--- title: "TNFD explained: nature-related disclosure and what it means for insurers" source_url: https://abgalis.com/regulation/tnfd canonical: https://abgalis.com/regulation/tnfd description: "TNFD in full: the September 2023 recommendations, the 14 disclosures and LEAP, the 733-adopter count as at November 2025, the ISSB Practice Statement route with an October 2026 exposure draft, and why SS5/25 deliberately says nothing about nature." publisher: Abgalis Limited author: Abgalis Research date_published: 2026-08-22 date_modified: 2026-08-22 keywords: ["TNFD", "nature-related financial disclosures", "LEAP", "biodiversity risk", "ISSB", "IFRS S1", "Practice Statement", "EIOPA biodiversity", "NGFS nature", "SS5/25", "insurance", "ORSA"] retrieved: 2026-08-22 content_signal: search=yes, ai-input=yes, ai-train=no citation: "Abgalis Research, 'TNFD explained: nature-related disclosure and what it means for insurers', Abgalis Limited, https://abgalis.com/regulation/tnfd" license_note: >- May be quoted and cited in AI-generated answers with attribution to the author named above and a link to source_url. Not licensed for model training or fine-tuning (ai-train=no; Art. 4 reservation, EU Directive 2019/790). --- Regulation · TNFD # TNFD explained: nature-related disclosure and what it means for insurers The **Taskforce on Nature-related Financial Disclosures** published its final recommendations — version 1.0 — in **September 2023**. It describes itself as *"a market-led, science-based and government-backed initiative"*: funded by governments and philanthropic foundations, accepting no private-sector money, and issuing no binding requirements. **No jurisdiction mandates TNFD reporting. Including the UK.** That is the position today. The reason this page exists is the direction of travel: the TNFD's content is being absorbed into the **ISSB's** global baseline, and the ISSB chair has already framed the stakes in a sentence most commentary has missed — material nature-related disclosure, he says, *is not optional under IFRS S1 as it stands*. --- ## What is the TNFD — and is it mandatory anywhere? A voluntary disclosure framework, built 2021–2023 by a 40-member taskforce co-chaired by David Craig and Razan Al Mubarak, deliberately modelled on the TCFD's architecture so that firms could extend existing climate reporting to nature. It is not a regulator, and adopting it is a commitment, not a compliance event: a **TNFD Adopter** is an organisation that has publicly committed to making TNFD-aligned disclosures in its corporate reporting for financial years up to 2027. On mandation, the accurate statement is short: **no jurisdiction requires TNFD reporting as such.** The nearest things to regulatory contact are the EU's ESRS — whose biodiversity standard has a published correspondence mapping to TNFD — and the ISSB route described below. Claims that "TNFD becomes mandatory in 2026" circulate widely and have no primary source behind them. ## What are the four pillars and the fourteen disclosures? TNFD keeps TCFD's shape with one deliberate renaming: | Pillar | Disclosures | |---|---| | **Governance** | 3 | | **Strategy** | 4 | | **Risk *and Impact* Management** | 4 | | **Metrics and Targets** | 3 | **Fourteen recommended disclosures** in all. The renamed third pillar is the substantive difference from TCFD: nature reporting covers the organisation's **impacts on nature** as well as nature's risks to the organisation — double materiality by architecture, even though the ISSB's own baseline is single materiality. One disclosure deserves an insurer's particular attention: the Strategy pillar requires disclosure of assets and activities in **priority locations**. Nature risk is inherently geospatial — a dependency on water basins, pollinators or coastal protection exists at coordinates, not at a balance-sheet line. For an underwriting portfolio, that maps directly onto exposure data insurers already hold. ## What is the LEAP approach? **Locate, Evaluate, Assess, Prepare** — the TNFD's recommended (and explicitly non-mandatory) assessment process, beginning with locating the organisation's interface with nature. LEAP is the working method; the fourteen disclosures are the output. The distinction matters because the ISSB has signalled interest in both. ## Who has actually adopted it? The taskforce's latest aggregate count, **as announced 7 November 2025**: **733 organisations** across more than 50 countries, including **179 financial institutions** representing **USD 22.4 trillion in assets under management**, and a quarter of global systemically important banks. Named insurers on the public list include AXA, Dai-ichi Life and Britam. The TNFD publishes no insurer-only count, and its list updates monthly — a page citing "320" or "500+" adopters is quoting milestones from January 2024 and January 2025 respectively. ## Is TNFD becoming part of the ISSB baseline? Yes — and this is the finding that changes what "voluntary" means in practice. On **7 November 2025** the ISSB announced it would begin standard-setting on nature, drawing on *"the TNFD framework and its non-siloed approach to nature"* — including its recommendations, metrics and the LEAP approach. The TNFD, in turn, committed to complete its in-flight technical work by Q3 2026 and then **pause new technical guidance** in support of the ISSB. On **22 April 2026** the ISSB settled the vehicle: an **IFRS Practice Statement** — guidance, not a new standard — with an **exposure draft targeted for October 2026** and a 120-day comment period approved at the July 2026 board meeting. The chair, Emmanuel Faber, explained why a Practice Statement suffices: > "Providing material nature-related disclosures is not optional; IFRS S1 already > requires that. A Practice Statement will guide companies on how to provide such > disclosures." Read that carefully. The ISSB's position is that **the obligation already exists** wherever IFRS S1 applies and nature-related risk is material — the Practice Statement only tells firms *how*. For a UK insurer, the chain is: [UK SRS](/regulation/uk-srs/) is built on IFRS S1 and S2; the FCA proposes to mandate UK SRS for listed companies from January 2027; and S1's materiality requirement is the door through which nature arrives without any instrument ever being named "TNFD". ## What is the UK position — and what does SS5/25 say about nature? **Nothing is mandated, and the PRA has been explicit about its silence.** We verified the text of [SS5/25](/regulation/ss5-25/) directly: it contains **no mention of nature, biodiversity or natural capital anywhere** in its 182 paragraphs. That was a choice, not an oversight — sixteen respondents to the consultation challenged the exclusion, and the PRA's response in PS25/25 was that the policy is focused on climate-related risk and it *"has not set specific expectations on nature-related risks"*, while noting that it *"continues to expect firms to manage all relevant financial risks"* and may update its position. That last clause is the one a CRO should file. "All relevant financial risks" already includes a material nature dependency — the PRA has simply declined, for now, to tell you what good looks like. Elsewhere in the UK stack: [UK SRS](/regulation/uk-srs/) (25 February 2026, voluntary) is climate-focused, with nature appearing only in respondents' commentary. The transition-plan consultation names the TNFD's draft nature transition plan guidance as a possible future reference point. And the 2023 Green Finance Strategy committed the government to *"explore how best"* to incorporate the TNFD framework into UK policy — a commitment with no verified follow-through to date. ## What do supervisors expect of insurers on nature risk today? Three primary positions, in ascending order of immediacy. **The NGFS** published its conceptual framework for nature-related financial risk in September 2023, and on **9 April 2026** followed with three working notes — on nature data, on modelling tools for nature scenarios, and on a four-step **supervisory approach** to nature-related risk. When the central bankers' network publishes a supervision manual, supervision follows. **EIOPA** has moved from framing to measurement. Its March 2023 staff paper set out nature-related risk for underwriting and investment; its **30 June 2025** report on biodiversity risk management found that only around **one in five insurers mention biodiversity in the ORSA**, that assessments are *"largely qualitative"*, and that work is needed on data, models, scenarios and risk-based measures. Under the amended Solvency II directive, EIOPA is mandated to assess how insurers treat biodiversity-loss risk in the ORSA. UK firms are outside EIOPA's reach — but UK supervisory practice has never developed in isolation from it. **The IAIS** has, to date, no nature-specific supervisory material — its 2025 outputs remain climate-framed. That absence is itself information: the international standard-setter for insurance supervision has not yet caught up with the central banks. The honest summary for a UK insurer: nobody requires a nature risk assessment today, one supervisor next door is already scoring ORSAs against it, and the toolkit your own supervisor would use arrived in April. ## Where Abgalis fits The gap EIOPA measured — biodiversity in one ORSA in five, treatment *"largely qualitative"* — is a modelling gap, not a reporting one. Nature risk enters an insurer the same way climate risk does: through named transmission channels into underwriting, reserving, market and credit exposure, with the added property that it is location-specific from the outset. Abgalis carries all seven risk domains in one continuously updated model, with geospatial exposure already first-class — so a nature dependency can be traced from priority location to portfolio effect with the same machinery that serves [SS5/25's](/regulation/ss5-25/) climate expectations. Building that capability against a voluntary framework now is what makes the eventual Practice Statement a formatting exercise rather than a scramble. Accountability for every regulatory judgement remains with the firm. Abgalis is analytics, not authority. --- ## Sources All load-bearing claims trace to the taskforce, the ISSB, the PRA, gov.uk, EIOPA or the NGFS. - **TNFD Recommendations v1.0** — [publication page](https://tnfd.global/publication/recommendations-of-the-taskforce-on-nature-related-financial-disclosures/), September 2023; [About the TNFD](https://tnfd.global/about/); [the LEAP approach](https://tnfd.global/recommendations/leap-approach/) - **Adoption figures** — [TNFD announcement of 7 November 2025](https://tnfd.global/issb-decision-on-nature-related-standard-setting-drawing-on-tnfd-framework/) (733 organisations, 179 financial institutions, USD 22.4tn AUM); [Adopters list](https://tnfd.global/engage/tnfd-adopters-list/), updated monthly - **Additional guidance for financial institutions v2.0** — [TNFD](https://tnfd.global/publication/additional-disclosure-guidance-for-financial-institutions/), June 2024 - **ISSB decision, 7 November 2025** — [IFRS Foundation](https://www.ifrs.org/news-and-events/news/2025/11/issb-welcomes-tnfd-support-nature-related-disclosure/) - **ISSB Practice Statement route, April 2026** — [IFRS Foundation](https://www.ifrs.org/news-and-events/news/2026/05/issb-agrees-proposed-way-forward-nature-related-disclosures/); [project page](https://www.ifrs.org/projects/work-plan/biodiversity-ecosystems-and-ecosystem-services/) - **SS5/25** — [text](https://www.bankofengland.co.uk/prudential-regulation/publication/2025/december/enhancing-banks-and-insurers-approaches-to-managing-climate-related-risks-ss) and **PS25/25** — [the PRA's response on nature](https://www.bankofengland.co.uk/prudential-regulation/publication/2025/december/enhancing-banks-and-insurers-approaches-to-managing-climate-related-risks-policy-statement), 3 December 2025 - **UK SRS** — [government response](https://www.gov.uk/government/consultations/exposure-drafts-uk-sustainability-reporting-standards/outcome/government-response-to-the-consultation-on-uk-sustainability-reporting-standards-web-version), 25 February 2026; [transition plan consultation](https://assets.publishing.service.gov.uk/media/685d0945c779b80d9a0e106b/transition-plan-consultation.pdf), June 2025; [2023 Green Finance Strategy](https://assets.publishing.service.gov.uk/media/64549ecdfaf4aa0012e1337d/2023-green-finance-strategy-annexes.pdf) - **EIOPA** — [staff paper on nature-related risks](https://www.eiopa.europa.eu/publications/eiopa-staff-paper-nature-related-risks-and-impacts-insurance_en), March 2023; [report on biodiversity risk management by insurers](https://www.eiopa.europa.eu/eiopa-notes-positive-early-steps-insurers-addressing-biodiversity-risk-calls-stronger-collaboration-2025-06-30_en), 30 June 2025 - **NGFS** — [conceptual framework](https://www.ngfs.net/en/publications-and-statistics/publications/nature-related-financial-risks-conceptual-framework-guide-action-central-banks-and-supervisors), September 2023; [new tools for nature-related risk](https://www.ngfs.net/en/press-release/ngfs-provides-new-tools-manage-nature-related-financial-risks), 9 April 2026 *This page states the position as at 22 August 2026 and will be reviewed when the ISSB publishes its exposure draft, targeted October 2026.* --- **Source:** [https://abgalis.com/regulation/tnfd](https://abgalis.com/regulation/tnfd) · Abgalis Research, published by Abgalis Limited (England and Wales, no. 17247499) **Cite as:** Abgalis Research, *TNFD explained: nature-related disclosure and what it means for insurers*, Abgalis Limited. https://abgalis.com/regulation/tnfd