On the Ground: Exploring the Rise of TNFD Reporting and Nature-Related Disclosures

Key Insights

Nature-related disclosure is quickly becoming a corporate reality. Driven by regulatory mandates such as the Corporate Sustainability Reporting Directive¹ and proactive industry efforts like the Taskforce on Nature-related Financial Disclosure (TNFD) recommendations, this shift is gaining momentum. The integration of Target 15 of the Global Biodiversity Framework into national strategies this year will further amplify this trend. Target 15 requires businesses to disclose their risks, dependencies, and impacts on biodiversity,² and the TNFD will play an important role in facilitating this implementation by countries.

Consequently, an increasing number of businesses are expected to adopt nature-related disclosure as a standard practice. While regulation will ultimately drive this shift, first-mover organizations are already taking proactive steps. These front-runners recognize the materiality of their biodiversity impacts and dependencies, acknowledging the associated risks and opportunities. To date, over 370 organizations have signaled their intent to align with the TNFD recommendations in their corporate reporting – a number that will continue to grow throughout this year.³ The TNFD will announce the next cohort of adopters during London Climate Action Week at the end of June 2024.

In this article, we draw upon insights gained from our stewardship engagement with 50 companies across the agricultural value chain. Through this lens, we examine the evolving landscape of nature-related disclosure, highlighting key trends observed during our engagement.

Trend One: Rapid Adoption of TNFD Reporting Among Leading Companies

Among the 50 companies we engage with through Morningstar Sustainalytics’ Biodiversity and Natural Capital Stewardship Program, approximately one-fifth intend to report in line with the TNFD by the financial year 2025 or earlier. Furthermore, four front-runners have already published their first TNFD report.

Considering the TNFD recommendations were only finalized in Sept. 2023, it is promising to see companies already publishing TNFD-aligned disclosures. The TNFD’s intentional leveraging of the Task Force on Climate-related Financial Disclosures’ approach has ensured that the format is familiar to organizations, enabling rapid adoption. Despite the issue of nature loss being brought to the attention of the private sector later than climate, we are hopeful that organizations will adopt nature-related disclosure relatively quickly. Additionally, some investors are beginning to put pressure on companies to do so through biodiversity-focused shareholder proposals.⁴

Regionally, companies in Europe and Asia-Pacific lead the way towards TNFD-aligned disclosure within Sustainalytics’ engagement program. The companies from our engagement that have already produced TNFD reports are exclusively from these regions. Conversely, none of the companies we engage with from Latin America or Africa and the Middle East have signaled their intent to disclose in alignment with the TNFD. However, these regions also represent a smaller portion of our current engagement. Despite companies from the United States comprising the largest portion of our engagement cases, only 2 out of 17 companies from the U.S. are on the list of TNFD adopters. Meanwhile, 3 out of 14 companies from Asia-Pacific and 4 out of 10 European companies are represented. These regional disparities reflect the regulatory environments, market pressures and current regional priorities regarding sustainability in general.  

Trend Three: Companies Face Common Challenges in TNFD Adoption 

1. They are currently assessing the TNFD’s relationship to other nature-related frameworks and standards such as the European Sustainability Reporting Standards (ESRS).
2. They are prioritizing mandatory reporting first.
3. They aim to enhance readiness on data quality and availability before committing to disclosure.

While these motives have been consistently cited across our engagement companies, one company has expressed a preference to ensure the topic is material to its business before committing to disclosure, and another company is openly skeptical of the added value or relevance of the TNFD.

Navigating the Path Forward for TNFD Implementation

Efforts to align biodiversity standards, regulations and frameworks are a positive development. A comparative analysis of the TNFD recommendations, Global Reporting Initiative (GRI) and ESRS standards shows they are well aligned,⁵ with interoperability mapping documents⁶ further highlighting this.⁷ Additionally, the International Sustainability Standards Board (ISSB) will draw on the TNFD’s work to launch its research project on biodiversity and ecosystems.⁸ Furthermore, CDP’s 2024 questionnaire is already partially aligned with the TNFD recommendations. These developments collectively indicate a trajectory toward more robust disclosure requirements in the future.

With only six years remaining to achieve global biodiversity targets, initiating action now and refining processes along the way is crucial. Companies already reporting on nature understand that this is just the beginning, and they will not have all the data recommended by the TNFD initially. Despite challenges in reporting nature-related impacts and dependencies, organizations can leverage significant data they already have on waste, water, climate and pollution. Furthermore, proxy data can serve as a foundation, guiding companies to enhance traceability and eventually gather primary data throughout their supply chains. 

This year’s disclosure efforts will demonstrate the feasibility of reporting on nature, providing a crucial first step toward more comprehensive future reporting. Collating and disclosing such data will offer organizations a clearer understanding of nature-related challenges and enable transformative actions. Transparent and comparable nature data will empower financial institutions to make informed investment decisions, shifting financial flows away from activities that harm nature and toward those that can contribute to halting and reversing nature loss. 

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References

1. Carabia, A. “Implications of CSRD: What the Final Standards Mean for Investors and Issuers.” October 25, 2023.  https://www.sustainalytics.com/esg-research/resource/investors-esg-blog/implications-of-csrd--what-the-final-standards-mean-for-investors-and-issuers.
2. Convention on Biological Diversity. “Decision adopted by the Conference of the Parties to the Convention on Biological Diversity.” December 19, 2022. https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-en.pdf.
   
3. Taskforce on Nature-related Financial Disclosures. 2024. “TNFD welcomes the ISSB’s decision to commence work on nature-related issues”. April 24, 2024. https://tnfd.global/tnfd-welcomes-the-issbs-decision-to-commence-work-on-nature-related-issues/
4. Verney, P. 2024. “Resolution round-up: Allianz GI backs biodiversity proposals at US giants.” Responsible Investor. April 24, 2024. https://www.responsible-investor.com/resolution-round-up-allianz-gi-backs-biodiversity-proposals-at-us-giants/
5. EU Business & Biodiversity Platform. April 2024. “Thematic Report on Biodiversity Disclosure”. https://www.greenfinanceinstitute.com/wp-content/uploads/2024/04/Thematic-Report-Biodiversity-Disclosure_April-2024.pdf
6. EFRAG. 2024. “Interoperability of the European Sustainability Reporting Standards (ESRS) and the disclosure recommendations of the Taskforce on Nature-related Financial Disclosures (TNFD) - Accompanying document.” January 18, 2024. SR TEG meeting. https://www.efrag.org/
7. Taskforce on Nature-related Financial Disclosures. 2024. “Strengthened collaboration between GRI and TNFD.” April 12, 2024. https://tnfd.global/strengthened-collaboration-between-gri-and-tnfd/
8. Taskforce on Nature-related Financial Disclosures. 2024. “TNFD welcomes the ISSB’s decision to commence work on nature-related issues”. April 24, 2024. https://tnfd.global/tnfd-welcomes-the-issbs-decision-to-commence-work-on-nature-related-issues/