Loose or generous definitions of risk can lead to a large proportion of sites being eligible for classification as a protection offset where, on balance, it may be difficult to justify them as contributing additional biodiversity protection. In Brazil, simplifying assumptions in the policy design process means that all natural habitats are classified as at risk so all natural habitat sites are eligible for use as protection offsets. The policy design has raised questions about the additionality of offsets in Brazil and consequently how scarce offsets finance may be better targeted (eftec et al., Biodiversity offsets should provide conservation benefits over a time period which is commensurate with the duration of biodiversity loss.