BBNJ: Report information as a database

Before you start

You may find it useful to read:

• Understand the UK requirements for marine genetic resources under the Biodiversity Beyond National Jurisdiction Act 2026
• Report information for a digital sequence information utilisation project

Understand database obligations

The obligations in the Biodiversity Beyond National Jurisdiction Act 2026 apply to a UK database in which digital sequence information (DSI) on marine genetic resources (MGR) of areas beyond national jurisdiction is stored.

The purpose of these obligations is to support access to DSI and contribute to benefit sharing under the BBNJ Agreement.

Check whether the requirements apply

The obligations apply to UK databases.

A database is a UK database if it is:

• controlled by a person in the UK
• accessible to members of the public

A database is controlled by a person in the UK if:

• the database is controlled by an individual who is habitually resident in the UK
• the database is controlled by an entity that is incorporated or formed under the law of any part of the UK

The obligations apply only to DSI on MGR collected after 9 August 2026.

Understand public accessibility

A database must be accessible to members of the public.

This does not prevent organisations from maintaining their own internal databases.

However, DSI on MGR of areas beyond national jurisdiction generated or utilised during utilisation projects must also be recorded on a publicly accessible database as required by the Act.

Check who must comply

The Biodiversity Beyond National Jurisdiction Act 2026 requires the person who controls the UK database to comply with the database obligations.

Who controls a database will depend on the governance arrangements of the organisation concerned.

Identify digital sequence information

The person who controls a UK database must, so far as reasonably practicable, ensure that DSI:

• can be identified, in accordance with current international practice, as relating to MGR of areas beyond national  jurisdiction; and 
• in particular, can be identified by reference to any BBNJ standardised batch identifier relating to the MGR concerned

Understand what “reasonably practicable” means

There may not always be a BBNJ batch identifier associated with the DSI.

International databases may hold DSI on MGR collected by individuals or institutions using ships registered in a country that is not a party to the BBNJ Agreement, or equipment owned or operated by a national of a country that is not a party to the BBNJ Agreement.

In those cases, there will be no BBNJ standardised batch identifier associated with the DSI.

It will therefore not be possible for the person who controls the database to ensure that the DSI is identified by reference to a BBNJ standardised batch identifier.

Provide access to digital sequence information

The person who controls a database must provide access to DSI.

For databases, access includes:

• downloading DSI
• viewing DSI programmatically

Databases are not expected to record the purpose for which users access DSI.

Understand reasonable conditions

Access to DSI for utilisation can be made subject to reasonable conditions in accordance with the BBNJ Agreement. 

Article 14(4) of the BBNJ Agreement lists the following reasonable conditions:

• the reasonable costs associated with maintaining the database in which the DSI is recorded
• the reasonable costs associated with providing access to the DSI
• other reasonable conditions in line with the objectives of the Agreement

The objectives of Part II of the BBNJ Agreement include:

• the fair and equitable sharing of benefits arising from activities relating to DSI on MGR of areas beyond national jurisdiction for the conservation and sustainable use of marine biological diversity of areas beyond national  jurisdiction
• the building and development of the capacity of Parties, particularly developing States Parties
• the generation of knowledge, scientific understanding and technological innovation
• the development and transfer of marine technology in accordance with the Agreement

Report access to digital sequence information

The person who controls a UK database must report:

• the number of times DSI has been viewed
• the number of times DSI has been downloaded

Where available, reports should identify the DSI using the related BBNJ batch identifier.

Complete the database reporting form

• BBNJ: Complete a database reporting form (ODT, 10.4 KB)

Meet reporting deadlines

Reports must be submitted for every relevant 2-year period.

The first reporting period begins on 9 August 2026.

Reports must be sent to the UK BBNJ Focal Point (bbnjfocalpoint@fcdo.gov.uk) no later than 2 months after the end of the reporting period.

The UK BBNJ Focal Point will submit the information to the BBNJ Access and Benefit Sharing Committee.