TNFD — Voluntary Today, With ISSB Nature Rules Out for Comment
The TNFD is the nature counterpart to the TCFD, and it is on the same trajectory. Its recommendations were published in September 2023, more than 800 organisations had adopted them by September 2026, and in October 2026 the International Sustainability Standards Board published proposed nature-related disclosure requirements that build on the Taskforce’s recommendations.
That makes this a page about a framework in transit. Everything on it is voluntary today. In October 2026 the ISSB published an exposure draft of nature-related disclosure requirements, in the form of an IFRS Practice Statement rather than a new standard. It is a proposal: comments close on 19 February 2027 and the text can still change.
It is also the third time the same thing has happened. The TCFD was structurally absorbed into IFRS S2. The SASB Standards were adopted by the ISSB in 2022 and are still maintained by it. Nature is next.
1. What the TNFD is, and is not
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2. The handover to the ISSB
The ISSB decided in late 2025 to set nature-related disclosure requirements that draw on the TNFD’s work. In April 2026 it chose to propose them as an IFRS Practice Statement rather than a new standard, and in October 2026 it published the exposure draft, IFRS Sustainability Disclosure Practice Statement 1 Nature-related Disclosures. Comments close on 19 February 2027. The ISSB says it drew on the TNFD’s recommendations, metrics and guidance (paragraph IN5) and on the requirement in IFRS S1 to disclose material sustainability-related information, which already covers material nature-related risks and opportunities. The draft names the TNFD’s LEAP approach version 2.0 (2026) as a process a company may follow, not one it must (paragraphs 11 and 12).
“Practice Statement” and “exposure draft” are both doing work in that paragraph. An exposure draft is a consultation document: it is published for comment, it can change, and it binds nobody. A Practice Statement, once final, is not required for a company to claim compliance with ISSB Standards, but a company that chooses to apply it must meet all of it, and a jurisdiction can make it mandatory. The sensible planning assumption is that the TNFD recommendations remain the reference point for voluntary nature disclosure into 2027.
What the ISSB has signalled is direction rather than detail: that nature disclosure will end up inside the IFRS Sustainability Disclosure Standards architecture, alongside IFRS S1 and IFRS S2, and that the TNFD’s work will be the raw material rather than being discarded.
3. What the ISSB draft would require, paragraph by paragraph
The draft is short: 38 paragraphs plus application guidance. Most of it adds a nature-specific layer to requirements that IFRS S1 already makes, so each row below says what it adds. Paragraph numbers are those of the exposure draft, ISSB/ED/2026/1, read on 27 October 2026; they can change in the final text.
| Area | Draft paragraphs | What it would add |
|---|---|---|
| Status | 3, IN7–IN8 | Not a Standard. A company can say it complies with ISSB Standards without applying it; one that applies it must meet all of it. A jurisdiction may make it mandatory or leave it optional. |
| Who can use it, and when | IN10–IN11, C3 | Companies that apply IFRS S1 and IFRS S2, from the date it is issued, starting at the beginning of an annual reporting period. No comparative figures in the first year. |
| Finding the risks | 10–12 | Consider where assets and activities sit across the value chain and what nature is like there, and the company’s dealings with Indigenous Peoples, Local Communities and affected stakeholders. LEAP may be used; it is not required. |
| Link to climate | 13 | Show how nature-related and climate-related risks connect, without repeating information; one integrated disclosure is allowed. |
| Governance | 15 | Whether and how the board and management take account of location and of engagement with Indigenous Peoples, Local Communities and affected stakeholders. |
| Strategy | 17–19 | Location detail (for example the landscape or river basin a risk depends on), the groups of people affected, where risks concentrate in the business model, and how the company is responding and paying for it, including trade-offs with climate action such as land taken for on-site renewables. |
| Resilience | 20–24 | Nature-related scenario analysis, “commensurate with the entity’s circumstances”, with its inputs, scenarios, time horizons, locations and key assumptions disclosed. |
| Risk management | 26–28 | How location, climate trade-offs and stakeholder engagement feed the processes that find and rank nature risks, and whether scenario analysis informs them. |
| Metrics | 30–33 | Two required numbers: the amount and percentage of assets or business activities vulnerable to nature-related risks, and aligned with nature-related opportunities, broken down by location where that is material. The TNFD’s metrics may be used as guidance, not as a requirement. |
| Targets | 34 | For each nature target: what it covers, which locations, whether it is shared with others in the same place, and whether a law or regulation shaped it. |
| Reliefs | 36–37 | Information may be left out where a law forbids disclosing it, and information about an opportunity where it is commercially sensitive. The second relief never covers risks. |
Comments close on 19 February 2027. The ISSB prefers responses through its online survey and also takes comment letters; every response is published unless confidentiality is granted.
4. Work out the two exposure metrics
Paragraph 30(a) is the one entirely new number the draft asks for. It is built on the TNFD core global metrics C7.0 and C7.1 (Basis for Conclusions BC191), with one difference: the TNFD splits physical risk from transition risk, and the ISSB draft does not, because in practice the two are often hard to separate. You choose the measure (carrying amount of assets, revenue, costs) and explain it. The calculator opens on the ISSB’s own worked example from its Accompanying Guidance, Example 2, so you can check it against the source before using your own figures.
It opens on the ISSB’s own worked example (Entity C, a forestry company). Replace the figures with yours; nothing you type leaves your browser.
Activities aligned with nature-related opportunities (30(a)(ii))
| Measure | Amount (million CU) | % |
|---|---|---|
| Carrying amount of productive forestry assets assessed as vulnerable to nature-related risks | 360 | 24% |
| Region A | 300 | 20% |
| Other regions | 60 | 4% |
| of which in: soil condition affects productive capacity | 360 | 24% |
| Revenue from products meeting the land-management and traceability criteria (aligned with nature-related opportunities) | 210 | 10% |
Region A holds 83.3% of the vulnerable amount. Paragraph 31 asks you to decide whether to show a concentration like this separately; in the ISSB’s own example, Entity C shows Region A separately because it holds most of the vulnerable assets. We flag any location holding half or more; whether it is material is your judgement.
Each percentage uses the total you entered as the denominator (the opportunity line uses its own total), as in the ISSB’s example. The draft lets you choose the measure, such as carrying amount, revenue or costs, and asks you to explain it and link it to the financial statements (IFRS S1 paragraphs 49 to 50).
The calculator only does the arithmetic and the layout of paragraphs 30 to 33. Deciding which assets are vulnerable needs your own assessment, using all reasonable and supportable information available without undue cost or effort (paragraph 33(a)). Our 50% concentration flag is a prompt, not a rule from the draft.
5. The 14 recommended disclosures — 11 borrowed, 3 new
The TNFD did not invent a reporting architecture. It took the eleven TCFD recommended disclosures, recast them for nature, and added three: on stakeholder rights and engagement, on priority locations, and on managing risks and impacts in the value chain. That was a deliberate design decision, and it is the single most useful fact for anyone who already reports against TCFD or IFRS S2: the shape is familiar, and the work is extension rather than replacement.
| Pillar | What it asks | Where the ISSB draft picks it up |
|---|---|---|
| Governance | Board oversight and management’s role in nature-related dependencies, impacts, risks and opportunities — plus human rights policies and engagement with affected stakeholders, including Indigenous Peoples and local communities. | Paragraph 15, and the engagement points in 17(b), 18(c), 19(d) and 26(c) |
| Strategy | The effects on business model, strategy and financial planning, including resilience, and the locations of assets and activities in sensitive places. | Paragraphs 17 to 24; location runs through 10(a), 17(a), 18(a), 26(b) and 31 |
| Risk and Impact Management | How dependencies, impacts, risks and opportunities are identified, assessed, prioritised and monitored — and how that process integrates with overall risk management. | Paragraphs 26 to 28; the value chain is in 10(a) |
| Metrics and Targets | The metrics used to assess and manage material nature-related matters, and performance against targets. | Paragraphs 30 to 34; TNFD metrics as optional guidance in 30(b) |
The third column is our reading of the draft against the TNFD pillars, not a mapping the ISSB has published.
6. The word that changed, and why it matters
The TCFD’s third pillar is “Risk Management”. The TNFD’s is “Risk and Impact Management”. That inserted word is the whole conceptual difference between climate disclosure as it was first framed and nature disclosure as the TNFD frames it.
The TNFD organises this around four things, and the vocabulary is worth learning because the ISSB has said it will draw on it:
The causal chain runs left to right and back again. Dependencies and impacts are the underlying reality; risks and opportunities are how that reality reaches the accounts. A disclosure that reports risks without the dependencies underneath has skipped the part that explains it.
7. LEAP — the assessment approach
LEAP is the TNFD’s method for working out what to disclose, and the ISSB draft names it (version 2.0, published in 2026) as a process a company may follow, though it adds that LEAP is not wholly aligned with ISSB terms (Basis for Conclusions BC102). It is not itself a disclosure requirement; it is how you get to one.
Climate reporting can be done from an accounting system: buy this much fuel, apply this factor, report the result. Nature reporting cannot. It requires knowing where your operations and your suppliers physically are, and whether those places are ecologically sensitive — which for most organisations means location data they have never had to assemble. If a nature programme stalls, it usually stalls here, and it stalls on data availability rather than on method.
8. Nature is local, and that changes the data problem
This is the structural difference from greenhouse gas accounting, and it is worth stating plainly because it defeats the instinct to reuse the climate playbook.
| Greenhouse gases | Nature | |
|---|---|---|
| Does location matter? | No, for the atmospheric effect. A tonne is a tonne. | Yes. The same abstraction, discharge or land use has completely different consequences in different places. |
| Unit of account | One — CO2e | Many, and not commensurable. Water, land, species, soil, pollutants. |
| Can you aggregate? | Yes, across the whole organisation | Only with care. A global total can hide the site that matters. |
| Primary data need | Activity data — volumes, spend, distances | Activity data and geolocation, including in the value chain |
| Where it usually fails | Scope 3 coverage | Knowing where suppliers physically operate |
The practical consequence: a mature greenhouse gas inventory gets you further with ESRS E1 than it does with nature. The governance and process work transfers; the data does not.
9. Adoption
The TNFD maintains a public register of adopters — organisations that have committed to publish TNFD-aligned disclosures. By September 2026, more than 800 organisations in a majority of industries had adopted the recommendations, according to the ISSB’s Basis for Conclusions on its nature draft (paragraph BC59(e)), which cites the TNFD’s own September 2026 update.
That number is given with the period it was true for, and it will go out of date as reporters respond to the ISSB exposure draft. It is included to convey scale — hundreds of organisations rather than a handful — not as a current statistic. The TNFD publishes periodic status reports and its adopter register; check those rather than this page for a live count. We re-check this figure every six months.
Adoption matters for a reason beyond the number. A framework with more than 800 committed reporters produces a body of practice, and that practice is what the ISSB has to build on. The ISSB’s October 2026 exposure draft builds on that body of practice.
10. TNFD alongside the frameworks that do bind
| Framework | Relationship to TNFD | Binding? |
|---|---|---|
| ESRS E4 (biodiversity) | The European mandatory counterpart. Where CSRD applies and biodiversity is material, E4 is a requirement; TNFD is not. The two ask overlapping questions and TNFD work is usable as input. | Yes, under CSRD |
| IFRS S1 | Requires disclosure of material sustainability-related risks and opportunities generally — which can include nature — without a nature-specific standard yet existing. | Where adopted |
| GRI | Impact reporting to a broad stakeholder audience, with its own biodiversity standard. Different audience from TNFD’s investor framing, overlapping subject matter. | Voluntary |
| TCFD | The architectural parent. TNFD borrowed eleven of its disclosures and its four-pillar structure. | Absorbed into IFRS S2 |
| CSDDD and the EU Deforestation Regulation | Not disclosure regimes but due-diligence ones. They ask about the same value-chain locations TNFD’s Locate step identifies. | Yes, in scope |
The pattern is the one running through this whole part of the corpus: the voluntary framework arrives first, gets adopted, and is then either absorbed by a standard-setter or overtaken by a regulator. TNFD is at the absorption point now.
11. What to do while the handover happens
- Start with Locate, whatever framework wins. Knowing where your operations and suppliers physically are is required by TNFD, by ESRS E4, by deforestation due diligence, and by any nature standard the ISSB writes. It is the one investment that cannot be wasted.
- Respond by 19 February 2027 if the draft affects you. It is a proposal and can still change; the ISSB asks, among other things, whether the content should become a Standard instead (Question 1 and paragraph IN9). The data work takes longer than the standard-setting, so do not wait for the final text to start it.
- Reuse the TCFD or IFRS S2 governance you already have. Eleven of the fourteen disclosures are the ones you are already answering, recast. The board oversight and process descriptions transfer with editing, not rebuilding.
- If CSRD reaches you, ESRS E4 is the binding obligation. Treat TNFD as the method that helps you answer it, not as an alternative to it.
- Try the two paragraph 30(a) numbers on one region. The calculator above shows the layout the ISSB uses in its example. Choosing the measure and the denominator, and linking them to the financial statements, is where most of the judgement sits.
- Record what you assessed and concluded. A nature assessment that found little is a finding; one that was never made is a gap, and the distinction only exists if it is documented.
12. How GreenCalculus implements this
Our corpus is strongest on the greenhouse gas side of nature-related reporting, and honest about where that stops.
- Nature exposure calculator — the two paragraph 30(a) metrics of the ISSB draft, in the browser, with nothing sent or stored.
- ISSB adoption tracker — the 37 jurisdictions on the IFRS Foundation’s list, and where each stands on IFRS S1 and S2. A jurisdiction that adopts them could also mandate the nature Practice Statement once it is final.
- FLAG emissions methodology — forest, land and agriculture emissions, where climate accounting and land-use change meet.
- GHG Protocol Land Sector and Removals Standard — the accounting standard for land-based emissions and removals.
- SBTi FLAG guidance — target setting for land-intensive sectors.
What we do not hold is biodiversity or ecosystem-condition data. A nature assessment needs spatial and ecological inputs that are not emission factors, and this page should not imply otherwise. Where a TNFD or ESRS E4 assessment produces a greenhouse gas number, the factors behind it carry their edition and provenance in the MasterBrain; the rest of the assessment comes from elsewhere.
13. Frequently Asked Questions
No. The TNFD is a voluntary framework published by a market-led taskforce, not a standard issued by a standard-setter, and no regulator requires it. Organisations adopt it by public commitment. Where nature reporting is mandatory the requirement comes from somewhere else — ESRS E4 under the CSRD, for example — and not from the TNFD itself.
Its work is being taken on rather than discarded. The ISSB decided in late 2025 to set nature-related disclosure requirements that draw on the TNFD’s work, and its October 2026 exposure draft builds on the TNFD recommendations. It is the same pattern as the TCFD, which was absorbed into IFRS S2, and the SASB Standards, which the ISSB adopted in 2022 and still maintains.
No. In October 2026 the ISSB published an exposure draft of nature-related disclosures in the form of an IFRS Practice Statement, not a new standard; comments close on 19 February 2027. An exposure draft is a consultation document: it is issued for comment, it can change, and it binds nobody. There is no final ISSB nature requirement yet.
For companies that choose to apply it, or are required to by their regulator: nature-specific detail under each IFRS S1 pillar (how location and engagement with Indigenous Peoples, Local Communities and affected stakeholders shape governance, strategy and risk management), a nature-related scenario analysis of resilience, the links to climate risks, details of any nature targets, and two numbers: the amount and percentage of assets or business activities vulnerable to nature-related risks and aligned with nature-related opportunities (paragraph 30(a)). The TNFD metrics may be used as guidance but are not required.
Pick a measure that links to your financial statements, such as the carrying amount of assets or revenue, add up the amount you have assessed as vulnerable, and divide by the total of the same measure. In the ISSB’s example, a forestry company with productive forestry assets of 1,500 million currency units assesses 360 million as vulnerable to soil deterioration: 24%. Region A holds 300 million (20%) and is shown separately because the concentration is material. Our calculator on this page does the arithmetic and the breakdown.
Directly and deliberately. The TNFD adopted the TCFD’s four-pillar structure and recast its eleven recommended disclosures for nature, then added three more covering nature-specific matters including stakeholder engagement. If you already report against TCFD or IFRS S2, the architecture is familiar and the work is extension rather than replacement — though the underlying data is a different problem.
Locate, Evaluate, Assess, Prepare — the TNFD’s method for working out what to disclose. Locate finds your interface with nature and which of those places are ecologically sensitive; Evaluate identifies dependencies and impacts there; Assess turns those into risks and opportunities and sizes them; Prepare decides the response, targets and disclosure. It is not itself a disclosure requirement, and the ISSB has said it will draw on it.
Because location matters. A tonne of CO2 has the same atmospheric effect wherever it is emitted, so a carbon inventory can be built from an accounting system. The same water abstraction or land conversion has entirely different consequences in different places, so nature assessment needs to know where operations and suppliers physically are — data most organisations have never had to assemble. There is also no single unit: water, land, species and pollutants are not commensurable the way greenhouse gases are.
If the CSRD reaches you and biodiversity is material, ESRS E4 is the obligation and TNFD is not an alternative to it. The useful framing is that TNFD supplies a method — particularly LEAP — for producing the assessment that E4 requires you to report. Many organisations run the TNFD process and report the results through whichever regime binds them.
The location work, because every route requires it. Knowing where your operations and value chain physically sit is needed by the TNFD, by ESRS E4, by deforestation due diligence and by any nature standard the ISSB writes. It is also the part that takes longest and the point at which most nature programmes stall. The governance and process descriptions you already have for TCFD or IFRS S2 transfer with editing; the location data does not exist until you build it.
Related References
- TCFD — the architectural parent, absorbed into IFRS S2
- IFRS S2 — where climate disclosure landed
- SASB Standards — the ISSB’s earlier adoption, and how it went
- CSRD / ESRS E1 — the European regime that contains E4
- GHG Protocol Land Sector and Removals — land-based emissions and removals
- FLAG emissions — forest, land and agriculture accounting
