spreadsheet. They concern some of our country’s most iconic, threatened and ecologically important animals: the black rhino, one of the world’s most threatened rhino species, and the leopard, whose populations are hard to quantify with confidence and have declined for decades.

More importantly, the quotas are the latest point in a sequence of policy decisions that deserve to be examined together.

A pattern is emerging

Three things have occurred in eight months.

First came the government’s renewed movement towards establishing CITES trophy-export quotas for elephant, rhino and leopard. Second was an apparent change in the state’s position on litigation concerning the welfare provisions associated with wildlife use and hunting, and effectively failed to oppose the hunting industry’s Constitutional Court challenge to the inclusion of welfare provisions in the national biodiversity legislation. Whatever one’s view of the underlying litigation, changes in the state’s stance on constitutional litigation involving its own wildlife policy matter because they reveal the new policy direction being taken by the government. Third, in July, the Department of Forestry, Fisheries and the Environment published draft Guidelines for the Management of Damage-Causing Animals. The earlier regulatory process had been directed towards national norms and standards. The new instrument is styled as “guidelines” rather than binding norms and standards and set the governing provisions as elective guardrails, in themselves permissive to exploitation, in faunal protections and management.

This distinction is not semantic.

Norms and standards impose nationally applicable requirements. Guidelines are optional. As legal commentators have noted, the draft retains the structure of the earlier norms and standards while changing their legal character.

Why does this matter?

Because the cumulative effect is to ask whether the government is progressively loosening the framework within which wildlife is protected and managed, while simultaneously expanding opportunities for its commercial use and commoditisation. That is a question which deserves a national conversation. The timing of the leopard quota – three days after inviting comment on a conservation strategy – makes the direction of travel unmistakable: conservation planning is being subordinated to commercial allocation.

Wildlife is not simply another commodity

South Africa’s wildlife belongs to a biological heritage older than any government, corporation, hunting organisation or private landowner. In fact, older than any political constituency. Private landowners undoubtedly have legitimate rights. Rural communities have legitimate rights. Farmers facing genuine losses from wildlife have legitimate commercial interests. But all citizens have rights. Sustainable use can, under appropriate circumstances, form part of conservation where those rights are respected and the accompanying obligations are met.

None of these answers the prior question: who bears ultimate responsibility for the country’s biodiversity?

The Constitution does.

Section 24 requires the environment to be protected for the benefit of present and future generations, through reasonable measures that promote conservation and secure ecologically sustainable use of natural resources. These rights are governed by National Environmental Act (Act 107 of 1998), the National Environmental Management and Biodiversity Act (Act 10 of 2004, Nemba) and its Threatened or Protected Species Regulations of 2007, together with the various provincial acts and ordinances. These legislative tools are neither a mandate for blanket preservation nor a licence for unrestricted exploitation. It is an instruction to govern as a steward. Nemba is explicit: the state is trustee of South Africa’s biological diversity, holding it for all citizens.

Stewardship is not commercialisation. These animals will be allocated to a small number of hunting operators and wealthy landowners, and their foreign clients, with a small percentage of the financial flows reaching our shores. The trustee is disposing of these public assets and that benefits few.

The leopard question exposes the problem

Nowhere is this clearer than with leopard. South Africa’s last published leopard Non-Detriment Finding (NDF), the assessment CITES requires before trade in an Appendix I species may be permitted, dates from May 2015. It concluded that legal trade and trophy exports posed a high risk to the survival of leopards in South Africa.

More than a decade later, a new national export quota has been set – and set three days after a conservation strategy was opened for public comment. The question is not whether one supports hunting. It is this: What scientific finding demonstrates that this level of export is non-detrimental, and where has it been published? How can a government claim to be developing a national conservation strategy for leopards while simultaneously allocating them to hunters before the public has even had a chance to respond?

The South African National Biodiversity Institute’s (Sanbi) own public information states that the minister’s most recently published NDFs are those gazetted in March 2026. That list does not include a leopard NDF. The discrepancy needs to be explained.

If a new Scientific Authority assessment underpins this quota, publish it. If it has not been gazetted as an NDF, explain why animals are being allocated to hunters before the finding that authorises the trade exists. If the 2015 finding has been superseded, South Africans are entitled to examine the science that superseded it before the animals are shot. Science that cannot be independently reviewed is not science. It is administrative justification.

This is not an unreasonable demand. It is the minimum expected of a government authorising international trade in a CITES Appendix I species. Setting quotas three days after inviting comment on a conservation strategy falls far short of that minimum.

The same principle applies to all the species

Enormous public and private resources have gone into protecting rhinos from poaching, and into elephant and leopard conservation. The black rhino is not a hunting opportunity. Its persistence depends on viable populations and connectivity across an increasingly fragmented landscape.

Elephants are ecosystem engineers whose effects run across whole landscapes. The question is not whether a given number of animals can be removed. It is: What are the cumulative consequences of those removals, legal and illegal, across the populations and ecosystems concerned?

Answering it requires credible population estimates, legitimate management interventions and functional monitoring, transparent modelling and an honest statement of uncertainty. It also requires the government to distinguish scientific advice from the interests of those who profit from the outcome and genuine consideration of all management options.

The quotas were set first. The scientific basis of the decision is still not public.

And this is where transparency becomes critical

There is nothing improper in the government consulting the hunting industry. Sanbi itself states that NDF assessments are consultative, and draws on scientific, industry, management and policy experts. The requirement is that consultation is even-handed.

But consultation is not the same as influence. And stakeholder participation is not the same as scientific independence. The distinction matters most where those with a direct economic interest in the outcome also hold close institutional relationships, and undue sway with the structures producing the science and the policy outputs.

This imbalance is institutional, not accidental. The Department of Forestry, Fisheries and the Environment’s long-standing Consultative Wildlife Forum, the principal formal channel through which the department engages the sector on policy, has for years been structured around consumptive-use interests. Its terms of reference and practical membership have effectively excluded or marginalised public interest conservation organisations, animal welfare bodies and biodiversity advocates, while regularly convening hunting, ranching and utilisation associations. Parallel attempts to create more balanced platforms, such as the Wildlife Well-Being Forum, have been allowed to atrophy. When the same department then sets hunting quotas three days after inviting comment on a leopard conservation strategy, the pattern is consistent: the voices with the greatest commercial stake in extraction are given structural priority; the voices charged with speaking for the public trust are kept at the door.

The Professional Hunters’ Association of South Africa’s published awards record shows that Dr Jeanetta Selier received its 2025 Wildlife Utilisation Award. She is the senior scientist: zoological support, scientific authority and wildlife economy at Sanbi, and leads the scientific authority function informing government policy.

The association has given its utilisation award to the scientist who leads the state’s scientific authority function. On its face that is a perceived conflict of interest. The public is entitled to see the declaration that was made and how it was managed. If none was made, that is the answer.

Minister Maynier now has a choice

Maynier took over the portfolio on 1 July 2026. The quotas were published on 31 August 2026. He inherited the process from Aucamp, who faced public questions about commercial interests in the wildlife and hunting sector and a prima facie conflict of interest in his conduct, and whose own appointment followed the controversial removal of Dion George, who stood up to the hunting industry.

That does not establish that Maynier personally endorsed every policy decision of his predecessor. Nor does it establish that the process was improper. But it does create a very reasonable question: Did the new minister independently reassess the scientific and legal basis of the inherited process, or did he simply allow an existing programme to reach its predetermined conclusion?

Only the minister can answer that, and he can answer it by publishing:

1. The scientific basis for the leopard quota;

2. The current NDF or Scientific Authority finding on which it rests;

3. The public submissions received during consultation, and how they were weighed – particularly given that the conservation strategy had only been open for three days;

4. The relevant conflict-of-interest declarations;

5. The role of stakeholder organisations in the scientific process; and

6. The underlying monitoring and modelling, released for independent scrutiny.

Publishing them would improve transparency, strengthen his decision and show responsible governance.

This is bigger than hunting

The real danger is that South Africans grow accustomed to change arriving one piece at a time, each presented as technical administration. A quota here. A regulatory change there. A guideline replacing a standard. A shift in litigation posture. An expanded role for private interests. A conservation strategy published for comment, immediately followed by the allocation of the very animals the strategy purports to protect.

Eventually, without anyone announcing that the country’s philosophy has changed, the philosophy has changed. The danger is not sustainable use. It is sustainable use as a slogan used to authorise decisions whose sustainability has never been independently demonstrated.

The live question is not whether private landowners may benefit from biodiversity public trust assets. It is whether a public asset should be managed principally for those with the greatest commercial capacity to extract value from it. The Professional Hunters’ Association of South Africa celebrated the outcome even before the department announced it, and Safari Club International celebrated the access.

South Africa needs to stop and look at the direction of travel

We have an extraordinary constitutional and legislative framework for biodiversity protection, and its implementation is failing. We have scientists of international standing, protected areas, private reserves, communal conservation areas and thousands of people who give their working lives to conservation. What we need is not another slogan about the “wildlife economy”. We need institutional integrity, transparent science, independent oversight and meaningful public participation.

Above all, the government must remember that it is the trustee of a public asset and answerable to the public that owns it.

The current minister therefore has an opportunity.

He can demonstrate that the publication of these quotas was not simply the final administrative step in a policy trajectory inherited from his predecessor, who himself was questioned on conflict of interests. He can demonstrate that he personally interrogated the evidence, the law, the public submissions and the conflicts surrounding the process – and reached an independent conclusion. If he does that, public confidence can be restored.

If that does not happen, South Africans are entitled to ask the harder question: are we watching the transfer of a common biodiversity heritage into a private wildlife economy, one trophy, one regulation and one policy decision at a time?

This was never about hunting, which has ethical questions to answer for itself. It is about who speaks for South Africa’s wildlife when the animals cannot speak for themselves. DM