TNFD vs CBD Global Biodiversity Framework

Quick Comparison

What is the TNFD?

The Taskforce on Nature-related Financial Disclosures (TNFD) is a market-led body, launched in 2021 with G20 support, that published its final recommendations in September 2023. Its recommended disclosures follow the four pillars familiar from the TCFD: governance, strategy, risk and impact management, and metrics and targets. They add nature-specific requirements, such as disclosing priority locations and describing engagement with Indigenous Peoples and local communities, along with core metrics reported on a comply-or-explain basis.

Behind the disclosures sits the LEAP approach, short for Locate, Evaluate, Assess and Prepare, which takes an organization from where it touches nature to what it should report. The TNFD says its recommendations were designed to align with the global policy goals of the Kunming-Montreal Global Biodiversity Framework, which is the formal bridge between the two.

In November 2025, the TNFD reported that 733 organizations from 56 countries had committed to TNFD-aligned reporting, including 179 financial institutions with $22.4 trillion in assets under management. The ISSB decided in late 2025 to develop nature-related disclosure requirements drawing on the TNFD's recommendations, with an exposure draft targeted for October 2026, and the TNFD is pausing new technical work once it finishes the work in progress, which it planned to complete by the third quarter of 2026. The ISSB's chair has encouraged market participants to keep using the TNFD framework in the meantime.

In April 2026 the ISSB agreed to propose those requirements as an IFRS Practice Statement. The Practice Statement would complement IFRS S1 and IFRS S2 and carry the full effect of an ISSB Standard for companies that apply it.

What is the CBD Global Biodiversity Framework?

The Kunming-Montreal Global Biodiversity Framework (GBF) is the plan governments agreed under the Convention on Biological Diversity at COP15 in Montreal in December 2022. It sets four long-term goals and 23 targets for 2030, covering conservation, sustainable use, benefit-sharing, finance and business disclosure, with the aim of halting and reversing biodiversity loss. The GBF was adopted as a decision of the Parties rather than as a new treaty, so it works through national action: biodiversity strategies and action plans, national targets and national reports. Our GBF guide covers the targets in more detail.

Target 15 is the business hook. It asks governments to take legal, administrative or policy measures to encourage and enable business, and in particular to ensure that large and transnational companies and financial institutions regularly monitor, assess and transparently disclose their biodiversity risks, dependencies and impacts across operations, value chains and portfolios. It also covers information for consumers and reporting on access and benefit-sharing compliance, with the goal of reducing negative impacts and biodiversity-related risks to business.

The framework runs on a cycle of negotiation, reporting and review. COP16 in Cali, Colombia, was suspended for lack of quorum on November 2, 2024, and concluded in Rome on February 27, 2025, where Parties finalized the monitoring framework and agreed a strategy to mobilize at least $200 billion a year by 2030 from all sources, including international flows of $20 billion a year by 2025, rising to $30 billion by 2030.

By March 2026, 125 countries, nearly two-thirds of the 196 Parties, had filed the seventh national reports that were due on February 28, 2026. Those reports feed COP17 in Yerevan, Armenia, from October 19 to 30, 2026, which holds the first global review of collective progress under the framework.

Key Differences

1. Who is accountable. The GBF commits governments; the TNFD guides companies and financial institutions. Neither creates legal duties for a company on its own; duties arrive when a jurisdiction writes Target 15 into law or adopts disclosure standards that build on TNFD content. The United States signed the CBD in 1993 but never became a Party, so U.S. companies meet the GBF indirectly, through rules in other jurisdictions where they operate, through investors and through customers' supply chain requirements.

2. What each is for. The GBF sets outcomes for nature itself: what the world should achieve by 2030. The TNFD sets out what an organization should assess and report so that investors, lenders and others can judge its nature-related dependencies, impacts, risks and opportunities. One is a destination; the other shows where a company stands relative to it.

3. Materiality. Target 15 is written in terms of risks, dependencies and impacts, which puts harm to nature on an equal footing with risk to business. The TNFD asks preparers to state how they apply materiality and was designed to work with the investor focus of the ISSB's standards as well as the impact focus of GRI and the EU's CSRD. That flexibility helps adoption, but it means two TNFD-aligned reports can rest on different materiality choices.

4. Unit of analysis. The GBF is measured country by country, through the national indicators in its monitoring framework. The TNFD works organization by organization and place by place, which is why its strategy pillar asks for the priority locations in an organization's direct operations and, where possible, its value chains.

5. Money and lifespan. The GBF carries finance commitments by governments, including the $200 billion a year mobilization goal. The TNFD has no financial mechanism; its lever is the capital markets, where disclosure helps investors and lenders price nature-related risk. The GBF runs to 2030, while the TNFD's technical role is passing to the ISSB.

When to Use Each

Use the TNFD when:

• You need to disclose nature-related issues to investors, lenders or regulators, or want to be ready for the ISSB's nature requirements.
• You need a structured method to assess dependencies and impacts across operations and value chains; our TNFD reporting guide walks through it.
• You are a financial institution assessing nature exposure across a portfolio.

Use the GBF when:

• You are setting corporate nature targets and want them to point at the outcomes governments are pursuing.
• You operate in countries turning Target 15 into disclosure rules and need to anticipate what those rules will ask.
• You work with governments, development banks or conservation partners whose programs and funding are organized around GBF targets.

Use both when:

• You report with the TNFD and want to show how your own targets contribute to specific GBF targets.
• You need one body of analysis to serve an investor audience and a policy audience, such as a regulator or a public funder, at the same time.

Council Fire's Recommendation

Stop treating these as alternatives. Use the GBF to decide which outcomes your nature strategy should serve, and the TNFD to structure how you assess, manage and report on it. Waiting for the ISSB is not a reason to delay: its chair has said material nature-related disclosure is "not optional" because IFRS S1 already requires it, and the coming requirements will draw on the TNFD, so assessment work done now carries forward.

Council Fire approaches nature disclosure as strategy first. We start with a location-based view of where operations and suppliers depend on and affect ecosystems, engage the communities and stakeholders who live with those effects, and turn the findings into targets and governance that a board can own. We then map those targets to the specific GBF targets they serve, so the same work speaks to investors now and to regulators as national rules arrive.