Nature · Voluntary disclosure
Biodiversity reporting: what UK companies disclose, and why
Biodiversity reporting is voluntary for UK companies: no statute requires it, and the disclosure frameworks companies use — the TNFD recommendations and GRI 101 — are private standards.
The ground is moving: the ISSB is preparing nature-related requirements as a non-mandatory Practice Statement, and the TNFD is closing its technical programme.
This guide sets out what a nature disclosure contains, which framework to use, and where UK law does and does not reach.
Where the law stands
Voluntary for companies, a duty for public bodies
The biodiversity duty in section 40 of the NERC Act 2006 binds public authorities: they must consider what action they can properly take to further the general biodiversity objective, and act on it.
The first consideration was due by 31 December 2023, and it must be repeated at least every five years.
Section 40A requires local authorities other than parish councils, local planning authorities and designated authorities in England to publish biodiversity reports.
Neither section, nor the planning rules on biodiversity net gain, creates any duty on a private company to report on biodiversity.
The Kunming-Montreal Global Biodiversity Framework’s Target 15 asks governments to put disclosure measures in place for large companies and financial institutions; it binds Parties, not companies.
No UK government consultation or date for mandatory corporate nature reporting has been announced.
Mandatory, voluntary, proposed
| Instrument | Status in the UK |
|---|---|
| NERC Act s.40 biodiversity duty | Mandatory — public authorities |
| NERC Act s.40A reports | Mandatory — local authorities, planning authorities, designated bodies in England |
| Biodiversity net gain | Mandatory — planning in England |
| TNFD recommendations | Voluntary |
| GRI 101: Biodiversity 2024 | Voluntary |
| ISSB nature Practice Statement | In development; non-mandatory |
TNFD
The TNFD recommendations: four pillars, fourteen disclosures
The TNFD built its framework on the TCFD’s, so a company with a climate disclosure already has most of the structure.
| Pillar | What it covers | Added for nature |
|---|---|---|
| Governance | Board oversight and management’s role for nature-related dependencies, impacts, risks and opportunities | C — human rights and engagement with Indigenous Peoples, local communities and affected stakeholders |
| Strategy | Effects on the business model, strategy and financial planning, and resilience | D — the locations of assets and activities that meet the criteria for priority locations |
| Risk and impact management | Processes to identify, assess, prioritise and monitor, and their integration | A(ii) — processes for the upstream and downstream value chain |
| Metrics and targets | The metrics and targets used to assess and manage nature-related issues | — |
The TNFD says it replicates the four pillars and all eleven TCFD recommended disclosures, and adds three for nature, for fourteen in total.
It also sets six general requirements, to make the information disclosed consistent from one reporter to the next.
The TNFD describes its final recommendations as science-based and voluntary.
The framework is designed to sit beside climate reporting; see our TCFD reporting guide for the structure it borrows.
The LEAP approach
Locate, evaluate, assess, prepare
LEAP is the TNFD’s guidance on doing the assessment that sits behind a nature disclosure.
Locate
Find your interface with nature across direct operations and the value chain, and identify priority locations.
Evaluate
Identify the dependencies and impacts on nature at those locations.
Assess
Work out the nature-related risks and opportunities that follow.
Prepare
Decide the response, set metrics and targets, and prepare to report.
Location is what makes nature harder than climate: a tonne of carbon is the same everywhere, but the effect of land use or water withdrawal depends on where it happens.
Tools such as ENCORE, which maps how economic activities depend on and affect nature, are commonly used in the Locate and Evaluate phases.
The Science Based Targets Network publishes methods for setting targets for nature, a separate body from the climate-focused Science Based Targets initiative.
What is changing
The TNFD steps back; the ISSB steps in
In November 2025 the ISSB decided to draw on the TNFD framework for nature-related disclosure.
The TNFD said it would complete its technical work in progress by the third quarter of 2026 and pause any further technical guidance, supporting the ISSB’s work instead.
In April 2026 the ISSB decided to propose its nature requirements as an IFRS Practice Statement, not a new Standard.
A Practice Statement is non-mandatory, but the ISSB treats it as standard-setting with full due process, and a jurisdiction can choose to mandate it.
In July 2026 the ISSB gave permission to ballot an exposure draft with a 120-day comment period.
The ISSB’s chair has said that providing material nature-related disclosures is already required by IFRS S1, and the Practice Statement will guide how to do it.
The TNFD’s 2026 status report counts 802 organisations committed to TNFD-aligned disclosure, and more than 1,000 that have published such reports.
The TNFD itself remains at tnfd.global; it has not disbanded.
- Sep 2023TNFD Recommendations v1.0
- Nov 2025ISSB decides to draw on TNFD
The TNFD will finish its technical work and pause new guidance.
- Apr 2026Form decided
An IFRS Practice Statement, not a new Standard.
- Jul 2026Permission to ballot
Exposure draft with a 120-day comment period.
- Sep 2026TNFD 2026 Status Report
Nature and UK SRS
Where nature fits in a UK SRS report
UK SRS S1 asks a company to disclose the sustainability-related risks and opportunities that could reasonably be expected to affect its cash flows, its access to finance or its cost of capital, and nature-related risks can fall within that.
Under the FCA’s final rules in PS26/19, listed companies in scope report against UK SRS on a comply-or-explain basis for periods beginning on or after 1 January 2027, with a two-year relief for non-climate matters under UK SRS S1.
So a listed company can take two years before it has to address non-climate sustainability matters, nature included, or explain why not.
Any ISSB nature Practice Statement would need its own UK endorsement before it formed part of UK SRS.
How UK SRS works is covered in the UK SRS standards, and our sister site explains where nature sits in wider sustainability reporting.
Choosing a framework
TNFD, GRI 101, ESRS E4 or CDP
| Framework | Owner | Materiality lens | Use it when |
|---|---|---|---|
| TNFD recommendations | TNFD | Nature-related risks and opportunities, plus dependencies and impacts | Investors ask how nature affects the business |
| GRI 101: Biodiversity 2024 | Global Reporting Initiative | Impacts on biodiversity | Stakeholders ask what the business does to nature |
| ESRS E4 | EU (EFRAG drafted) | Double materiality, for companies in CSRD scope | A group has EU reporting obligations |
| CDP forests and water | CDP | Questionnaire, scored | Customers or investors request it through CDP |
GRI 101 took effect for reporting from 1 January 2026, replacing GRI 304; since 2024 the number 101 means biodiversity, where before 2023 it meant the old Foundation standard.
Many organisations use TNFD for the investor-facing risk story and GRI 101 for the impact data, because the two answer different questions.
CDP’s forests questionnaire covers seven commodities; see our CDP reporting guide.
Getting started
A first nature disclosure, in five moves
Set governance
Give the board oversight of nature, name a management owner, and connect it to the risk process.
Screen for materiality
Use sector tools to find where the business depends on or affects nature, and which locations matter.
Run LEAP where it matters
Assess dependencies, impacts, risks and opportunities at the priority locations.
Choose metrics
Start with data you already hold: land use, water, pollution, sourcing of forest-risk commodities.
Disclose and connect
Publish against TNFD or GRI 101, and connect it to your climate disclosure and targets.
Much of the starting data already exists in energy and environmental reporting; our sister reference site covers SECR, and srsreport.co.uk covers implementation data in more depth.
If it would help to talk through where nature fits beside your other disclosures, book a free 15-minute call.
Further reading
Science, policy and finance on nature
These bodies publish the science and policy behind nature disclosure; they are context, not sources for any requirement on this page.
The Convention on Biological Diversity owns the Global Biodiversity Framework, and IPBES assesses the science for governments.
Defra leads UK biodiversity policy, Natural England advises on nature in England, and the government publishes the UK biodiversity indicators.
The UN Environment Programme and UNEP Finance Initiative publish programme and finance-sector material.
The NGFS conceptual framework guides central banks and supervisors on nature-related risk, and is non-binding by its own words.
The Cambridge Institute for Sustainability Leadership and WWF publish research on natural capital and biodiversity.
Resource use connects nature to circularity: the EU’s circular economy strategy aims to double its circular material use rate by 2030, and our circular economy guide covers the UK side.
Frequently asked
Questions people ask
Is biodiversity reporting mandatory in the UK?
Not for companies. No UK law requires an ordinary company to report on biodiversity in its annual report. Public authorities have a biodiversity duty under section 40 of the NERC Act 2006, and some must report on it under section 40A. Corporate biodiversity reporting is voluntary and framework-driven.
When will TNFD become mandatory in the UK?
No UK mandate or date has been announced. The TNFD recommendations are voluntary. The ISSB is developing nature-related disclosure requirements in the form of an IFRS Practice Statement, a non-mandatory document, and any ISSB output would need separate UK endorsement before it applied here.
What are the TNFD recommendations?
Fourteen recommended disclosures under four pillars: governance, strategy, risk and impact management, and metrics and targets. They carry over all eleven TCFD recommended disclosures and add three specific to nature, covering engagement with Indigenous Peoples, local communities and affected stakeholders, priority locations, and value-chain processes.
What is the TNFD LEAP approach?
LEAP is the TNFD’s assessment approach: Locate your interface with nature, Evaluate your dependencies and impacts, Assess the resulting risks and opportunities, and Prepare to respond and report. It is guidance for doing the assessment behind a disclosure, not a disclosure requirement in itself.
Is the TNFD still active?
Its technical programme is closing. In November 2025 the TNFD said it would complete technical work in progress by the third quarter of 2026 and pause any further technical guidance, supporting the ISSB’s nature work. Its September 2026 status report says 802 organisations have committed to TNFD-aligned disclosure.
What is GRI 101?
GRI 101: Biodiversity 2024 is the Global Reporting Initiative’s biodiversity topic standard. It took effect for reporting from 1 January 2026 and replaces GRI 304: Biodiversity 2016. Before 2023, "GRI 101" meant the old Foundation standard, so a reference to it should always carry a date.
Is the ISSB writing a nature standard?
Not a new Standard. In April 2026 the ISSB decided to propose nature-related requirements and guidance as an IFRS Practice Statement, and in July 2026 it gave permission to ballot an exposure draft with a 120-day comment period. A Practice Statement is not mandatory, but a jurisdiction can choose to mandate it.
How does biodiversity reporting relate to biodiversity net gain?
Biodiversity net gain is a planning requirement in England: development must deliver at least a 10% gain in biodiversity value. It is not a reporting duty, but the habitat data and gain plans it produces can support a company’s voluntary nature disclosures.
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 Taskforce on Nature-related Financial Disclosures (v1.0, September 2023)
Fourteen disclosures, four pillars, and the three nature-specific additions.
- TNFDTNFD 2026 Status Report (September 2026)
802 organisations committed; over 1,000 have published TNFD-aligned reports.
- TNFDNews release, 7 November 2025 — the ISSB decision and the TNFD’s technical programme
Technical work to complete by Q3 2026; further guidance paused.
- IFRS FoundationISSB work plan — Nature-related Disclosures
Permission to ballot, July 2026; 120-day comment period.
- IFRS FoundationISSB Update, April 2026
The decision to propose an IFRS Practice Statement.
- GRIGRI Standards — GRI 101: Biodiversity 2024
Effective 1 January 2026; replaces GRI 304.
- Convention on Biological DiversityKunming-Montreal Global Biodiversity Framework, Target 15
Asks Parties to put disclosure measures in place; binds Parties, not companies.
- legislation.gov.ukNERC Act 2006, section 40 — the biodiversity duty
Public authorities must consider action to further biodiversity.
- legislation.gov.ukNERC Act 2006, section 40A — biodiversity reports
Which authorities in England must report.
- legislation.gov.ukTown and Country Planning Act 1990, Schedule 7A — biodiversity gain
The 10% planning requirement in England.
- NGFSNature-related Financial Risks: a Conceptual Framework (July 2024)
Non-binding, by its own words.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
UK SRS S1 covers sustainability-related risks and opportunities generally.
- FCAPS26/19: Aligning listed issuers’ sustainability disclosures with international standards
Comply or explain from 2027, with a two-year relief for non-climate matters.
- CDPCDP scores and 2026 scoring
Forests and water scored; biodiversity questions not scored in 2026.