Financial institutions ask TNFD to provide more guidance in their framework

15 February 2023 – The members of the Finance for Biodiversity (FfB) Foundation provided collective feedback to the TNFD Framework v0.3 consultation, led by a dedicated subgroup of the FfB Foundation Impact Assessment working group. For the members, it was important to contribute to the consultation to express a collective voice and vision from private financial institutions committed to the protection of biodiversity, calling for the most ambitious disclosure practices.

FfB Foundation members appreciated the consultation process for the development of the TNFD framework. It enabled them to share their collective vision of ambitious disclosure practices to protect biodiversity. One of the key elements in the consultation answer is the members’ request for more guidance in the framework. For instance, it should mention how to manage the use of modeled versus reported company data, but also how to integrate both climate and nature into their transition plans.


Summary of the main points of feedback to the consultation

In their answer to the TNFD consultation, the Finance for Biodiversity Foundation members emphasized the following key points:

  • Financial institutions need additional guidance throughout the framework on how to manage the use of modeled versus reported company data.
  • There is a need for more standardisation on metrics, at least per sector/driver, to enable aggregation of information for financial institutions.
  • Climate and nature strategies should be closely linked and complementary. However, climate and nature should not be oversimplified into a single topic
    • Additional guidance is needed on how organisations should integrate both climate and nature into their transition plans, target setting and use of scenario analysis to inform their strategy and asset allocation;
    • Organisations must have an awareness of potential trade-offs and co-benefits between climate action and biodiversity action, and they require guidance from the TNFD on how to report on and disclose these.
  • The TNFD must complement and align with flagship frameworks and regulatory initiatives on nature, including but not limited to the Global Biodiversity Framework, SBTN, SASB and ESRD E4.
  • Significant additions are required to enable scenario analysis that is useful for decision making, including the links between the fundamental drivers of biodiversity impact model outputs .
  • We would welcome the publication of the TNFD pilots to inform best-practice disclosure.
  • The framework must not be biased toward large institutions, in particular with respect to costly provision of data.


The Taskforce on Nature-related Financial Risks (TNFD) develops and delivers a risk management and disclosure framework for organisations to report and act on evolving nature-related risks, with the ultimate aim of supporting a shift in global financial flows away from nature-negative outcomes and toward nature-positive outcomes.