Both the Forest Certification Council of Latvia, and the Latvian portal for the forestry and related sectors zemeunvalsts.lv join in and support the arguments presented in this letter, noting that these issues have been highlighted and discussed within the sectors ever since the guidelines were published.

Riga, 2 September 2026

To the President of the Republic of Latvia Edgars Rinkēvičs

To the Prime Minister of the Republic of Latvia Andris Kulbergs

To the Speaker of the Saeima of the Republic of Latvia Daiga Mieriņa

To the Minister for Agriculture of the Republic of Latvia Uldis Augulis

To the Minister for Climate and Energy of the Republic of Latvia Jānis Vitenbergs

To the Minister for Finance of the Republic of Latvia Māris Kučinskis

To the Minister for Economics of the Republic of Latvia Viktors Valainis

Open letter regarding concerning trends in the activities of Latvijas Banka

We, the organisations and companies representing the land sectors, wish to draw your attention to a dangerous trend within Latvijas Banka, where, through its actual actions, the central bank is not steering Latvia’s development towards its defined vision of an “advanced state and prosperous society”, but quite the opposite – it is using the instruments at its disposal to deliberately hinder Latvia's economic growth and obstruct the implementation of meaningful biodiversity measures.

On 11 May of this year, the “Recommendations for identifying economic activities beneficial and harmful to biodiversity” developed by Latvijas Banka (LB) were published on its website (bank.lv). According to LB, this document does not constitute lending guidelines for credit institutions, it is not mandatory to apply, and it is not intended as direction for specific sectors or businesses. LB justifies the development of these guidelines by stating that Latvian commercial banks have an obligation to assess environmental, social and governance (ESG) risks, and if Latvia did not develop its own biodiversity guidelines, commercial banks would have to use either their own internally created guidelines or international methodologies like ENCORE, which might not be optimal for the Latvian situation. Based on the information available to us, none of the Latvian commercial banks have decided to use the guidelines developed by LB, nor do they plan to do so in the near future, primarily due to their incomplete content. We, the organisations representing the land sectors, do not conceptually object to an initiative by LB or any other institution to create individual guidelines tailored to Latvia’s natural and climatic conditions, but they must be professional, high-quality, and suited to local Latvian circumstances. Unfortunately, the current guidelines are not.

We clearly see that the LB guidelines have several significant methodological flaws, which have primarily led to the low quality of their content.

Firstly, at no point have there been clearly defined standards, qualification criteria, or a methodology used to select the experts or non-governmental organisations involved in developing the guidelines. During several meetings with LB representatives, Edvards Kušners, advisor to the Council of Latvijas Banka and head of the sustainability division, indicated that no such expert selection criteria existed because “Latvijas Banka does not engage in creating bureaucratic paperwork”. Kušners also stated that experts were chosen based on his own subjective understanding of who the leading biodiversity experts were, as well as personal acquaintances. We wish to inform you that despite the fact that no selection methodology, standards or criteria existed, we have invited LB to formulate the actual expert selection procedure in writing.

Secondly, the development of the guidelines themselves did not follow a professionally defined methodology understood by the participants. When asking LB representatives about the methodology used for the development of the guidelines, we received a very vague and chaotic explanation from Edvards Kušners regarding surveys, expert opinions, and scientific groups, while at the same time admitting that no written methodology for the development of the guidelines, understood by everyone, had existed prior to their creation. Despite the fact that the guidelines were drawn up without a methodology, we have requested that LB formulate the actual methodology for the development of the guidelines in writing.

We believe that this amateurish and openly destructive approach to the development of the guidelines is the main reason for their unforgivably low quality. The criteria included in the guidelines are flawed not only from an economic perspective but also from the viewpoint of biodiversity. As an example, we can cite the criterion where keeping animals in a barn is mentioned as an unfavourable practice. Beyond economic considerations, keeping cattle in a barn is important for fully ensuring high standards of animal welfare (continuous access to water, feed, dry bedding, cooling, etc.), reducing the risk of infectious diseases, and lowering the risk of injury; furthermore, keeping animals in a barn does not automatically mean a reduction in biodiversity.

Beyond this example, the guidelines are overflowing with questionable, imprecise, incomprehensible and mutually conflicting claims. Moreover, the authors of the guidelines have envisaged that in many cases, commercial banks will assess their clients' compliance with the conditions of the guidelines based on whether, for example, a farmer is eligible for any of the eco-scheme measures created for Latvia’s CAP Strategic Plan 2023-2027. The authors of the guidelines completely ignore the fact that after 2027, such support measures (eco-schemes) will no longer exist and the Rural Support Service will not administer them; therefore, it is already known that using these guidelines after 2027 will simply not be possible.

In reference to the low quality of the document, we are concerned by the arrogant, unprofessional and, in our opinion, ideologically motivated actions and communications of LB experts, specifically Edvards Kušners, which industry organisations and companies have been encountering for several years. At no point, during any stage of the development of the guidelines, were there any consultations with representatives of the agricultural or forestry sectors. To create a misleading impression of widespread involvement by state institutions and scientific bodies, the initial version of the guidelines mentioned that they were developed with experts from institutions such as the Latvian Rural Advisory and Training Centre, the Latvian State Forest Research Institute “Silava”, and others. Following objections from the mentioned institutions and a written explanation that their employees had not been delegated to participate in the development of the guidelines, LB made changes to the introduction of the guidelines, stating that the experts work in the respective institutions on a daily basis, thus creating a false impression that the specific institutions had participated in the development of the guidelines. In the case of LSFRI “Silava”, a letter was sent several times with a request to remove the name of LSFRI “Silava” from the guidelines. After a long period of providing no response and the sending of a follow-up letter, Edvards Kušners did not agree to delete the name of LSFRI “Silava” from the introduction, despite the fact that LSFRI “Silava” did not participate in the development of the guidelines and has repeatedly requested that the institute's name be removed.

Formal involvement of the land sector only occurred following public communication from the sector and official correspondence with LB, when the developers of the guidelines agreed to an in-person meeting. Unfortunately, they did not speak about the substance of the guidelines, and repeatedly questioned the competence of agricultural and forestry representatives to understand the necessity of the guidelines. Kušners and the LB management also rejected the invitation to withdraw the developed guidelines, informed us that they had been submitted to the European Central Bank, and as the only form of involvement for farmers, offered official correspondence, inviting us to submit the necessary improvements in writing, which would then be evaluated by the circle of experts chosen by LB. During the meeting, arrogant assumptions were even voiced, such as “it is possible that it was a mistake to publish these guidelines for everyone to see, and they should have simply been sent to the commercial banks”, which we consider to be an unacceptable and destructive attitude on the part of LB employees.

In conclusion, we wish to emphasise that the land sector is vitally important for ensuring biodiversity in Latvia. All agricultural sectors are ready to fully implement measures that preserve and promote biodiversity, provided that they are logical, economically proportionate, appropriate for Latvian conditions, and discussed in advance with industry representatives.

The land sector is important not only for the country’s biodiversity and national security but also for its economy. The total annual contribution of the land sector to the Latvian economy is approximately 4 billion EUR, and when combined with the indirect contribution, it reaches as much as 8 billion EUR. We wish to emphasise that the agricultural sector accounts for 30–40% of Latvia's exports over the years, and all land sector industries have defined clear goals for growth, efficiency, and increased output. One of the most important cornerstones of growth is the availability of stable, long-term financing on the most favourable terms possible. Since the majority of land sector companies raise financing not in the capital markets, but in Latvian commercial banks, we believe that these guidelines will significantly negatively affect the conditions for future funding, and will negatively impact industry growth, the creation of added value, the increase of output, and contributions to the state budget.

For this reason, we call upon you to hold discussions with the management of Latvijas Banka and urge you to point out the problems we have identified regarding the competence of Latvijas Banka staff, as well as the potential desire of LB employees to implement their personal ideologies and convictions through the spheres of competence of Latvijas Banka, which is categorically not permissible.

We would like to ask you to discuss the situation with the management of Latvijas Banka and call upon them to:

1) Halt the practical use of the guidelines until an independent methodological evaluation is carried out;

2) Publicise the criteria for expert selection, the circle of experts, and the actual methodology used to develop the document;

3) Clarify exactly what was sent to the European Central Bank, in what status, and with what objective;

4) Conduct an impact assessment of the guidelines on the availability of credit and its conditions;

5) Redraft the guidelines, fully involving professional organisations in agriculture, forestry, and other land sectors;

6) Evaluate the responsibility of Latvijas Banka employees regarding the process of developing the guidelines and their communication;

7) Increase oversight of the analytical work, publications, and communication of Latvijas Banka as an independent institution.

Yours sincerely,

Chairman of the Board of the Association “Zemnieku saeima” Juris Lazdiņš

Chairman of the Board of the Association “Latvian Forest Owners' Association” Arnis Muižnieks

Chairman of the Board of the Association “Farmers' Parliament Cooperation Council” Guntis Gūtmanis

President of the Association “Employers' Confederation of Latvia” Andris Bite

Chairman of the Board of the Association “Latvian Association of Agricultural Cooperatives” Rolands Feldmanis

President of the Association “Latvian Forest Industry Federation” Indulis Kovisārs

Chairman of the Council of AS “Latvijas finieris” Uldis Biķis

Chairman of the Board of LPKS “LATRAPS” Roberts Strīpnieks

Acting Chair of the Board of LPKS “Straupe” Jānis Šulcs

Chairman of the Board of LPKS “Durbes grauds” Sandris Bēča

President of the Association “Latvian Fish Industry Union” Jānis Endele

Chair of the Board of the Cooperative Society “Pig Breeders' Association” Dzintra Lejniece

Chairman of the Board of the Association “Livestock Farming Association” Jānis Miezītis

Chair of the Board of the Association “Latvian Young Farmers' Club” Sandra Eimane-Strautniece

Board Member of the Association “Latvijas dārznieks” Jānis Bušs

Chairman of the Board of the Association “United Poultry Industry Association” Jānis Gaigals

Chairman of the Board of the Association “Latvian Agronomists' Association” Ringolds Arnītis

Chairman of the Board of the Association “Latvian Viticulturists and Winemakers' Association” Ričards Ivanovs

Board Member of the Association “Sustainable Greenhouse Vegetable Growers' Association” Oto Marinaki

Chairman of the Board of the Cooperative Society “Jurgensburg Agro” Kristaps Veide

Chairman of the Board of the Association “Beef Cattle Breeders' Association” Raimonds Jakovickis

Chairman of the Board of the Latvian Forest Owners and Managers Confederation Māris Liopa

Board Member of the Forest Certification Council of Latvia Pauls Rēvelis