POLICY & GOVERNANCE / VOLUNTARY FRAMEWORKS
TNFD & LEAP
Taskforce on Nature-related Financial Disclosures
The disclosure framework that goes where climate reporting leaves off: maps your business to specific ecosystems, evaluates what you depend on and what you damage, and connects your nature footprint to financial risk and opportunity.
In 30 seconds
TNFD (Taskforce on Nature-related Financial Disclosures) published its final recommendations in September 2023. It provides a framework for organisations to identify, assess, manage, and disclose their nature-related dependencies, impacts, risks, and opportunities. By mid-2025, over 620 organisations from more than 50 countries had committed to TNFD-aligned disclosures, representing over $20 trillion in assets under management.
TNFD is built on the same four-pillar structure as TCFD (Governance, Strategy, Risk Management, Metrics and Targets) but addresses nature rather than climate. Its practical methodology is called LEAP: Locate, Evaluate, Assess, Prepare. By 2026 more than 730 organisations had adopted TNFD-aligned disclosure, representing around $9 trillion in market capitalisation and $22 trillion in assets under management.
2026 update: the handoff to the ISSB. In April 2026 the ISSB announced it will develop nature-related disclosures as an IFRS Practice Statement, drawing on TNFD's LEAP approach, with an exposure draft expected at CBD COP17 (October 2026). TNFD is pausing its own technical work. This mirrors the TCFD to ISSB climate journey: TNFD proved the demand, and the ISSB now carries nature disclosure toward the global baseline. The practical implication is to keep building LEAP capability, while tracking the ISSB as the destination for nature disclosure.
The key difference from CDP: TNFD starts with geography (where exactly your business touches nature) before asking what that means. CDP is a questionnaire platform covering climate, water, forests, and biodiversity; TNFD is a methodology you apply to your specific locations, then disclose through your own annual report. CDP's biodiversity questionnaire covers some of the same territory, but does not require TNFD's full LEAP analysis, nature scenario analysis, or financial risk assessment.
The LEAP methodology
LEAP is the practical engine of TNFD. It is a four-step process for identifying nature-related issues across your business and value chain, from mapping your footprint to producing a disclosure. The steps build sequentially; each depends on the previous.
Where does your business interface with nature?
Map your business locations, operations, and supply chain footprint against areas of ecological sensitivity: biodiversity hotspots, protected areas, water-stressed catchments, deforested landscapes. Use spatial tools including the IBAT (Integrated Biodiversity Assessment Tool) database and biome mapping.
KEY OUTPUTS
- ✓Footprint map of operations and key supply chain nodes
- ✓Overlay with biodiversity and ecosystem sensitivity data
- ✓Identification of priority locations for deeper assessment
What are your dependencies and impacts on nature?
At each priority location, evaluate which ecosystem services your business depends on (water supply, pollination, soil formation, climate regulation) and where your operations negatively impact nature (land use change, pollution, water extraction, invasive species). Use the ENCORE tool (Exploring Natural Capital Opportunities, Risks and Exposure) for dependency mapping.
KEY OUTPUTS
- ✓Dependency register: which ecosystem services your business model relies on
- ✓Impact register: where and how your operations affect nature
- ✓Materiality ranking of dependencies and impacts
What nature-related risks and opportunities does this create?
Convert the dependencies and impacts into financial risk and opportunity categories. Physical risks (ecosystem degradation threatening supply), transition risks (regulatory change, market shifts, reputational exposure), systemic risks (tipping points that affect the wider economy). Also identify opportunities: new markets, products, financing routes that arise from nature-positive positioning.
KEY OUTPUTS
- ✓Nature-related risk register with financial exposure estimates
- ✓Opportunity identification (nature markets, green finance, procurement relationships)
- ✓Scenario analysis across 1.5°C, 2°C, and high-impact nature loss pathways
How will you disclose and respond?
Produce the TNFD-aligned disclosure across four pillars (Governance, Strategy, Risk and Impact Management, Metrics and Targets) and design your response: targets, management actions, and monitoring systems. TNFD recommends aligning targets with the Kunming-Montreal Global Biodiversity Framework (30x30, nature-positive by 2030) and with SBTN science-based nature targets.
KEY OUTPUTS
- ✓TNFD disclosure document (14 recommended disclosures across four pillars)
- ✓Nature-related targets and commitments
- ✓Monitoring and reporting system design
The four disclosure pillars
TNFD disclosure follows the same four-pillar structure as TCFD (Governance, Strategy, Risk and Impact Management, Metrics and Targets), with 14 recommended disclosures across the pillars. If your organisation already reports against TCFD or IFRS S2, the structure is familiar; the content is significantly more complex given nature's multi-dimensionality and the addition of impact management as a distinct discipline.
The 14 recommended disclosures span four pillars
Board oversight of nature-related dependencies, impacts, risks and opportunities. Management roles and responsibilities. How nature is integrated into governance structures.
Nature-related risks and opportunities identified over short, medium, and long time horizons. Effect on business model, strategy, and financial planning. Resilience of strategy under different nature scenarios.
Processes for identifying, assessing, and prioritising nature-related dependencies, impacts, risks and opportunities. Integration into overall risk management. Impact management processes (mitigation hierarchy).
Metrics used to assess and manage nature-related dependencies, impacts, risks and opportunities. Targets set, and performance against targets. Cross-reference to SBTN, GBF, and sector-specific metrics.
All 14 recommended disclosures
Framework context
TCFD: the framework TNFD mirrors
TCFD (Task Force on Climate-related Financial Disclosures) was established by the Financial Stability Board in 2015 and published its recommendations in 2017. It established the same four-pillar structure that TNFD now uses for nature. In October 2023, TCFD declared its mission complete and disbanded; its recommendations had been absorbed into mandatory frameworks.
TCFD recommendations now live inside IFRS S2 (the global climate standard issued by the ISSB, now mandatory or being adopted across major markets), UK mandatory climate reporting (large listed companies and financial services firms), and ESRS E1 (the EU CSRD climate standard). Like TNFD, TCFD disclosures appear in company annual reports, not submitted to a central platform.
TNFD was deliberately designed as nature's answer to TCFD and published in September 2023, effectively the month TCFD retired. The four-pillar structure is the same by design.
CDP alignment note
CDP is a disclosure platform, not a framework. Its climate questionnaire is aligned with TCFD and IFRS S2 methodology, but completing CDP is a separate exercise from TCFD-aligned disclosure in an annual report. Both can be relevant to the same company; neither replaces the other.
CDP's Biodiversity questionnaire partially aligns with TNFD LEAP recommendations, but the alignment is partial. Completing CDP Biodiversity does not satisfy TNFD, particularly on the financial risk assessment and scenario analysis requirements.
Nature-related risk categories
TNFD distinguishes three categories of nature-related risk. All three can be financially material. The systemic risks are the most difficult to quantify but the most important at the portfolio level.
How an organisation actually discloses against TNFD
Unlike CDP, TNFD has no submission portal. There is no login, no questionnaire, no score. TNFD-aligned disclosures are produced by the organisation and published in its own reports. This is by design: TNFD intends nature-related financial risk to sit inside mainstream financial reporting, not in a specialist data system.
1. Conduct the LEAP analysis
Work through Locate, Evaluate, Assess, Prepare across your operations and value chain. This is the analytical foundation. It can take months for a large organisation; a focused assessment for a smaller business with a defined land footprint is significantly faster. The LEAP outputs are the raw material for the disclosure.
2. Draft the four-pillar disclosure
Write the 14 recommended disclosures across Governance, Strategy, Risk and Impact Management, and Metrics and Targets. This is a narrative and data document, typically several pages in the sustainability or environmental section of an annual report or standalone sustainability report. No prescribed format; TNFD provides guidance and sector-specific worked examples.
3. Publish in your annual or sustainability report
The primary vehicle is the company's own published report. For most organisations this means the annual report (sustainability section) or a standalone ESG or nature report published alongside the annual report. The company owns the document; it is not submitted to TNFD.
4. Register on the TNFD voluntary disclosure register
TNFD operates a public register where organisations record that they are making TNFD-aligned disclosures and link to where those disclosures appear. This makes the disclosure findable by investors and analysts. The register is a signposting mechanism; TNFD does not hold or verify the data itself.
How investors find it
Investors and analysts access TNFD disclosures by reading company reports directly, or through data aggregators (Bloomberg, MSCI, Sustainalytics) that scrape and structure published disclosures. Unlike CDP, there is no instant visibility into a database, which is one reason early TNFD adoption has been slower to translate into investor-usable data.
The regulatory trajectory
ESRS E4 (EU biodiversity reporting under CSRD) broadly aligns with TNFD LEAP, meaning large EU companies in scope are effectively producing TNFD-style disclosures in statutory sustainability reports. The UK is watching. When TNFD is embedded in mandatory requirements, the vehicle becomes a regulated annual report filed with authorities, still not a central platform.
CDP and TNFD together: CDP's integrated questionnaire covers climate, water, forests, and biodiversity, including nature dependencies and impacts that overlap with TNFD territory. But a CDP submission does not constitute TNFD disclosure. Investors receiving your CDP data will not have your TNFD-aligned financial risk assessment or scenario analysis. For organisations with material nature exposure, both are relevant: CDP as the investor-facing platform submission, TNFD as the framework for the full disclosure in your annual report.
TNFD vs CDP: how they relate
They are parallel, not competing, but different in kind. CDP is a disclosure platform: you submit questionnaire data covering climate, water, forests, and biodiversity to a central system, where it is scored and shared with investors. TNFD is a framework for annual report disclosure: you conduct a LEAP analysis and publish four-pillar narrative in your own reports. Completing CDP does not satisfy a mandatory TNFD-aligned reporting obligation, and vice versa. In practice, CDP questionnaire data often feeds the TNFD disclosure work, but they are not interchangeable.
| Dimension | TNFD | CDP |
|---|---|---|
| What it is | A disclosure framework: you conduct a LEAP analysis and publish four-pillar narrative in your own annual or sustainability report | A disclosure platform: you submit questionnaire responses to a central system, which scores them and makes the data available to investors |
| Disclosure vehicle | Your annual report or sustainability report. No portal, no score. TNFD operates a voluntary register where organisations signal adoption; the disclosure itself lives in your own published documents. | The CDP platform. Investors access data via CDP's system. A CDP submission does not substitute for annual report disclosure obligations under ESRS E4, IFRS S2, or UK mandatory climate rules. |
| Coverage | All nature: biodiversity, water, soil, land, ocean, assessed through the lens of your specific geographic locations and value chain | Climate, water security, forests, and biodiversity, all integrated into a single questionnaire since 2024 |
| Starting point | Geography: where exactly does your business touch nature? LEAP Step 1 (Locate) must happen before any topic questions can be answered. | Topic-based questions: a structured questionnaire covering activities, governance, targets, and data across defined topic areas |
| International alignment | Kunming-Montreal Global Biodiversity Framework (30x30, nature-positive by 2030) and SBTN science-based nature targets | Paris Agreement (1.5°C) for climate; GBF-aligned for biodiversity questionnaire |
| Mandatory trajectory | ESRS E4 (EU CSRD) already makes TNFD-aligned nature disclosure mandatory for large EU companies from 2024. UK mandatory nature reporting expected to follow. | Voluntary platform. Does not satisfy mandatory annual report obligations under ESRS E4, IFRS S2, or UK climate rules. Completion driven by investor demand (over $110 trillion AUM signatories request it). |
TNFD and SBTN: disclosure and target-setting
TNFD and SBTN (Science Based Targets for Nature) are designed as a pair. TNFD provides the framework for assessing and disclosing nature-related risks and opportunities: the LEAP methodology, the four pillars, the annual report output. SBTN provides the methodology for setting credible, science-based nature targets: the commitment that TNFD's strategy and metrics disclosures point toward. Neither is complete without the other.
Without SBTN: TNFD maps but does not commit
TNFD's MET-C and STR-B disclosures require organisations to describe their nature-related targets and transition plans. Without SBTN, those sections are either empty or filled with non-scientific aspirational statements. SBTN is the methodology that makes those commitments credible and verifiable.
Without TNFD: SBTN has no disclosure vehicle
SBTN produces validated, location-specific nature targets. But targets need to be disclosed: in annual reports, in CSRD ESRS E4 statements, in investor-facing reporting. TNFD is the structure that determines where and how SBTN targets appear publicly. SBTN generates the content; TNFD structures the publication.
SBTN ≠ SBTi: SBTi (Science Based Targets initiative) covers climate: greenhouse gas reduction targets aligned to 1.5°C. SBTN (Science Based Targets Network) covers nature: freshwater, land, ocean, and biodiversity targets aligned to the Kunming-Montreal Global Biodiversity Framework. Separate bodies, separate methodologies, explicitly designed to be pursued as a pair. CSRD incorporates both: ESRS E1 for climate, ESRS E4 for nature.
Who TNFD matters most to
Nature risk is not evenly distributed. Sectors with direct land, water, or biodiversity dependencies face the most material exposure. Sectors with large supply chain footprints face significant indirect exposure.
A DIFFERENT PERSPECTIVE
If you manage the land, not just depend on it
Most TNFD guidance is written for the organisation that uses nature: the food business that depends on pollination, the manufacturer that draws on water. For land managers, estates, and farming operations, the framing inverts.
You are not the entity conducting LEAP to map your exposure to someone else's ecosystem. You are the ecosystem that others' LEAP analyses land on. When a food company runs LEAP Step 1 and identifies a priority agricultural landscape or water catchment, your land is what they find.
What this means for a land steward
- ✓Your land management practices flow into corporate nature disclosures upstream in supply chains
- ✓Demonstrating nature-positive management strengthens your position as a preferred supply chain partner
- ✓Nature data you generate (species surveys, soil health, water quality) has financial value to organisations that depend on your ecosystem services
- ✓TNFD's mitigation hierarchy drives demand for high-quality restoration on land like yours; biodiversity offsets sit at the end of the hierarchy, not as a substitute for impact reduction
The data ownership question
As TNFD drives corporate demand for nature data, the question of who owns the data generated from your land matters. Nature monitoring contracts, MRV agreements, and supply chain transparency programmes all involve data flowing from your land into someone else's disclosure.
Understanding what you contribute, and what terms govern that contribution, is part of the emerging land steward position in the nature-finance ecosystem.
A DIFFERENT PERSPECTIVE
If you run a small business
Direct TNFD reporting is designed for large organisations with complex supply chains and investor obligations. You almost certainly don't need to produce a TNFD disclosure. But TNFD shapes the environment small businesses operate in, through four channels that are worth understanding now rather than later.
Why it reaches you anyway
- ✓Supply chain data requests: Your large clients are conducting TNFD LEAP and need nature data from their suppliers. That data request flows down the chain, to you.
- ✓Green finance conditions: Bank loans with sustainability covenants, impact investment, and government grants increasingly reference TNFD-aligned frameworks in their criteria.
- ✓Public sector procurement: UK government procurement policy (PPN 06/21) is building sustainability requirements that follow the same logic as TNFD for supply chain partners.
- ✓CDP SME questionnaire: CDP is developing an SME questionnaire with a TNFD-aligned methodology. Early familiarity with the framework reduces the effort when it arrives.
What matters now
- ✓Land footprint: If you run a farm, rural business, or estate, you are already the subject of someone else's TNFD LEAP analysis. Understanding what buyers and funders are assessing strengthens your position.
- ✓Sector exposure: If your product or service touches food, materials, water, or land, your largest customers are mapping TNFD nature dependencies in your sector, which means they are mapping you.
- ✓Early mover advantage: SBTN for nature is approximately where SBTi was in 2017. Businesses that engaged with SBTi early gained supply chain access and financing advantages. The same pattern is emerging for nature.
- ✓Vocabulary fluency: Understanding the terms (LEAP, ecosystem services, priority locations, nature-positive) helps you engage credibly with large buyers, funders, and public sector clients who are already using them.
The practical starting point: read the LEAP methodology above, particularly Step 1 (Locate). The question “where does your business interface with nature?” is exactly the question your large customers are asking about their supply chains, which means they are asking it about you. Knowing how to answer it puts you ahead of most small businesses.
The Pandion view on TNFD
TNFD fills the gap CDP cannot close.
CDP's climate questionnaire is built around a single measurable metric: the tonne of CO2 equivalent. Nature does not have a single metric. TNFD acknowledges this: it covers biodiversity, water, soil, land, and ocean across four ecosystem categories. For any organisation with a meaningful nature interface (a farm, a landscape estate, a food business, a timber company) CDP alone is structurally insufficient. TNFD is not an addition to CDP; it addresses a different question.
LEAP starts with geography, not accounting.
The most important shift TNFD makes is that it starts with location. Where is your footprint? What ecosystems does it touch? This is fundamentally different from the carbon accounting approach, which starts with emission sources and works outward. For organisations with a defined land footprint (estates, farms, rural businesses) LEAP Step 1 (Locate) is often partially done already through designations, surveys, and management plans. The work is often in evaluation and framing, not discovery.
The mitigation hierarchy is the practical engine.
TNFD expects organisations to apply the mitigation hierarchy to their nature impacts: Avoid → Reduce → Restore → Offset. This sequencing matters. The hierarchy establishes that buying biodiversity credits is not equivalent to avoiding damage in the first place. For organisations thinking about BNG credits or voluntary biodiversity offsets, TNFD's framing places those instruments at the end of the hierarchy, not as a substitute for impact reduction.
TNFD and SBTN are designed to work together.
TNFD provides the disclosure framework (what to report). SBTN provides the target-setting methodology (what to commit to). An organisation doing TNFD LEAP without SBTN has mapped its nature risks without committing to address them. An organisation doing SBTN without TNFD has set targets without a disclosure vehicle. The two are intended as a pair, and aligning both with CDP biodiversity, BNG, and WCC creates the complete nature-finance picture.
Where to go next
SBTN
The nature target-setting pair to TNFD: how to set credible, location-specific science-based targets for freshwater, land, ocean, and biodiversity
SBTi
Science-based climate targets, the climate counterpart to SBTN, coordinated rather than duplicated for land-sector organisations
CDP
How CDP and TNFD work together, and where CDP's nature coverage stops
Biodiversity markets
How TNFD connects to BNG, biodiversity credits, and nature finance instruments