Emily McKenzie
The TNFD framework for managing and disclosing nature-related risks
The Taskforce for Nature-related Financial Disclosure (TNFD) is a global initiative with a mission to develop and deliver a risk management and disclosure framework so that organisations can report and act on evolving nature related risks and its ultimate aim is to support a shift in global financial flows away from outcomes that are harmful to nature towards those that help it thrive. It is market-led, government supported and science-based initiative which has been endorsed by G7 finance ministers. The Taskforce is composed of 34 members from across financial institutions, corporates, and market service providers, and includes a forum of more than 300 institutions who are aligned with the TNFD mission.
The TNFD framework is broader than just disclosure, it’s about risk management, opportunity management and improving decision-making. We’ve been very concerted of being consistent in its approach, so we’ve built on the earlier Taskforce for Climate-related Financial Disclosure (TCFD) and we are aligning with the global baseline that’s emerging for the sustainability standards with the International Sustainability Standards Board (ISSB). There’s a strong emphasis on the importance of location, which is so important for nature impacts, dependencies, risks and opportunities. It’s not only a set of disclosure recommendations like the TCFD; it also provides guidance and internal assessment process which we’ve included based on market feedback on the need to build understanding and capabilities in this space.
The beta TNFD framework was released on the 15th of March. It has three core components. This first is a set of fundamental concepts and definitions around nature to enable market participants to understand what nature is, how they depend on nature, impact nature and what the risks and opportunities are emerging. The second component is a set of draft disclosure recommendations. These are aligned with those put together by the TCFD but extended to consider other specific for nature. The third component is an analytical process we’ve called LEAP, which is for internal analysis, a set of phases and core components for thinking about and assessing nature-related risk and opportunities. We’ve produced both a summary report of the framework, but also an interactive online platform which enables users to see the framework in their own self-paced way. It also enables you to give immediate feedback through the platform on what we could improve, add how easy or difficult you found it. It also links out to wider resources which could be used.
The framework is being developed with an open innovation approach and is currently in a prototype phase. We plan to add many different frameworks like scenarios, metrics sector and specific guidance in subsequent releases. We’ll be adding and extending the framework and revising it based on feedback and consultation over the next 18 months. We really look forward to feedback from users both in the private and public sector.
More information on this is available at: https://framework.tnfd.global/
Discussion
Is there anything that governments can do to improve the accessibility of data that they’re holding in a way which would be helpful for the TNFD?
One of the issues we found is data coverage differs across nature categories – there’s more data for terrestrial biomes than for oceans or freshwater. Governments could be doing a lot here. One thing which came out of the work of the Dasgupta Review is there should be much more emphasis on natural capital accounts in the statistics offices and from the Treasury. But the private sector can also be feeding their data into those same systems. It seems there is a clear role for national governments to be investing more in this data collection and the technology behind it. If they don’t the private sector will drive it forwards themselves. So, I think it’s in the interest of governments to be doing more to create more substance here.
What regulators could also do is look at the role played by ESG data and ratings. These regulators are providing a lot of this data to their investor clients. The Financial Conduct Authority (FCA) is looking at bring them in to the existing regulatory perimeter. This is a step that we would support the FCA taking, or at the very least there can be best practise standards that can be applied to data providers to make sure we have more transparency over methodology being used to measure this data. The CDP have coordinated a letter from investors representing over $130 trillion of assets under management, calling for a database for companies to disclose far more meaningful data on climate, but also deforestation and climate as well. So. the demand is there, but we need more targeted rules and regulations that are looking at data providers, that’s a key missing piece in the UK at present
What is going to or could happen over the next 6-12 months that will help get this agenda embedded into both governments and financial institutions?
The Bank of England currently does some great work on climate change and has set out its supervisory expectations on financial institutions to disclose on climate change. A great next step for the Bank of England would be to integrate biodiversity considerations into existing work on climate change. For instance, looking at how the biennial exploratory scenario, a kind of a stress test exercise for the financial system, should incorporate biodiversity. They could also publish their own expectations for what financial institutions need to start doing today. This is an urgently needed first step to build momentum on this important topic.
A big issue for central banks and supervisors is understanding the climate change and biodiversity nexus and understanding the exposure is of the financial system. Very few central banks have started on this with very basic impact and dependency assessments, but these have been quite a successful way within their central banks to get the discussion started and justify the importance of addressing this.
We do need more stress-testing, but we also need a lot more scenarios that are easily usable by financial institutions. The NGFS does a fantastic job with climate scenarios and if nature could start to be incorporated as well, it will make it easier for financial institutions to start understanding this. If we’re to adopt proposed targets at COP15 to rewire our economic system by 2030 to stop and reverse nature loss, which means we’re going to have to move quickly. There is enough data and tools out there to start working out your biggest exposures and how to mitigate these.
Important for policymakers to recognise the linkages between climate and nature, to ensure that that’s reflected in all approaches, rather than operating in silos.
The CBD’s Global Biodiversity Framework needs to be ambitious, and it needs to be specific. The TNFD is a voluntary, market-led framework, which is a great way to begin, but over time governments and regulators will need to think about what needs to be mandatory and disclosed against those frameworks.
This issue needs traction in private and public markets, but the language can sometimes be difficult, how can we communicate this issue in a way the public can understand clearly?
If you look at biodiversity accounting, the terminology is so vague and definitions of biodiversity so generalised, it doesn’t mean anything to people. We’ve argued extinction is a very good way of communicating the urgency of the problem. Species accounting is a part of biodiversity reporting and disclosure frameworks. But we’ve suggested to use an extinction rate as a way of easily communicating what the problem is with biodiversity. With climate we have an easy target on reducing temperatures, but we don’t have the same for biodiversity. Language is important and the vagueness around nature terminology is one of the problems.
The language of financial risk is very familiar in western spheres where we’re occupied with measuring, evidence bases, and data. We must be aware this data focus is inherently quite alienating to other cultures, especially indigenous cultures who view the value of nature in more intrinsic terms. Even in the global north there are a lot of people who don’t speak the language of financial risk. So, we need to wary of the limitations of the financial risk narrative and not lose sight of the fact that what we’re talking about is ensuring that finance funds good activities and stops funding harmful activities. That’s the crux of the problem and the financial risk narrative is a very useful way to raise awareness amongst western actors, but its not the only story we need to tell.
We need multilingualism in this because, if we’re have any hope of getting the financial markets to turn, it needs to become unfortunately a very financialised language. Currently nature is spoken about mostly in its conservation sense and this doesn’t relate to financial markets. So, on the one hand you have to bring this very financialised perspective of nature, of our dependencies on it, and on the other hand, we need to bring the rest of society with us to whom this is a very foreign way of addressing things. So, there is a there is a call to be more multilingual in our approaches and speaking certain languages with certain audiences to get them into the conversation.
How do you make sure that the financial flows go to the places where globally there is the most benefit?
The issue is the financial flows are already there causing the damage, rather than a lack of positive financial flow. So, its things like TNFD which needs to be global frameworks that allows us to manage these existing financial flows. There’s indigenous people and local communities and their valued spaces, and the reason these things are being lost is because of encroachment from large financial projects into those places. So, the finance is already there, it’s about managing it appropriately rather than trying to find new flows of finance.