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.
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.
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.
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.
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.
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 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".
Nothing is mandated, and the PRA has been explicit about its silence.
We verified the text of 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 (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.
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.
No. As at 22 August 2026 no jurisdiction mandates TNFD reporting, including the UK. The TNFD is a market-led, voluntary framework funded by governments and philanthropic foundations; it is not a regulator and issues no binding requirements. The claim that TNFD 'becomes mandatory in 2026' circulates in commentary and has no primary source behind it. The nearest regulatory contact points are the EU's ESRS, which have a published correspondence mapping to TNFD, and the ISSB's forthcoming Practice Statement.
Governance (3 disclosures), Strategy (4), Risk and Impact Management (4) and Metrics and Targets (3) — fourteen in all. The architecture deliberately mirrors TCFD, with one substantive difference: the third pillar is 'Risk and Impact Management', covering the organisation's impacts on nature as well as nature's risks to the organisation.
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 recommended disclosures are the output. The ISSB has said it will draw on TNFD's recommendations, metrics and the LEAP approach as appropriate.
As announced by the taskforce on 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. The adopters list updates monthly and includes named insurers such as AXA, Dai-ichi Life and Britam; the TNFD publishes no insurer-only count. Figures of 320 or 500-plus are stale milestones from January 2024 and January 2025.
Its content is. On 7 November 2025 the ISSB announced standard-setting on nature drawing on the TNFD framework, and on 22 April 2026 it settled the vehicle: an IFRS Practice Statement — guidance under IFRS S1 rather than a new standard — with an exposure draft targeted for October 2026 and a 120-day comment period. ISSB chair Emmanuel Faber's framing: providing material nature-related disclosures is not optional, because IFRS S1 already requires it; the Practice Statement will guide companies on how. The TNFD is completing its in-flight work and pausing new technical guidance in support.
No. The text of SS5/25 contains no mention of nature, biodiversity or natural capital. Sixteen consultation respondents challenged the exclusion; the PRA responded in PS25/25 that the policy is focused on climate-related risk, that it has not set specific expectations on nature-related risks, and that it may update its position — while noting it continues to expect firms to manage all relevant financial risks. A material nature dependency therefore already falls within general risk-management expectations even though no nature-specific supervisory statement exists.
No. UK SRS S1 and S2, issued 25 February 2026 for voluntary use, are climate-focused; nature appears only in respondents' commentary in the government's consultation response. 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 incorporating TNFD into UK policy, with no verified follow-through to date. The realistic route for nature content into UK requirements is IFRS S1's materiality requirement, via the ISSB Practice Statement, if and when the FCA mandates UK SRS for listed companies.
No supervisor requires a nature risk assessment of UK insurers today. EIOPA's 30 June 2025 report found only around one in five insurers mention biodiversity in the ORSA and that assessments are largely qualitative, and under the amended Solvency II directive EIOPA is mandated to assess insurers' treatment of biodiversity-loss risk in the ORSA. The NGFS published a four-step supervisory approach to nature-related risk in April 2026 alongside notes on nature data and scenario modelling tools. The IAIS has no nature-specific supervisory material yet.
Through the same transmission channels as climate risk — into underwriting, reserving, market and credit exposure — with the added property that it is location-specific from the outset: dependencies on water basins, pollinators or coastal protection exist at coordinates. TNFD's Strategy pillar requires disclosure of assets and activities in priority locations, which for an insurer maps directly onto exposure data already held for underwriting and catastrophe modelling.
Developments on this and related instruments are tracked in regulatory updates.
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