ESG · nature
Nature-related disclosures in the UK: voluntary, and waiting on the ISSB
Nature-related disclosure in the UK is voluntary: no law or listing rule asks a company to report on nature as such, and the TNFD recommendations are a framework, not a requirement.
The next move is the ISSB’s: a nature Practice Statement, with an exposure draft targeted for October 2026, which would still need UK endorsement.
Status
What a UK company is asked about nature today
There is no UK nature reporting duty, and none has been proposed.
Nature can still reach a UK report two ways: through UK SRS S1, which asks for material sustainability-related risks and opportunities of any kind, and through the “environmental matters” in the non-financial statement under section 414CB(1).
Listed companies in scope report against UK SRS S1 on a comply-or-explain basis under the FCA’s final rules, with two years’ relief from non-climate disclosures — which is where nature falls.
Biodiversity net gain, under Schedule 7A to the Town and Country Planning Act, is often mentioned alongside, but it is a condition on development, not a disclosure.
How any ESG topic passes the UK SRS test is on ESG integration under UK SRS and UK SRS S1 materiality.
| Route | What it asks | Status |
|---|---|---|
| UK SRS S1 | Material nature-related risks and opportunities | Voluntary; comply or explain for listed from 2027 |
| Companies Act s.414CB(1) | “Environmental matters”, for traded, banking and insurance companies | In force |
| TNFD recommendations | 14 disclosures on dependencies, impacts, risks, opportunities | Voluntary |
| ISSB Practice Statement | Nature-related requirements and guidance | Exposure draft targeted October 2026 |
| Biodiversity net gain | A 10% gain on development sites in England | Planning condition, not disclosure |
TNFD
The TNFD framework: fourteen disclosures, four pillars
The Taskforce on Nature-related Financial Disclosures published its recommendations in September 2023: fourteen recommended disclosures under four pillars, and six general requirements.
It carried over all eleven TCFD recommended disclosures and added three specific to nature, so a company already reporting on climate uses the same architecture.
The third pillar is renamed: risk and impact management, because nature disclosure covers what a company does to nature as well as what nature does to it.
The recommendations are voluntary, and the TNFD’s disclosure pages set out the general requirements and metrics.
The 2026 Status Report counts 802 organisations committed to TNFD-aligned disclosure and over 1,000 that have published TNFD-aligned reports — two different populations.
The TNFD said in November 2025 that it would complete its technical work in progress by the third quarter of 2026 and pause new technical guidance, to support the ISSB.
| Pillar | Nature-specific addition to the TCFD eleven |
|---|---|
| Governance (C) | Human rights and engagement with Indigenous Peoples, local communities and affected stakeholders |
| Strategy (D) | Locations of assets and activities meeting the criteria for priority locations |
| Risk and impact management (A(ii)) | Processes for the upstream and downstream value chain |
| Metrics and targets | No addition — the TCFD disclosures, framed for nature |
The ISSB
The ISSB’s nature work: a Practice Statement, not a standard
The ISSB is taking the TNFD’s work forward, but not as a new standard: it decided in April 2026 to propose nature-related requirements as an IFRS Practice Statement, per its work plan.
A Practice Statement, in the ISSB’s own staff paper, is non-mandatory and is not a Standard, though it goes through full due process and a jurisdiction can choose to mandate it.
An exposure draft is targeted for October 2026 with a 120-day comment period, so a final Practice Statement cannot come before 2027.
Nothing the ISSB issues applies in the UK automatically: the FRC says new ISSB standards on nature would first need UK endorsement.
The UK’s Technical Advisory Committee has a nature-related disclosures project at research stage, with its plan approved on 21 April 2026; any UK endorsement date is therefore unknown.
- Sep 2023TNFD recommendations v1.0
- Nov 2025ISSB decides to draw on TNFD and set standards
TNFD to wind down new technical guidance.
- Apr 2026Form decided: IFRS Practice Statement
All twelve ISSB members agreed.
- 21 Jul 2026Permission to ballot the exposure draft
120-day comment period.
- Oct 2026Exposure draft targeted
- No dateUK endorsement
Required before any UK use.
UK policy
UK policy on nature disclosure: a commitment to explore
The government’s 2023 Green Finance Strategy said it would “explore how best the final TNFD framework … should be incorporated into UK policy and legislative architecture, in line with Target 15 of the Global Biodiversity Framework”, in its list of commitments.
No instrument has followed; the strategy page holds both the 2019 and 2023 editions.
England’s environmental objectives sit in the 25 Year Environment Plan, since revised by the Environmental Improvement Plan 2023; they set government targets, not company reporting duties.
The biodiversity duty on public authorities, and biodiversity net gain on development, likewise do not reach corporate reporting.
The wider regulatory map is on the UK sustainability regulation landscape.
Target 15 of the Global Biodiversity Framework asks governments to take measures so that large companies disclose biodiversity risks, dependencies and impacts; it places no duty on a company.
The NGFS conceptual framework for central banks describes itself as non-binding.
Materiality
When nature is material under UK SRS
Under UK SRS S1, a nature-related matter is reported if it could reasonably be expected to affect the company’s cash flows, access to finance or cost of capital.
The routes are dependencies (the company relies on water, soil, pollination), impacts that attract regulation or litigation, supply-chain exposure, and the response of customers and lenders.
An impact that matters only to the environment, with no plausible financial effect, falls outside UK SRS and inside a double-materiality framework such as the EU’s.
The TNFD asks companies to state which materiality approach they apply, so a UK SRS reporter using TNFD says it is applying financial materiality.
The two approaches are compared on double materiality, and the climate side on UK SRS S2.
| Route to the financial statements | Example |
|---|---|
| Dependency on an ecosystem service | Water scarcity interrupting production |
| Impact that draws regulation or litigation | A site affecting a protected habitat |
| Supply-chain exposure | A commodity linked to deforestation |
| Market or financing response | Customers or lenders pricing nature risk |
Getting started
Starting nature-related disclosure: an order of work
Start by locating where the business touches nature — sites, sourcing regions, water use — because the TNFD’s approach begins with location.
Then evaluate dependencies and impacts, assess which create material risks or opportunities, and prepare the response and the disclosure.
Free modelling tools such as InVEST map and value ecosystem services, which helps with the evaluation step.
Use the climate governance already in place: the same board committee, the same risk register, the same four-pillar structure.
Board oversight is covered on UK SRS for boards, and the general standard on UK SRS S1.
Frequently asked
Nature-related disclosures: frequently asked
What are nature-related disclosures?
Nature-related disclosures are what a company reports about its dependencies and impacts on nature — water, land, species, ecosystems — and the risks and opportunities those create for the business.
The main framework is the TNFD's, published in September 2023, which follows the TCFD's structure of governance, strategy, risk and impact management, and metrics and targets.
Is TNFD mandatory in the UK?
No. The TNFD recommendations are voluntary, and no UK law or listing rule requires companies to report against them.
The government's 2023 Green Finance Strategy said it would explore how the TNFD framework should be incorporated into UK policy, but no instrument has followed.
What is the TNFD framework?
A set of 14 recommended disclosures in four pillars — governance, strategy, risk and impact management, and metrics and targets — with six general requirements, including how materiality is applied and where nature-related issues are located.
It carries over all eleven TCFD disclosures and adds three nature-specific ones, and it is accompanied by the LEAP approach (locate, evaluate, assess, prepare) for assessing nature-related issues.
Is the ISSB writing a nature standard?
Not a standard.
The ISSB decided in April 2026 to propose nature-related requirements and guidance in the form of an IFRS Practice Statement, which is non-mandatory and is not a Standard, though a jurisdiction can choose to mandate it.
An exposure draft is targeted for October 2026 with a 120-day comment period.
Any output would need UK endorsement before becoming part of UK SRS.
Do UK companies have to report on biodiversity?
There is no specific UK duty to report on biodiversity.
A company applying UK SRS S1 reports material nature-related risks and opportunities under its general requirements, and traded companies, banks and insurers with more than 500 employees cover environmental matters in their non-financial statement.
Biodiversity net gain is a planning condition on development, not a reporting duty.
What happened to the TNFD in 2026?
The TNFD said in November 2025 that it would complete its technical work in progress by the third quarter of 2026 and pause any new technical guidance, supporting the ISSB's nature work instead.
Its September 2026 status report counts 802 organisations committed to TNFD-aligned disclosure and over 1,000 that have published TNFD-aligned reports.
Does the Global Biodiversity Framework require companies to disclose?
No. Target 15 of the Kunming-Montreal Global Biodiversity Framework asks the Parties — governments — to take measures so that large companies and financial institutions monitor, assess and disclose their biodiversity risks, dependencies and impacts. It creates no duty directly on a UK company.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- TNFDRecommendations of the TNFD (v1.0, September 2023)
14 recommended disclosures across four pillars; voluntary.
- TNFDDisclosure recommendations — overview page
- TNFDTNFD 2026 Status Report, September 2026
802 organisations committed; over 1,000 have published TNFD-aligned reports.
- TNFDISSB decision on nature-related standard-setting, 7 November 2025
Technical work in progress to complete by Q3 2026; new guidance paused.
- IFRS FoundationISSB work plan — Nature-related Disclosures
Exposure draft targeted October 2026, 120-day comment period.
- IFRS FoundationISSB Staff Paper AP3D, April 2026, ¶¶55, 58
A Practice Statement is non-mandatory and not a Standard; a jurisdiction can choose to mandate it.
- Financial Reporting CouncilSustainability reporting developments — FAQ
New ISSB standards, including on nature, would not automatically apply in the UK.
- Financial Reporting CouncilUK Sustainability Disclosure TAC — research project: nature-related disclosures
Project plan approved 21 April 2026.
- Convention on Biological DiversityKunming-Montreal Global Biodiversity Framework, Target 15
Asks Parties to take measures; binds governments, not companies.
- NGFSNature-related Financial Risks: a Conceptual Framework, July 2024
Non-binding by its own words.
- Department for Energy Security and Net ZeroMobilising green investment: 2023 Green Finance Strategy — annexes
“We will explore how best the final TNFD framework … should be incorporated into UK policy and legislative architecture.”
- HM GovernmentGreen finance strategy (2019 and 2023 editions)
- Defra25 Year Environment Plan
Revised by the Environmental Improvement Plan 2023.
- Department for Business and TradeUK SRS S1 (PDF), ¶3, ¶17
Material sustainability-related risks and opportunities, nature included.
- legislation.gov.ukCompanies Act 2006, section 414CB(1)(a)
“Environmental matters”.
- legislation.gov.ukTown and Country Planning Act 1990, Schedule 7A ¶2 (biodiversity net gain)
A planning condition, not a disclosure.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
- Natural Capital ProjectInVEST — open-source models for mapping and valuing nature’s services