Feedback on TNFD v0.4 Beta framework consultation

FfB members call for stronger guidance on practical application and materiality

The Finance for Biodiversity (FfB) Foundation members are calling on the Taskforce on Nature-related Financial Disclosures (TNFD) to increase the practical applicability of its draft framework and specify points on materiality. In particular, the members see a need to pare back the recommendations to enable the dissemination of decision-useful information and clearly demonstrate interoperability with emerging regional and global standards.

Charlotte Apps, sustainable investing analyst at Fidelity International, lead of the FfB Foundation TNFD subgroup and co-chair of the Target Setting working group at the FfB Foundation, commented: “The draft TNFD framework, if executed wisely, has the potential to unlock a wealth of decision-useful information to enable organisations, financial institutions and other stakeholders to better understand impacts and dependencies on nature, and in turn enable better risk management and opportunity identification.

“However, to realise this outcome, the framework needs to be further refined and pared back in terms of its complexity. Nature is still a relatively new topic for most organisations, therefore what TNFD needs to deliver is a pragmatic solution to nature-based risk management and reporting to enable broad-based adoption.”

A subgroup of the FfB Foundation’s Impact Assessment working group developed the feedback to the TNFD Framework v0.4 consultation, and it was supplemented with input from other members of the Foundation. The FfB Foundation has as of today 140 signatories and 67 members with total assets under management of €19.7 trillion.

Apps added: “The take-up and usefulness of the voluntary TNFD framework will depend on whether it manages to package the complex topic of biodiversity measurement into a clear and concise manual for companies to implement and report on.”

The below key points are an abstract of the feedback document which the FfB Foundation has submitted.

Key Points:


  • The interactive online platform needs to be redesigned. In its current form, it is challenging to navigate, and information is difficult to find.
  • One PDF version of the framework would help to provide an overview of all of the elements it contains, eliminating the need to download several documents and supporting annexes.
  • A phased implementation approach for the framework is advisable to enable the near-term application of the framework – if it is too complex and burdensome to adopt, it runs the danger of getting dismissed by organisations. As a starting point, disclosure against some of the key and easier-to-implement recommendations would enable the take-up of the framework.
  • Interoperability with emerging regional and global standards is key. TNFD should provide guidance as to how its recommended metrics align with evolving nature and biodiversity reporting standards of standard-setting bodies (e.g. ISSB, GRI, EFRAG), the Convention on Biological Diversity (CBD), scientific organisations and framework initiatives (e.g. SBTN).


  • Too much discretion for companies to determine what is material could limit cross-comparability.
  • All organisations should use a double-materiality approach.


  • We support the idea that the global core metrics should be disclosed on a comply or explain basis. Our suggestions include several points:
    • TNFD defines critical sectors which must disclose against all core metrics.
    • Other sectors should be given discretion to disclose against global core metrics on a comply or explain basis, allowing users of the framework to determine which metrics are most material to their operations and value chain.
    • This approach will accommodate the dissemination of material and decision-useful information.
  • Additional sector guidance should only focus on the material drivers per sector rather than all drivers – e.g. by applying the Science Based Targets for Nature’s (SBTN) sector materiality tool.

The mission of the TNFD is to develop and deliver a risk management and disclosure framework for organisations to report and act on evolving nature-related risks, supporting a shift in global financial flows away from nature-negative toward nature-positive outcomes.

In March 2023, TNFD released the fourth version of its beta framework for market consultation, building on v0.1, v0.2 and v0.3. The release of the final framework for market adoption is planned for September 2023.

The FfB Foundation’s latest feedback on the v0.4 beta release is a follow-up on its input on v0.3 from February this year.

The G7 Finance Ministers and G20 Sustainable Finance Roadmap have endorsed the TNFD. The G20 Sustainable Finance Roadmap was developed to help focus the attention of the G20, international organisations and other stakeholders to key priorities of the sustainable finance agenda and form consensus on key actions to be taken.

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