Nature reporting · the TNFD and the ISSB
TNFD: nature reporting, the ISSB and the UK
The TNFD — the Taskforce on Nature-related Financial Disclosures — is the leading framework for reporting nature-related dependencies, impacts, risks and opportunities, and it is voluntary.
The ISSB is now drawing on it for a non-mandatory IFRS Practice Statement on nature, with the exposure draft targeted for October 2026.
In the UK nothing names the TNFD; nature reaches a company through the materiality test in UK SRS S1, and any ISSB output would need UK endorsement first.
What it is
The TNFD, in one framework and one method
The Taskforce published its final recommendations in September 2023 to give companies and investors a consistent way to assess and report their relationship with nature.
Its own launch release was explicit: “The final Recommendations are science-based and voluntary” (18 September 2023).
The framework has two parts: what to report — fourteen disclosures under four pillars — and how to find it, the LEAP approach.
It was built on the climate precedent: the pillars are the TCFD’s, with “risk management” widened to “risk and impact management”.
The case it answered is the scale of dependence: the World Economic Forum estimated in January 2020 that $44 trillion of economic value generation — more than half of world GDP — is moderately or highly dependent on nature.
That figure is the WEF’s own estimate, not a regulator’s, and it dates from 2020.
Internationally, corporate nature disclosure traces to Target 15 of the Kunming-Montreal Global Biodiversity Framework, which binds governments, not companies.
The TNFD in four numbers
- 4 pillars: governance, strategy, risk and impact management, metrics and targets.
- 14 recommended disclosures.
- 6 general requirements across all four pillars.
- 4 LEAP phases: Locate, Evaluate, Assess, Prepare.
Source: TNFD Recommendations.
Adoption and status
Who uses it, and what the Taskforce is doing now
The TNFD’s 2026 Status Report counts 802 organisations committed to disclosures aligned with its recommendations.
More than 1,000 organisations across 56 countries or areas have published first-, second- or third-generation TNFD-aligned reports, double the number identified in 2025.
The two populations are different: committing is a promise, publishing is a report, and neither number contains the other.
The Taskforce is also changing role: in November 2025 it said it would complete its technical work in progress by the third quarter of 2026 and pause any further technical guidance.
It would then support the ISSB, and conclude its technical programme subject to the outcome of the ISSB’s process.
It has not disbanded, and its framework, guidance and sector material remain published.
| Figure | What it counts |
|---|---|
| 802 | Organisations committed to TNFD-aligned disclosure |
| Over 1,000 | Organisations that have published TNFD-aligned reports |
| 56 | Countries or areas where they are |
| US$26.6 trillion | Assets under management of the committed financial institutions |
The recommendations
Fourteen disclosures, pillar by pillar
The Recommendations describe a framework that “includes 14 recommended disclosures covering nature-related dependencies, impacts, risks and opportunities” (the recommendations).
Counted by pillar: governance three, strategy four, risk and impact management four, metrics and targets three.
Risk and impact management reaches four because its first disclosure is split: A(i) for direct operations, A(ii) for the upstream and downstream value chain.
The Recommendations say they replicate “the four disclosure pillars and all 11 TCFD recommended disclosures”, so three are new: Governance C on human rights and engagement with Indigenous Peoples, Local Communities and affected stakeholders; Strategy D on priority locations; and Risk and impact management A(ii).
Strategy B is where nature meets climate: it asks about “any transition plans or analysis in place”, so a company with a climate transition plan should expect its nature disclosure to point back to it.
Metrics come in two tiers: core global and core sector metrics to be disclosed on a comply-or-explain basis, and additional metrics preparers may use.
The checker beside this text turns the fourteen into a gap list for a draft report; a TCFD-shaped climate report will usually be missing the three new ones.
Your report against the fourteen
Governance · 0 of 3
One of the three with no TCFD counterpart.
Strategy · 0 of 4
One of the three with no TCFD counterpart.
Risk and impact management · 0 of 4
One of the three with no TCFD counterpart.
Metrics and targets · 0 of 3
0 of 14 covered
TNFD Recommendations (September 2023), Figure 1; TNFD-in-a-Box Module 3.
The TNFD framework is voluntary; this is a gap list, not a compliance test.
Nothing is stored or sent.
General requirements
Six requirements that sit across all four pillars
| Requirement | What it asks |
|---|---|
| 1 · Application of materiality | Which materiality approach the report applies — the Recommendations accommodate the ISSB’s investor lens and an impact lens consistent with GRI. |
| 2 · Scope of disclosures | Which parts of the business and value chain the disclosures cover. |
| 3 · Location of nature-related issues | Nature issues are location-specific; the report says where they arise. |
| 4 · Integration with other sustainability disclosures | How the nature disclosures connect to climate and other reporting. |
| 5 · Time horizons considered | Short, medium and long term, as the organisation defines them. |
| 6 · Engagement with Indigenous Peoples, Local Communities and affected stakeholders | How they were engaged in identifying and assessing the organisation’s nature-related issues. |
The first requirement is the one that most changes a report: the TNFD lets the preparer choose its materiality lens, and requires it to say which.
A UK company reporting against UK SRS S1 applies financial materiality; one also reporting under the EU’s ESRS applies double materiality — see double materiality.
The third requirement is what makes nature reporting harder than carbon: a tonne of CO2 is the same everywhere; a hectare of land use is not.
The method
The LEAP approach, phase by phase
The LEAP guidance (version 1.1, October 2023) describes four phases “designed to be used by an assessment team in an organisation”, for organisations of all sizes, sectors and geographies.
Before them comes scoping.
| Phase | Components | What it hands on |
|---|---|---|
| Scoping | Sector, value chain and geography filters; a quick scan | Working hypotheses for the scope of the assessment |
| L · Locate | L1 span of the business model and value chain · L2 dependency and impact screening · L3 interface with nature · L4 interface with sensitive locations | Potentially material activities, and a list or map of assessment locations including every sensitive location |
| E · Evaluate | E1 environmental assets, ecosystem services and impact drivers · E2 dependencies and impacts · E3 measurement · E4 impact materiality assessment | Measured dependencies and impacts, and an answer to “which of our impacts are material?” |
| A · Assess | A1 risk and opportunity identification · A2 adjustment of existing risk management · A3 measurement and prioritisation · A4 materiality assessment | The risks and opportunities to disclose in line with the recommendations |
| P · Prepare | P1 strategy and resource allocation · P2 target setting and performance management · P3 reporting · P4 presentation | Decisions, targets, and the disclosure itself |
In the guidance’s own words, LEAP “aims to help organisations conduct the due diligence necessary to inform disclosure statements aligned with the TNFD recommendations”.
It is a method, not a disclosure: “we applied LEAP” describes process, and a report that never discloses Strategy D locations or the metrics has done the assessment and skipped the reporting.
On targets, P2 asks how to set them and measure progress, and the TNFD’s sector guidance points to the Science Based Targets Network for nature — a different body from the SBTi, whose climate targets are on science-based targets.
Sector guidance exists for several industries, among them forestry and paper.
Locate · L4
Five criteria; one is enough
The pivot of the Locate phase is L4: is this site or sourcing area a sensitive location?
The TNFD treats a location as sensitive if it meets one or more of five criteria, and “only one criterion needs to be met” (TNFD in a Box, Module 4).
The criteria are areas important for biodiversity, areas of high ecosystem integrity, areas of rapid decline in integrity, areas of high physical water risk, and areas important for ecosystem service provision.
Strategy D then asks for the locations that meet the criteria for priority locations, so the L4 list is the evidence behind that disclosure.
The test beside this text applies the one-criterion rule to one location and records what it cannot yet test as a gap.
Locate · L4 · one location
0 of 5 answered.
One “yes” is enough to make it sensitive.
TNFD-in-a-Box Module 4 (the five criteria; “only one criterion needs to be met”); LEAP guidance v1.1 (October 2023), component L4; TNFD Recommendations, Strategy D. Your judgements; nothing is stored or sent.
Worked example
A Locate screen for a UK packaging manufacturer
Illustrative only: an invented company, invented sites and invented figures, carrying seven candidates down to two sensitive locations and two data gaps.
None of it describes a real company or place.
| Candidate | Spend | L2 screen | L4 outcome |
|---|---|---|---|
| Site 1 — paper mill (abstracts river water) | — | High | Meets criterion 4 (water risk): sensitive |
| Site 2 — converting plant | — | Low | Screened out at L2, reason recorded |
| Site 3 — converting plant | — | Low | Screened out at L2, reason recorded |
| Virgin pulp, traced region | £5.0m of £7.2m | High | Meets criterion 1 (biodiversity): sensitive |
| Virgin pulp, untraced | £2.2m | High | Cannot be tested: data gap |
| Recycled fibre | £5.4m | Moderate | Meets none on the data held: not sensitive, data and date recorded |
| Starch adhesive | £2.7m | Moderate | Country of origin only: data gap |
| Inks and coatings | £2.7m | Low | Screened out at L2, reason recorded |
Scoping gives the working hypothesis: paper and packaging is likely to depend on water and fibre; the value chains worth following are fibre, adhesives and inks.
The four items rated moderate or high at L2 go forward; they account for (£7.2m + £5.4m + £2.7m) ÷ £18.0m = 85% of purchased spend.
Inks and starch cost the same £2.7m and only one goes forward: the screen is on dependency and impact, not on spend, and screening out by spend alone is the shortcut a reviewer should look for.
Two of three pulp suppliers can trace fibre to a region, covering £5.0m of £7.2m (69%); the remaining £2.2m cannot yet be placed.
The two data gaps total £2.2m + £2.7m = £4.9m, or 27% of purchased materials, each with a supplier-engagement action and a date.
Every item that leaves the screen has a recorded reason, and untraceable volumes are reported as gaps rather than counted as low risk.
The same supplier-data problem appears in Scope 3 work, and one supplier request can serve both — see Scope 3 emissions and UK SRS Scope 3 reporting.
The ISSB
The ISSB’s nature work: a Practice Statement, not a Standard
In November 2025 the ISSB decided to undertake nature-related standard-setting, drawing on the TNFD framework.
In April 2026 it decided the form: requirements and guidance “in the form of an IFRS Practice Statement” (ISSB Update; ISSB news).
Its staff explained what that means: a Practice Statement “is a non-mandatory document… It is not a Standard”, but it goes through full due process, and “a jurisdiction can choose to mandate it” (AP3D ¶55).
On 21 July 2026 all 12 members confirmed due process had been met, none indicated an intention to dissent, and the Board set a 120-day comment period (ISSB Update; AP3A).
The ISSB’s October 2026 paper to its advisory forum still reads “Nature Exposure Draft coming October 2026” (SSAF paper); the project page gives the next milestone as the exposure draft.
Non-mandatory does not make nature reporting optional where it is material: the ISSB’s FAQ says IFRS S1 already requires material information about nature-related risks and opportunities.
“Standard-setting” describes the process and “Practice Statement” the output; both are true at once, and neither is an “IFRS S3”.
The climate precedent is IFRS S2, which is consistent with the TCFD’s recommendations — the TCFD itself disbanded in October 2023; the whole ISSB work plan is on the ISSB framework.
- Nov 2025Standard-setting begins
The ISSB decides to draw on the TNFD framework.
- 22 Apr 2026Form decided
Requirements to be proposed as an IFRS Practice Statement; all 12 members agree.
- 21 Jul 2026Cleared for ballot
Due process confirmed; 120-day comment period; no member dissenting.
- Oct 2026Exposure draft — target
Timed to the CBD’s COP17.
- 2027 at the earliestFinal Practice Statement
Not before the comment period closes and feedback is considered.
The UK
Voluntary or required: the UK position, line by line
As at 1 October 2026.
No mandate is implied where none exists.
| Item | UK position |
|---|---|
| TNFD Recommendations | Voluntary. No UK instrument requires them. |
| UK SRS S1 | An entity applying it discloses material sustainability-related information, which can include nature. Listed companies in five categories report against it on comply or explain from periods beginning 1 January 2027, after a two-year relief for non-climate matters (FCA PS26/19). |
| ISSB nature output | An exposure draft of a non-mandatory Practice Statement, targeted for October 2026. |
| UK endorsement | Required before any future ISSB nature output applies in the UK. The FRC’s technical committee is at research stage on nature. No date exists. |
| The biodiversity duty | NERC Act 2006 s.40 binds public authorities. Its s.40A reporting duty applies to local authorities, local planning authorities and designated authorities in England. |
| Biodiversity net gain | A 10% gain, deemed a pre-commencement planning condition for development in England (TCPA 1990 Sch 7A). An obligation on a development, not a corporate reporting duty. |
| Company annual reports | Neither the NERC Act nor Schedule 7A creates a duty on an ordinary company to report biodiversity in its annual report. |
Read together, the exact answer is narrow: the TNFD binds nobody.
Nature disclosure becomes required of a UK company only by another route: an entity applying UK SRS S1 that finds a nature matter material has to disclose it, or explain under the FCA’s rules.
A future ISSB Practice Statement could become required only if the UK chose to endorse and mandate it.
New ISSB pronouncements do not reach UK SRS automatically: the FRC names nature as an example that would first need endorsement, and its technical committee’s nature project is research, with papers in its meeting summaries.
The UK standards themselves are on GOV.UK; how they reach UK companies is on UK SRS legislation and the UK SRS timeline.
Planning-side nature obligations for major infrastructure follow their own regime — see the government’s biodiversity gain statements for nationally significant infrastructure projects.
This is our reading of the instruments, not legal advice.
UK groups with EU operations
The exception to watch: CSRD and its biodiversity standard
UK groups caught by the EU’s Corporate Sustainability Reporting Directive report under the European Sustainability Reporting Standards, a different regime with its own biodiversity and ecosystems standard.
That is a legal duty for those in scope, and it asks for impacts as well as risks, because the ESRS apply double materiality.
Who is in scope is on CSRD reporting for UK groups, and the standards on the ESRS.
For a company already reporting against the ISSB’s standards, the TNFD’s pillars look familiar, because both were built on the TCFD’s; due-diligence obligations in the EU supply chain are on CSDDD.
What to do now
Preparing for nature disclosure before anything requires it
Nature data takes longer to gather than the regulatory timetable suggests, for the same reason Scope 3 does: it lives with suppliers and in places, not in the finance system.
A LEAP Locate screen is the cheapest first step, because it shows where the dependencies and sensitive locations are before anyone asks.
Fold nature into the existing UK SRS S1 materiality process: where a dependency or impact could reasonably be expected to affect cash flows, access to finance or cost of capital, it is already in scope.
Keep a clear line between corporate reporting and planning obligations such as biodiversity net gain; the two are often confused, and only one is a reporting duty.
Watch for the ISSB exposure draft and its consultation, and for any UK endorsement project that follows.
The duties that already apply to a UK company — SECR, ESOS, the Companies Act climate disclosures — are mapped on UK sustainability reporting.
The global sustainability standards map shows where nature fits among the other systems; for an outside view of what the ISSB proposals mean in practice, KPMG’s commentary is background reading, not a source for any fact here.
The climate side of the same exercise is on TCFD and TCFD and UK SRS.
Check yourself
Six claims about the TNFD, true or false
Each statement circulates in commentary, and each is settled by a document the Taskforce, the ISSB or the FRC published.
The sixth is the commonest error in TNFD explainers: the TCFD did not become IFRS S2.
The answers name their source, so each can be checked.
TNFD: true or false?
The TNFD recommendations are mandatory for UK listed companies.
The TNFD carries over all 11 TCFD recommended disclosures and adds three, for 14.
802 organisations have published TNFD-aligned reports.
The ISSB is turning the TNFD framework into a new IFRS Sustainability Disclosure Standard.
A future ISSB nature Practice Statement would apply in the UK automatically through UK SRS.
The TCFD was consolidated into the ISSB and became IFRS S2.
0 of 6 answered.
Nothing you choose is stored or sent.
Side by side
TCFD, TNFD and the ISSB’s nature work: what carries across
| TCFD | TNFD | ISSB nature output | |
|---|---|---|---|
| Subject | Climate | Nature: dependencies, impacts, risks and opportunities | Nature-related risks and opportunities |
| Form | Recommendations, 2017 | Recommendations, September 2023 | Proposed IFRS Practice Statement |
| Pillars | Governance, strategy, risk management, metrics and targets | The same four, with risk and impact management | Guidance on applying IFRS S1 to nature |
| Disclosures | Eleven | Fourteen — the eleven plus three | Exposure draft targeted for October 2026 |
| Materiality | Financial | The preparer chooses, and says which | Financial, as in IFRS S1 |
| Status | Disbanded October 2023; carried into IFRS S2 | Voluntary; technical work concluding, framework still published | Non-mandatory unless a jurisdiction requires it |
| In the UK | Replaced for listed companies by the FCA’s UK SRS rules | Voluntary | Would need UK endorsement |
The TNFD was designed to sit beside the TCFD, and the table shows how closely: the same four pillars, all eleven climate disclosures carried over, and three nature-specific additions.
The difference that matters most is the materiality lens: the TCFD and the ISSB ask only what affects the company, while the TNFD lets the preparer report impacts as well, provided it says which approach it took.
The ISSB’s output will take the investor lens, because it sits under IFRS S1; impact reporting on nature stays with the TNFD’s impact option, GRI and, for those in scope, the ESRS.
So a UK company reporting under UK SRS S1 and the TNFD can use one LEAP assessment for both, and will report a narrower set of matters under UK SRS than under the TNFD’s impact lens.
Nature disclosure, in this sense, is not one thing: it is a risk disclosure under the ISSB’s standards and, under the TNFD or the ESRS, can also be an account of the company’s effect on nature.
Frequently asked
TNFD, answered
What is the TNFD?
The Taskforce on Nature-related Financial Disclosures, a market-led initiative that published its final recommendations in September 2023.
They give companies and financial institutions a framework for assessing and reporting their nature-related dependencies, impacts, risks and opportunities: fourteen recommended disclosures across four pillars, six general requirements, and the LEAP assessment approach.
What does TNFD stand for?
Taskforce on Nature-related Financial Disclosures.
Its sister for climate was the TCFD, the Task Force on Climate-related Financial Disclosures, which disbanded in October 2023.
Is TNFD mandatory in the UK?
No. The TNFD’s own launch release calls the recommendations science-based and voluntary, and no UK instrument requires them.
Nature disclosure reaches a UK company only by another route — for example a material nature-related risk under UK SRS S1, which listed companies in scope report against on a comply-or-explain basis from 2027.
Is TNFD part of UK SRS?
No. UK SRS S1 and S2 are the UK versions of the ISSB’s standards.
The ISSB is developing a nature-related Practice Statement drawing on the TNFD, and any such output would need the UK’s endorsement process before it could form part of UK SRS.
No UK endorsement date exists.
What is the ISSB doing on nature?
In November 2025 the ISSB moved its nature project into standard-setting, drawing on the TNFD framework.
In April 2026 it decided the output would be a non-mandatory IFRS Practice Statement, not a new Standard.
On 21 July 2026 all 12 members cleared the exposure draft for ballot with a 120-day comment period, and it is targeted for October 2026.
Is the ISSB writing an IFRS S3 on nature?
No. The ISSB’s staff wrote that many assume standard-setting means a new Standard like IFRS S2 for climate, and “this is not the case”.
The output is a Practice Statement, which is not a Standard but goes through full due process and can be mandated by a jurisdiction.
If the Practice Statement is non-mandatory, is nature reporting optional?
Not where nature is material.
The ISSB says IFRS S1 already requires material information about nature-related risks and opportunities.
The Practice Statement will guide how to provide it; using it is optional unless a jurisdiction requires it.
How many TNFD recommendations are there?
Fourteen recommended disclosures, across four pillars: governance, strategy, risk and impact management, and metrics and targets — three, four, four and three.
All eleven TCFD disclosures are carried over, and three nature-specific ones are added: Governance C, Strategy D and Risk and impact management A(ii).
Six general requirements apply across all four pillars.
What is the LEAP approach?
The TNFD’s assessment method: Locate the interface with nature, Evaluate dependencies and impacts, Assess risks and opportunities, and Prepare to respond and report. Each phase has four components, after a scoping step. It produces the evidence; the fourteen disclosures are what is reported.
What does the LEAP Locate phase produce?
A list of potentially material activities and a list or map of assessment locations, including every ecologically sensitive location.
A location is sensitive if it meets any one of five criteria: importance for biodiversity, high ecosystem integrity, rapid decline in integrity, high physical water risk, or importance for ecosystem service provision.
How many organisations use the TNFD?
The TNFD’s 2026 Status Report (September 2026) counts 802 organisations committed to TNFD-aligned disclosure, with financial institutions among them representing US$26.6 trillion of assets under management, and more than 1,000 organisations across 56 countries or areas that have published TNFD-aligned reports.
Commitments and published reports are different populations.
Has the TNFD stopped?
Not disbanded.
In November 2025 it said it would complete its technical work in progress by the third quarter of 2026, pause further technical guidance and support the ISSB, and conclude its technical programme subject to the ISSB’s process.
The framework remains published and usable.
When will nature reporting be required in the UK?
There is no date.
The ISSB’s exposure draft is targeted for October 2026 with a 120-day comment period, so a final Practice Statement cannot come before some months into 2027.
Any UK use would then need endorsement, and the FRC’s technical committee is at research stage on nature.
Is biodiversity net gain a reporting duty?
No. Biodiversity net gain is a 10% gain deemed a pre-commencement condition on planning permission for development in England.
It is an obligation on a development, not a corporate reporting duty, and the NERC Act biodiversity duty binds public authorities, not companies.
Is TNFD the same as TCFD?
No, but it is built on it.
The TCFD covered climate; the TNFD covers nature.
The TNFD keeps the TCFD’s four pillars and all eleven of its disclosures and adds three nature-specific ones, for fourteen.
The TCFD disbanded in October 2023 and its recommendations live on in IFRS S2; the TNFD’s framework remains published.
Does the TNFD use double materiality?
It leaves the choice to the preparer.
The first of its six general requirements asks the report to state which materiality approach it applies: the Recommendations accommodate the ISSB’s investor lens and an impact lens consistent with GRI.
The ISSB’s own nature output will take the investor lens.
What is nature-related disclosure?
Reporting on how a company depends on nature, how it affects nature, and the risks and opportunities that follow.
Under the ISSB’s standards and UK SRS it covers nature-related risks and opportunities that could affect the company’s prospects; under the TNFD’s impact option, GRI or the ESRS it can also cover the company’s impacts.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- TNFDRecommendations of the Taskforce on Nature-related Financial Disclosures (September 2023)
The fourteen recommended disclosures, the four pillars and the six general requirements.
- TNFDFinal recommendations launch release, 18 September 2023 (PDF)
“The final Recommendations are science-based and voluntary.”
- TNFDGuidance on the identification and assessment of nature-related issues: the LEAP approach, v1.1 (PDF)
The four phases and sixteen components.
- TNFDTNFD in a Box, Module 4 — the LEAP approach (PDF)
The five sensitive-location criteria: only one needs to be met.
- TNFDTNFD 2026 Status Report (September 2026)
802 committed; over 1,000 publishing; 56 countries or areas; US$26.6 trillion AUM.
- TNFDTNFD welcomes ISSB decision on nature-related standard-setting — 7 November 2025
Technical work in progress to complete by Q3 2026; new guidance paused.
- IFRS FoundationNature-related Disclosures — ISSB work plan project
Standard-setting; next milestone the exposure draft.
- IFRS FoundationISSB Update, April 2026
The output will be a proposed IFRS Practice Statement.
- IFRS FoundationISSB Update, July 2026
Permission to ballot; 120-day comment period; no member dissenting.
- IFRS FoundationStaff paper AP3D (April 2026), ¶¶55, 58
A Practice Statement “is not a Standard”; a jurisdiction can mandate it.
- IFRS FoundationNature-related disclosures — FAQs (PDF)
IFRS S1 already requires material nature-related information.
- IFRS FoundationSustainability Standards Advisory Forum paper, October 2026 (PDF)
“Nature Exposure Draft coming October 2026”; 120-day consultation.
- Financial Reporting CouncilSustainability Reporting Developments — FAQs
New ISSB pronouncements, nature named, would first need UK endorsement.
- Department for Business and TradeUK SRS S1 (PDF)
Material sustainability-related information, which can include nature.
- legislation.gov.ukNatural Environment and Rural Communities Act 2006, section 40
The biodiversity duty binds public authorities, not companies.
- legislation.gov.ukTown and Country Planning Act 1990, Schedule 7A
Biodiversity net gain: a planning condition, not a reporting duty.
- Convention on Biological DiversityKunming-Montreal Global Biodiversity Framework, Target 15
The international source of corporate nature disclosure; binds Parties, not companies.
- World Economic ForumNature Risk Rising (January 2020)
WEF’s estimate that $44 trillion of economic value generation is moderately or highly dependent on nature.
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