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TNFD Reporting for Indian Companies in 2026: How Nature Disclosure Maps to BRSR

C² Team
Aug 5
4 min read

Indian sustainability teams have spent three years getting carbon numbers into shape. In 2026, investors and global customers are asking a wider question: what does your business depend on from nature, and what does it do to nature?

That question now has a framework behind it, the Taskforce on Nature-related Financial Disclosures (TNFD), and since November 2025 it also has a route into mainstream accounting standards. Here is what Indian companies need to know, and why BRSR filers are further along than they think.

What TNFD actually asks for

TNFD published its final recommendations in September 2023. The structure mirrors the TCFD climate framework Indian finance teams already know: 14 recommended disclosures across four pillars, covering governance, strategy, risk and impact management, and metrics and targets.

The difference is scope. TNFD covers dependencies, impacts, risks and opportunities. A dyeing unit depends on freshwater. A cement plant alters a limestone landscape. An agri-processor depends on soil health and pollination. TNFD asks you to locate where those interfaces sit, evaluate them, and report what they mean financially.

The assessment method is the LEAP approach: Locate your interface with nature, Evaluate dependencies and impacts, Assess risks and opportunities, Prepare to respond and report. ISO has since published ISO 17298 on biodiversity for organisations, which operationalises LEAP for companies of any size.

Adoption has crossed 733 organisations, and Indian names are on the list

Ahead of COP30 in November 2025, TNFD reported 733 organisations committed to nature-related reporting, drawn from 56 countries and areas, 26 of them emerging markets, and 64 of 77 SASB sectors. Listed adopters represent over USD 9.4 trillion in market capitalisation. A further 179 financial institutions represent USD 22.4 trillion in assets under management, including a quarter of the world's globally systemically important banks. Adoption rose 46% from COP16 in November 2024.

Indian and India-linked adopters include Tata Steel, Adani Ports and Special Economic Zone, and Bangalore International Airport. ITC has published an inaugural Nature Report built on a LEAP-based assessment, and Tata Steel's CFO Koushik Chatterjee sits on the TNFD Taskforce. Adopters commit to publishing TNFD-aligned disclosures within annual reporting by FY2026 or earlier, which makes this a current agenda item rather than a 2030 one.

The BRSR overlap is bigger than most teams assume

On 2 September 2025, at CII's 20th Global Sustainability Summit in New Delhi, the India Business & Biodiversity Initiative, CII and TNFD jointly published a mapping report, Integrating nature-related aspects in BRSR disclosures using the TNFD recommendations. Its findings matter for every one of India's top 1,000 listed filers:

  • Most of TNFD's 14 recommended disclosures on governance, strategy and risk management are already reflected in existing BRSR requirements.

  • BRSR Core indicators overlap with many of TNFD's core disclosure metrics.

  • Both frameworks require disclosure on operations in or around ecologically sensitive locations. BRSR Principle 6 already asks for offices and operations near national parks, wildlife sanctuaries, biosphere reserves, wetlands, biodiversity hotspots, forests and coastal regulation zones.

  • Both cover the quality of an organisation's engagement with affected local stakeholders.

The practical implication is that LEAP can feed your annual BRSR cycle instead of running beside it, and a correspondence table inside a single report can serve SEBI, TNFD-aligned investors and export customers at once. If your reporting base is still shaky, fix that first: our guide to BRSR Core assurance in 2026 covers what the top 500 expansion means in practice.

What the ISSB decision changes

On 7 November 2025 the ISSB confirmed it will move into standard-setting on nature-related risks and opportunities, drawing on TNFD's recommendations, metrics and guidance, including LEAP. The ISSB is targeting an exposure draft by CBD COP17 in October 2026, with any requirements following public consultation after that.

TNFD itself is winding down technical work rather than disappearing. It will complete work in progress, including additional sector guidance, by Q3 2026, then pause and support the ISSB, so its recommendations remain the working reference in the meantime. The route into regulation runs through IFRS S1, which the ISSB confirms already covers nature-related issues. With ISSB standards adopted or used in nearly 40 jurisdictions, nature disclosure is heading into mainstream annual reporting rather than staying a voluntary appendix.

One 2026 deadline is already live. GRI 101: Biodiversity 2024 took effect on 1 January 2026 and applies to all biodiversity reporting published from that date, replacing GRI 304. Indian companies reporting under GRI are inside that window now.

A realistic first year

  1. Run Locate first. Map your sites and key sourcing regions against protected and ecologically sensitive areas. You likely hold most of this already for BRSR Principle 6.

  2. Pick two or three material dependencies. Water, land use change and soil are the usual starting set. Attempting every realm in year one produces a report nobody can verify.

  3. Reuse your GHG inventory. Climate change is one of the drivers of nature loss, so your Scope 1, 2 and 3 work is an input, not a separate track.

  4. Build the BRSR to TNFD correspondence table before writing narrative. It shows you what you already disclose and what is genuinely new.

  5. Settle governance ownership early. TNFD and Accounting for Sustainability published CFO-specific guidance on nature-related issues in June 2026, aimed at exactly this conversation.

Where restoration fits, and where it does not

Nature disclosure and nature action are different things, and conflating them is the most common mistake we see. A TNFD-aligned assessment tells you where your dependencies and impacts actually sit. Plantation, watershed work and habitat restoration are responses you choose afterwards, and they do not substitute for the assessment. Where a site-level impact is identified near a degraded landscape, native-species restoration such as Miyawaki afforestation can be a credible response, provided survival rates and biodiversity outcomes are monitored over years rather than assumed at planting.

Csquare's ESG reporting team works with Indian companies on BRSR, GHG inventories and nature-related assessment. If you want a clear view of where your existing BRSR disclosures already meet TNFD and what is missing, get in touch with our team.

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