The IIF responds to the TNFD consultation on its v0.4 beta framework

On June 1, the IIF submitted a response letter to the Taskforce on Nature-related Financial Disclosures (TNFD) consultation on its v0.4 beta framework.

In the letter, the IIF welcomes the release of the TNFD framework, which, when finalized, has the potential to serve as an important voluntary, market-based, and cross-sectoral framework for disclosure of nature-related information. However, the IIF comment letter notes that, to fulfill its mission, the TNFD framework should address a set of challenges associated with the identification, assessment, management, and development of strategic responses to nature-related impacts, dependencies, risks and opportunities, which will require substantial development and capacity building efforts across the financial sector and broader economy.

The response addresses key issues related, but not limited to:

• The role that government policies must play in averting nature loss, reducing negative impacts on biodiversity, and guiding economies in a transition towards a nature-positive pathway.
• The extent to which climate-related disclosure approaches can be applied to nature-related information.
• The premature stage of development of metrics and scenario analysis in the nature context.
• The future integration of climate and nature-related disclosures.

Reflecting these challenges, the IIF comment letter makes the following recommendations:

• Specifying that phased implementation approach is permitted and providing a reasonable time period for firms to develop internal capabilities.
• Providing flexibility for firms including financial institutions to determine which metrics are relevant and feasible to them, according to their dependencies and impacts.
• To emphasize the importance of market testing to develop consensus-driven reporting practices that enhance decision-usefulness in nature-related reporting.