TNFD reporting requirements UK: voluntary, and what could change

No. On 11 October 2026 no UK law or regulator’s rule requires a company to report against the TNFD recommendations.

The TNFD describes its recommendations as voluntary, and the government’s 2023 Green Finance Strategy committed only to explore how the framework should be incorporated into UK policy.

For an organisation that chooses to use them, the TNFD recommendations set general requirements and 14 recommended disclosures across four pillars: governance, strategy, risk and impact management, and metrics and targets.

They carry over the TCFD’s eleven recommended disclosures and add three on nature.

None of this is a UK legal requirement.

Yes, by another route.

UK SRS S1 requires an entity applying it to disclose material information about sustainability-related risks and opportunities, which can include nature.

Listed companies in scope of the FCA’s PS26/19 report against UK SRS S1 on a comply-or-explain basis, after a climate-first relief that ends for periods beginning on or after 1 January 2029.

LEAP is the TNFD’s approach to identifying and assessing nature-related issues: Locate the interface with nature, Evaluate dependencies and impacts, Assess risks and opportunities, and Prepare to respond and report. It is guidance, not a requirement.

The ISSB is standard-setting on nature, but it decided in April 2026 to propose its requirements in the form of an IFRS Practice Statement.

Its staff describe a Practice Statement as non-mandatory and not a Standard, though a jurisdiction can choose to mandate it.

The exposure draft is due to be launched on 22 October 2026.

The IFRS Foundation announced on 6 October 2026 that the exposure draft will be open for a 120-day consultation ending on 19 February 2027.

No final Practice Statement date has been set.

No. The FRC says any new or amended ISSB standards, for example on nature-related disclosures, would not automatically apply in the UK and would first need to go through the UK’s endorsement process.

The FRC’s technical advisory committee has a nature research project whose plan was approved on 21 April 2026.

In a written answer on 7 April 2026 the government said it continues to be a strong supporter of the TNFD, that Defra funds the Green Finance Institute to help UK companies engage with it, and that Defra, DBT and the FRC are following the ISSB’s nature work and stand ready to use the established process to assess and endorse it when it is finalised.

Only where nature-related risks or opportunities are material.

UK SRS S1 asks for material information about sustainability-related risks and opportunities that could affect an entity’s prospects; the ISSB states that IFRS S1, on which UK SRS S1 is based, already requires material nature-related information.

Not closing, but winding down its technical work.

In November 2025 the TNFD said it would complete technical work in progress by the third quarter of 2026, pause any further technical guidance, and, subject to the ISSB’s process, conclude its technical work programme. It has not disbanded, and its recommendations remain published.

The TNFD’s 2026 Status Report, released on 21 September 2026, says more than 1,000 organisations across 56 countries or areas have published some TNFD-aligned disclosure, and more than 800 organisations, with US$26.6 trillion in assets under management among financial institutions, identify as TNFD Adopters.

No. Section 40 of the NERC Act 2006 is a duty on public authorities, and the reporting duty in section 40A applies to local authorities, local planning authorities and designated authorities in England.

Neither creates a reporting duty for an ordinary company.

BNG is a planning regime in England: most planning permissions carry a deemed condition that a biodiversity gain plan is approved before development begins, aiming at a 10% gain.

It binds developers through planning, not corporate reporting, though a developer may choose to describe it in a TNFD-aligned report.

No. Target 15 asks Parties to take legal, administrative or policy measures to encourage and enable businesses to disclose their risks, dependencies and impacts on biodiversity. It is addressed to governments, not companies.

That is a choice, not a duty.

The ISSB has encouraged market participants to continue using the TNFD framework to help prepare disclosures in accordance with IFRS S1 and for future ISSB requirements, and the ISSB’s nature proposals draw on the TNFD.

Three things, all still ahead: the ISSB’s exposure draft and final Practice Statement; a UK endorsement assessment, for which there is no date; and any decision by the government or the FCA to require it.

None has happened on 11 October 2026.