SUMMARY: The draft Nature Restoration Regulation is welcome because of the legally binding restoration targets which it brings, but EURAF criticises three things: a) the clarification that  “productive trees” are part of “high-diversity landscape features” is given only for arable land and not grassland; b) the suggested  indicators make insufficient use of existing CAP Performance Monitoring and Evaluation Framework Indicators and in particular GAEC-8 data from IACS/LPIS datasets; c) standing and lying deadwood are used as mandatory indicators of forest biodiversity - but this is inappropriate for forests of medium or high fire-risk.