TNFD seeks feedback on disclosure metrics for FIs as recommendations launched

Further efforts to align with global standard setters also announced, while next steps will include guidance on transition planning and sector disclosures.

aeriel view of forest with data points

The Taskforce on Nature-related Financial Disclosures (TNFD) is asking for feedback on two proposed metrics that financial institutions could disclose on immediately “without being reliant on corporates to report to them”.

The additional guidance for financial institutions was published late on Monday by the TNFD alongside the launch of its final recommendations.

At the core of the taskforce’s recommendations for all types of organisations are 14 disclosures, most of which are drawn from the climate-equivalent Taskforce on Climate Related Disclosures (TCFD) and developed around the same four conceptual pillars: governance, strategy, risk and impact management, and metrics and targets.

The disclosures were first announced in a draft version published in March, and the final version is largely in line with these.

The framework is centred around nature-related dependencies, impacts, risks and opportunities. Related to these, reporting organisations are expected to disclose, for example: resilience to these factors; processes for identifying, assessing and prioritising them; the metrics used to assess opportunities and risks; and targets set to manage them and report progress.

Other disclosures include the location of assets and activities in ecologically sensitive locations, as well as describing the organisation’s human rights policies and engagement activities with respect to Indigenous peoples, local communities and other stakeholders in relation to nature-related factors.

The separate financial institutions guidance includes additional points for asset managers and owners, banks, insurers and development finance institutions on how to report on some of the 14 recommended disclosures. It also sets out for the first time two proposed disclosure metrics specifically for financial institutions.

The first is exposure to sectors considered to have material nature-related dependencies and impact.

For asset owners and managers, this would be disclosed as the absolute amount or percentage of invested or owned assets. For banks it would be the absolute amount of percentage of lending volume. The taskforce has also identified a set of sectors that should be considered for this disclosure.

The second is exposure to sensitive locations, which should also be reported based on assets invested/owned or lending volume.

The TNFD said it encourages institutions to pilot test the application of these metrics and provide feedback.

Speaking at a webinar on the launch of the final framework, the taskforce’s technical director, Emily McKenzie, said the metrics should highlight “important priorities for financial institutions that they could now disclose immediately without being reliant on corporates to report to them”.

She highlighted that the guidance and metrics should be used in conjunction with the main recommendations, and that the financial sector guidance will be finalised in 2024.

Reflecting on broader efforts to develop the framework, TNFD executive director Tony Goldner said on the webinar that creating metrics has been “the most complex task we’ve had to wrestle with”. He said the group has grappled with the need to boil down “potentially thousands of things that can be measured” into something that can be reported on and audited annually.

As a first step, he said companies should focus on the “small group of 14 indicators and associated metrics” referred to as core global metrics, and reflected in global policy priorities such as the Global Biodiversity Framework. Firms can then consider suggested sector-specific disclosures and other additional reporting points that could be relevant to an organisation’s business model.

LEAP methodology

Underpinning these external disclosures is the TNFD’s internal risk and opportunity assessment approach LEAP (Locate, Evaluate, Assess and Prepare).

LEAP has been pilot tested with more than 240 institutions, Goldner said, and some changes have been made since the latest beta version was released. These include a simplified and more focused scoping guidance after feedback from preparers.

The taskforce has also “aligned the evaluation and assessment phase” to incorporate financial and materiality tests from standard bodies the ISSB and GRI, as well as the EU’s CSRD reporting rules. This has effectively configured LEAP to “support disclosure across the single, double or multiple materiality lenses”, Goldner said.

An EU company using the LEAP approach will “be able to get to a stage where they will have identified the material impacts that they should be disclosing consistent with CSRD”, he added.

Monday’s press statement on the final framework emphasised that the TNFD recommendations are “consistent with the global sustainability standards” of the ISSB, GRI and European Sustainability Reporting Standards (ESRS).

Next steps for the taskforce include developing sector guidance, working with standard bodies on further alignment and with the NGFS on nature-related scenario analysis, as well as working with partners on “additional guidance on transition planning and further guidance on target-setting, including for financial institutions”.

It is also looking to announce a group of adopters of the recommendations at the World Economic Forum in Davos in January.

Some have already committed to disclosing. At Monday’s launch event, GSK announced plans to publishing its first TNFD disclosures from 2026, based on 2025 data. Today, Mirova said it would implement the TNFD recommendations.