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Nature Is the New Material Risk: Inside the TNFD–IFRS “S3” Pivot—and Why IUCN Must Be in the Room

In boardrooms from New York to Nairobi, a quiet revolution is underway. Climate once owned the sustainability spotlight; now nature—the species, ecosystems, and services that keep supply chains alive—is taking the stage. Two initiatives sit at the center of this shift: the Taskforce on Nature-related Financial Disclosures (TNFD) and the International Sustainability Standards Board (ISSB) ’s emerging biodiversity project, often shorthand in markets as “IFRS S3 (BEES)” for Biodiversity, Ecosystems and Ecosystem Services. One is voluntary and already in the wild; the other is moving through the IFRS Foundation’s exacting due process toward a potential global baseline. The story of how these two efforts braid together reveals a simple truth: without the IUCN —and its Red List and Green List—the market will be flying half blind.

The New Disclosure Playbook: From Climate to Nature

In September 2023, TNFD published its final recommendations—14 disclosures organized under four familiar pillars (Governance, Strategy, Risk & Impact Management, Metrics & Targets), together with the LEAP approach (Locate, Evaluate, Assess, Prepare) to help companies actually do the work of assessing nature-related issues. The process drew on pilots with hundreds of organizations and intentionally mirrored the architecture of TCFD and the ISSB to speed adoption. By 2025, TNFD reported hundreds of early adopters and launched capacity tools to close the skills gap.

Meanwhile, the International Sustainability Standards Board (ISSB)—which issued IFRS S1 (general requirements) and IFRS S2 (climate) in 2023 and secured IOSCO’s endorsement—turned its research lens to BEES. The ISSB has been explicit: biodiversity disclosures must be decision‑useful for investors, interoperable with other frameworks, and grounded in the ISSB system that already leans on SASB’s industry-based content. The timeline is cautious: research first, then any potential standard-setting. But the direction of travel is clear.

A key inflection point arrived in April 2025, when the IFRS Foundation and Taskforce on Nature-related Financial Disclosures (TNFD) signed a Memorandum of Understanding to formalize collaboration: the ISSB would consider the TNFD recommendations in its BEES research; the two bodies would share technical work and engage markets together. Translation: TNFD’s market-tested guidance will not sit on a shelf while the ISSB builds; it is raw material for the next standard.

Why This Matters to Markets

The mechanics are wonky; the stakes are not. Nature loss is a cash‑flow issue—for water‑intensive processors, raw‑material‑dependent manufacturers, land‑using sectors, and financial institutions with exposures all along those chains. The Kunming‑Montreal Global Biodiversity Framework’s Target 15 calls on jurisdictions to require large and transnational companies and financial institutions to assess, monitor, and disclose biodiversity risks, dependencies, and impacts. Regulators will increasingly look to the ISSB’s global baseline as they draft rules. BEES is where the plumbing gets built.

In other words, can investors compare Company A’s exposure to critically endangered species with Company B’s? Can lenders price the risk of a plantation’s encroachment near a protected area? Can insurers factor ecosystem service degradation into catastrophe models? Without common definitions, location‑specific metrics, and authoritative reference lists, the answer is no.

The Missing Ingredient: IUCN

Enter the International Union for Conservation of Nature ( IUCN )—the world’s largest conservation network and a trusted repository of conservation data and standards, with deep convening power across governments, civil society, academia, and business. IUCN has already produced corporate biodiversity performance guidelines and operates two assets whose value to markets is hard to overstate: the Red List of Threatened Species and the Green List of Protected and Conserved Areas. Each could be native infrastructure for IFRS S3.

• The IUCN Red List is the world’s most comprehensive source on the conservation status of species and the threats they face. It’s a living database—now counting over 169,000 assessed species, with ~47,000 threatened—used by governments, scientists, and businesses alike. It offers common categories (CR, EN, VU) and rich ecological context that can be operationalized in risk models.

• The IUCN Green List is a certification standard for protected and conserved areas that meet rigorous criteria for governance, design, management, and conservation outcomes. With dozens of certified sites and hundreds in the pipeline, it provides a quality signal that goes beyond a polygon on a map. Not all protected areas are equal; Green List sites are the ones proven to deliver results.

IUCN’s data and methods are not just scientifically credible—they are built for aggregation, designed to translate site‑level realities into corporate‑level performance. That is exactly the chasm IFRS S3 must bridge.

How TNFD and ISSB Set the Table—And Where IUCN Must Sit

TNFD’s LEAP method forces companies to Locate their interface with nature and identify priority locations—a nod to the local character of biodiversity risk. It’s hard to implement without authoritative signals about which species and ecosystems matter most and where. The Red List and Green List fill that gap: Red List for which species are at risk, Green List for which areas are effectively conserved.

The ISSB’s system, for its part, mandates industry-specific thinking and financial materiality. SASB heritage matters here: sectors from forestry and food to mining and apparel face different biodiversity vectors, and the ISSB requires entities to refer to industry-based guidance and to report on location‑specific and value‑chain exposures when material. IUCN’s datasets would anchor those sector stories in comparable, verifiable facts.

The MoU between IFRS and TNFD foreshadows this integration: TNFD’s market-facing machinery plus IUCN’s scientific backbone equals an implementable global baseline regulators and investors can trust. Without IUCN at the center, BEES risks becoming a taxonomy of intent—without the biology.

A Practical Blueprint: Bringing Red List and Green List Into IFRS S3

1) Location‑based metrics that mean something. Require disclosure of operations and supply nodes located within (or materially affecting) ranges of Red‑Listed species (CR/EN/VU), and within set buffers of Green Listed sites. Phrased in IFRS language: disclose exposure and sensitivity to biodiversity risks in priority locations, with quantitative counts of assets and revenue share at risk.

2) A minimal viable metrics set (MVM) for comparability. Borrowing from IUCN’s Pressure‑State‑Response‑Benefit logic for corporate biodiversity performance, define a small, scalable indicator set that every company with material BEES exposure must report:

• Pressure: area (ha) of habitat conversion within supply chains; pesticide or nutrient intensity in sensitive catchments.

• State: number of Red‑Listed species potentially impacted (by category) and ecosystem condition where feasible.

• Response: percent of priority sites under Green List-aligned management effectiveness; share of suppliers under verified nature‑positive practices.

• Benefit: proxy indicators of ecosystem services relevant to financial performance (e.g., water yield stability).

3) Interoperability with TNFD’s LEAP and the GBF’s Target 15. Encourage preparers to use LEAP to identify priority locations, then map those against Red List ranges and Green List sites; ensure disclosures meet Target 15 expectations on dependencies, impacts, and risk reduction. This embeds policy relevance into investor-grade reporting.

4) Assurance and data quality. IUCN can support methodological notes, reference layers, and confidence ratings for species and site data—akin to how GHG reporting references the GHG Protocol. For BEES, IUCN becomes the default scientific reference, improving auditability without prescribing a single tool.

5) Safeguards for rights and equity. IUCN has already worked with TNFD to bring Indigenous Peoples and Local Communities (IPLCs) into the nature‑risk conversation. Codifying stakeholder rights and engagement into IFRS S3’s governance disclosures would reduce social license risk and align with modern stewardship expectations.

What Could Go Wrong Without IUCN

Data drift and greenwish metrics. Without Red List and Green List anchoring, companies will choose heterogeneous proxies—think “biodiversity hectares”—that obscure comparability and invite greenwashing. Markets trade on standardized definitions; biodiversity lacks them unless IUCN’s are adopted.

Blind spots in priority locations. TNFD correctly insists on site‑specificity. But recognizing which sites matter requires ecosystem and species intelligence. Absent IUCN, firms will rely on vendor tools with uneven methods, fragmenting the very baseline the ISSB is trying to build.

Social backlash. Ignoring IPLCs’ rights in disclosure design invites litigation and reputational risk. IUCN’s rights‑based practice is the shortest route to legitimacy—and to investor confidence that biodiversity strategies won’t blow up in the field.

The Regulatory Weather Is Changing

IOSCO’s endorsement of the ISSB standards in July 2023 unlocked a path to jurisdictional adoption; early movers are already aligning domestic rules to S1/S2. When BEES matures into a standard, expect the same “adopt or be informed by” approach by regulators. That makes the quality of the inputs—IUCN’s data and standards—a systemic issue for risk pricing.

The ISSB has said out loud that its BEES research will build on existing frameworks—explicitly TNFD and SASB—and strive for interoperability with GRI and ESRS. The IFRS–TNFD MoU is therefore more than a press release; it is a design choice to converge voluntary practice with the global baseline. IUCN is the missing leg of that tripod.

A Reporter’s Take: Follow the Biology

Markets have learned the climate lesson: when you standardize the language (TCFD → S2), adoption takes off; when you anchor it to publicly accessible, science‑based references, assurance becomes cheaper and capital becomes smarter. Biodiversity is messier than carbon, but the same rule applies. The IUCN Red List tells us who is at risk; the Green List tells us where conservation actually works. Bake both into IFRS S3, and you shift disclosures from aspiration to accountability.

The alternative is an expensive detour: a proliferation of methods, a credibility problem for issuers, and investors discounting nature claims they cannot compare. A standard that clears the bar for capital markets should also clear the bar for conservation science. That is a test IUCN helps the ISSB pass.

What Companies Can Do Now

1) Use TNFD’s LEAP to surface priority locations, then overlay Red List ranges and Green List sites to quantify exposure; report internally while the standard evolves. 2) Align your sector metrics with ISSB/SASB guidance and prototype PSRB‑style indicators from IUCN’s corporate guidelines to ensure data scale from site to enterprise. 3) Build governance for IPLC engagement now; it is cheaper than a retrofit when IFRS S3 (BEES) lands.

The Call to Action—for Standard Setters and IUCN

• ISSB: Make Red List and Green List the default references in the exposure and metrics sections; specify a minimal viable metrics set that every material reporter must disclose, with location‑specific counts and revenue-at-risk linkages.

• TNFD: Update guidance to show worked examples of LEAP using Red List/Green List overlays, accelerating capacity building for preparers.

• IUCN: Formalize a data partnership with the ISSB, publish assurance‑friendly documentation, and continue rights‑based safeguards—to keep science, society, and finance in the same room.

If you’re wondering whether this is doable, remember: the ISSB already harmonized an alphabet soup for climate. Nature is harder—but the pieces exist. Put them together, and capital markets will finally be able to see nature risk with the clarity they demand.

Sources

• TNFD framework & LEAP: TNFD final recommendations (Sept 18, 2023); TNFD LEAP guidance; TNFD site overview; UN SEEA note on TNFD alignment.

• ISSB BEES project & architecture: ISSB BEES research cover note (Feb 2025); KPMG analysis of ISSB priorities; EY note on BEES research.

• IFRS–TNFD collaboration: IFRS Foundation–TNFD MoU (Apr 9, 2025); IAS Plus brief on the MoU.

• Global baseline & adoption context: IOSCO endorsement of ISSB standards; IFRS note on IOSCO endorsement.

• IUCN resources: IUCN corporate biodiversity performance guidelines; Guidelines overview (PSRB/aggregation); IUCN Red List portal; Red List update (Apr 9, 2025); IUCN Green List overview; Green List Standard v1.1.

• Interoperability details: ISSB guidance on using SASB/industry-based content; IFRS S2 Appendix B—industry-based requirements.

• Policy alignment: GBF Target 15 (CBD Secretariat).

Simon Mak

Simon Mak didn’t set out to build just another finance firm—he set out to change how business measures success. After graduating from McGill University and earning credentials as a CFA and CMA, Simon founded Ascent Partners in Hong Kong, blending financial rigor with a vision for sustainability. Along the way, he realized that true value isn’t just in numbers—it’s in impact. That belief inspired the Ascent Partners Foundation, which Simon leads as Chairman. The foundation supports causes from poverty relief to environmental protection, partnering with NGOs and sustainability networks to drive real change. His influence extends beyond the boardroom through roles with Friends of the Earth, the UN ESCAP Sustainable Business Network, and industry alliances—always guided by one principle: business should be a force for good.

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