TNFD and Nature Reporting: What Australian Companies Should Prepare For

Forty-nine percent of Australia's GDP — roughly $896 billion — depends on nature. Not in some abstract, tree-hugging sense. In a direct, material, "if pollinators collapse your food supply chain breaks" sense. Mining, agriculture, construction, water utilities, forestry. These aren't peripheral industries. They're the backbone of the Australian economy, and they all sit on top of ecosystem services they've never had to measure, disclose, or defend.

That's about to change. TNFD reporting in Australia is still voluntary today. But the ISSB voted unanimously in January 2026 to develop nature-related disclosure standards, drawing directly on the TNFD framework. An exposure draft is expected by COP17 in October this year. And given that Australia adopted the ISSB's climate standards almost verbatim as AASB S2, the trajectory here isn't subtle.

Twenty-three Australian companies — including Qantas, Telstra, Brambles, GPT Group, and EnergyAustralia — are already reporting against TNFD recommendations. They're not doing it because someone made them. They're doing it because they can see what's coming.

Nature is not climate with different metrics

This is the first thing that trips people up. TNFD isn't just TCFD with "biodiversity" swapped in for "carbon." The differences are structural.

Climate reporting under ASRS (AASB S2) centres on a single substance: greenhouse gases. You measure tonnes of CO2-equivalent. You apply emission factors. You disclose Scope 1, 2, and 3. The methodologies are messy — we know that better than most — but the basic unit of measurement is universal.

Nature doesn't work that way. The TNFD framework covers biodiversity loss, water degradation, land-use change, pollution, and resource extraction. There's no single unit. A mining operation in the Pilbara has completely different nature dependencies to a dairy farm in Gippsland or a property portfolio in Sydney. The metrics change by industry, geography, and ecosystem type.

The TNFD's 14 recommended disclosures are structured around four pillars that will look familiar if you've done climate reporting: governance, strategy, risk and impact management, and metrics and targets. Same architecture as TCFD — which, as we've written about, is now embedded inside ASRS. But there's a critical addition. TNFD adds a location dimension that climate reporting mostly ignores.

Where your operations sit matters enormously for nature. A warehouse in suburban Melbourne has different biodiversity interactions than an identical warehouse next to a wetland in the Hunter Valley. Climate reporting rarely cares about that distinction — a tonne of CO2 is a tonne of CO2 regardless of location. Nature reporting demands you know exactly where your interfaces with ecosystems are, and what those ecosystems look like.

The LEAP approach — and why it's harder than it sounds

TNFD's core assessment methodology is called LEAP: Locate, Evaluate, Assess, Prepare. It's designed to be iterative rather than one-and-done, and every early adopter we've spoken to says the first phase is the hardest.

Locate means mapping where your organisation interfaces with nature. Not just your owned sites — your supply chain too. If you're a construction company, that means understanding where your timber, aggregates, steel, and concrete come from and what ecosystems those extraction points sit within. If you're a food manufacturer, it means tracing agricultural inputs back to specific regions and understanding whether those regions face water stress, soil degradation, or habitat loss.

Evaluate means understanding your dependencies and impacts at those locations. Dependencies are the ecosystem services your business relies on — clean water, pollination, stable soil, climate regulation. Impacts are the effects your operations have on nature — land clearing, water extraction, pollution discharge, habitat fragmentation.

Assess translates those dependencies and impacts into financial risks and opportunities. A water utility dependent on catchment health faces a different risk profile if that catchment is degraded. A mining company operating near threatened species habitat faces regulatory, reputational, and operational risks that don't show up in a carbon footprint.

Prepare is about integrating all of this into your governance, strategy, and reporting. Which, frankly, is where most companies stall out — because the data requirements are genuinely different from anything they've done before.

We'll be honest: we're still figuring out how automated tools (ours included) can help with the Locate and Evaluate phases. Climate data is hard enough — nature data involves spatial analysis, species databases, ecosystem condition assessments, and location-specific metrics that don't live in utility bills or financial systems. The data infrastructure for nature reporting is years behind where climate data infrastructure is today.

Which Australian industries should be paying attention right now

Not every company faces the same level of nature-related risk. But in Australia, the list of exposed industries is longer than you'd think.

Mining and resources is the obvious one. Australia's mining sector interacts with some of the most biodiversity-rich and ecologically sensitive landscapes on the continent. The Pilbara, the Kimberley, the Great Barrier Reef catchment. BHP and Rio Tinto have been doing biodiversity assessments for decades under the EPBC Act, but TNFD asks for something different — a financial risk lens on nature dependency, not just an environmental impact statement. The TNFD has published sector-specific guidance for metals and mining, and it goes well beyond what most companies currently disclose.

Agriculture and food is where the dependency angle bites hardest. Australian agriculture contributes around $70 billion to GDP and depends entirely on ecosystem services — soil health, water availability, pollination, natural pest control. Drought, soil degradation, and biodiversity loss aren't abstract risks for these companies. They're operational risks that show up in yield data and cost of production. Agriculture is also one of the eight priority sectors for TNFD guidance.

Construction and property might surprise people. But construction is the world's largest consumer of raw materials. Concrete, timber, aggregates, steel — all extracted from or dependent on natural systems. Property developers and managers with assets near waterways, coastal zones, or native vegetation face direct nature-related risks. GPT Group (one of Australia's largest REITs) is already a TNFD early adopter, which tells you something about where the property sector sees this heading.

Water utilities sit at the intersection of nature dependency and nature impact. They depend on catchment health for water quality and supply. They impact aquatic ecosystems through extraction and discharge. If any sector should be running the LEAP assessment today, it's water.

Forestry and fisheries — both directly dependent on and directly impacting biodiversity — round out the high-exposure group. Together with agriculture, these sectors generate $293.6 billion per year in Australia, about 16% of GDP, with very high direct nature dependency.

Why your climate reporting gives you a head start

Here's the argument we actually want to make. If you've been building solid climate reporting infrastructure — data collection systems, governance structures, assurance-ready processes — you're in a better position for nature reporting than you think.

The four-pillar structure is identical. TNFD uses the same governance, strategy, risk management, and metrics architecture that TCFD pioneered and ASRS made mandatory. Your board oversight processes, your risk assessment frameworks, your disclosure templates — they all carry over. You don't rebuild from scratch. You extend.

Your emissions data feeds into nature assessments. Scope 1 and 2 emissions data — particularly around energy, fuel, and refrigerants — already tells you something about your environmental footprint. Scope 3 supplier data, if you've started collecting it, maps parts of your supply chain that overlap with the LEAP "Locate" phase.

Your data systems matter more than you'd expect. Companies that have moved from spreadsheets to structured data platforms for climate reporting have a massive advantage. Nature reporting will be even more data-intensive — location coordinates, spatial datasets, temporal biodiversity data, water stress indices. If you're still doing climate on spreadsheets, adding nature on top will be brutal.

But don't kid yourself. Climate reporting readiness gets you maybe 30% of the way there. The other 70% — spatial data, ecosystem condition baselines, species interaction maps, location-specific metrics — is new territory for almost everyone. Two-thirds of companies globally say they aren't prepared for TNFD disclosures. In Australia, we'd guess it's higher.

Where the regulation is headed

Let's trace the regulatory signal, because it's clearer than most people realise.

The ISSB met in January 2026 and unanimously approved a standard-setting project on nature-related risks and opportunities. This isn't a "maybe we'll look at it" — it's an active workstream with an exposure draft targeted for COP17 in October 2026. The scope covers biodiversity, land use, water, pollution, and resource extraction. The ISSB has explicitly stated it will draw on the TNFD's recommendations, metrics, and LEAP approach.

The form these requirements will take isn't settled yet. They could be application guidance bolted onto IFRS S1, a standalone standard (some are calling it IFRS S3, though that's not official), or something else. But the direction is unambiguous.

And here's the Australian angle. The AASB published a research report in September 2025 (RR26) specifically on Biodiversity, Ecosystems and Ecosystem Services. They're monitoring ISSB's work, they've analysed nature-related disclosures across Australian companies, and they've found that the Financials and Materials sectors are already the most active in biodiversity-related reporting. The AASB isn't just watching. They're doing the homework to bring nature standards to Australia once the ISSB finalises them.

Meanwhile, the federal government's Nature Positive agenda is complicated. The Nature Positive Bills were pulled from Parliament in February 2025 and haven't returned. But the Nature Repair Market launched in March 2025 and is operational — biodiversity certificates are tradeable through the Clean Energy Regulator. And Australia's Strategy for Nature 2024-2030, aligned with the Kunming-Montreal Global Biodiversity Framework, sets targets that will eventually need measurement and disclosure infrastructure.

The political timeline for mandatory nature reporting in Australia is uncertain. We'd guess 2028 or 2029 at the earliest, depending on how fast the ISSB moves from exposure draft to final standard and how quickly AASB adopts it. But waiting for a mandate is exactly the wrong strategy. Group 1 ASRS reporters who started preparing early spent a fraction of what latecomers did. The same pattern will repeat with nature.

Three things to do this year (not ten, not twenty, three)

If you're a sustainability manager or board member looking at TNFD, here's where we'd start. Not a twelve-month program. Not a $200K consultant engagement. Three concrete things.

First, run a quick nature-dependency scan. Pick your top five sites and your top ten suppliers by spend. For each one, ask: what ecosystem services does this location depend on? Water? Soil? Pollination? Stable climate? You can use freely available tools like the ENCORE database (developed by UNEP-WCMC) or the IBAT biodiversity screening tool. This isn't a full LEAP assessment. It's a rough map of where your nature exposure sits. Budget two to three days of analyst time.

Second, extend your climate governance to cover nature. If your board already has a climate risk committee or a sustainability sub-committee, add nature-related risks to their terms of reference. Don't create a parallel structure. The TNFD pillar on governance will ask the same questions ASRS already asks — does the board oversee nature risks, what's management's role, how are stakeholders engaged? If those processes already exist for climate, widening the scope is far cheaper than building new ones.

Third, start talking to your auditors about nature data. This is a conversation, not a project. Ask your assurance provider what they're seeing from other clients on TNFD readiness. Ask what data standards they'd expect for nature-related metrics. Get a sense of the assurance landscape before it becomes a compliance requirement. The firms that scrambled to find ASRS-capable auditors in 2025 will tell you — early conversations save money.

That's it. Three actions. None of them require buying software or hiring a new team. They're about building awareness and connecting nature risk to the climate reporting structures you've already invested in.

Nature reporting will be harder than climate reporting. The data is messier, the metrics are less standardised, and the science is more location-specific. But the companies that start with imperfect data today will be the ones that can actually report when the mandate arrives. The ones that wait for perfect standards will be starting from zero.

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