Introduction

On October 22, 2026, the International Sustainability Standards Board (ISSB) published an Exposure Draft proposing an IFRS Practice Statement on nature-related disclosures, with public comments due by February 19, 2027. The Practice Statement is non-mandatory in form, yet IFRS S1 already requires companies to disclose material nature-related risks and opportunities, so the draft sets out how that existing obligation should be met. For executives, nature risk now sits inside the same investor reporting architecture that governs climate disclosure under IFRS S2.

The ISSB launched the proposal during the UN Biodiversity Conference (COP17), drawing extensively on the framework of the Taskforce on Nature-related Financial Disclosures (TNFD) (IFRS). This article explains what the ISSB published, how it connects to TNFD, ESRS and GRI, and what leadership teams should decide before the consultation closes.

Key Takeaways

• The ISSB released its nature-related Exposure Draft on October 22, 2026, and the 120-day comment period closes on February 19, 2027.
• The proposal is an IFRS Practice Statement: companies need not apply it to state compliance with ISSB Standards, but a company asserting compliance must meet all of its requirements.
• IFRS S1 already requires disclosure of material nature-related risks and opportunities; the Practice Statement adds specificity on how to provide that information.
• Proposed disclosures include strategic response, resilience informed by nature-related scenario analysis, the amount and percentage of assets or activities vulnerable to nature risk, and nature-related targets.
• Companies using the TNFD framework are well positioned, and jurisdictions can decide whether and when to require the Practice Statement.

What Did the ISSB Publish on Nature-Related Disclosures?

The ISSB released an Exposure Draft on October 22, 2026, proposing an IFRS Practice Statement on nature-related disclosures. The draft is designed to help companies give investors consistent and comparable information on nature-related risks and opportunities, and it is open for public comment until February 19, 2027.

The ISSB announced the consultation on October 22, 2026, and marked the launch with a live webinar during COP17. The 120-day comment period closes on February 19, 2027. The proposals are designed to help companies provide material information about nature-related risks and opportunities, including how their dependencies and impacts on nature give rise to those risks and opportunities.

An IFRS Practice Statement is a stand-alone part of IFRS Foundation materials, developed through the same full due process as a Standard. According to the ISSB, there is no difference between a Practice Statement and a Standard from a content and drafting perspective. The key difference is that a company does not need to comply with the Practice Statement to state compliance with ISSB Standards.

Applying the Practice Statement is a substantive commitment. When a company asserts compliance, the effect on its reporting is the same as applying an ISSB Standard, and it can assert compliance only if it meets all of the requirements. The company must also disclose that it complies, so investors can see whether its reports apply IFRS S1 and IFRS S2 alone or together with the Practice Statement.

Jurisdictions are not required to adopt the Practice Statement to be described as adopters of ISSB Standards, but they can include it in national materials and decide whether and when to require its use. ISSB Vice-Chair Sue Lloyd said the approach balances giving markets time to implement the ISSB Standards well with investor demand for nature information. The ISSB is also asking whether to finalize the Practice Statement or issue nature-related content in another form, for example as a Standard.

The underlying obligation already exists. IFRS S1 requires companies to disclose material information about sustainability-related risks and opportunities that could affect their prospects, including those related to nature. When the ISSB announced the Practice Statement approach in April 2026, Chair Emmanuel Faber stated, “Providing material nature-related disclosures is not optional; IFRS S1 already requires that”.

ISSB Nature Exposure Draft: Proposed Disclosure Requirements

The Exposure Draft proposes a small number of incremental disclosures where investors have a clear, common need. These include the company’s strategic response to nature-related risks and opportunities, resilience informed by nature-related scenario analysis, the share of assets or activities vulnerable to nature risk, and nature-related targets.

According to the ISSB’s Exposure Draft Snapshot, the proposed specific disclosures include the following:

• Strategy and decision-making: how the company has responded, and plans to respond, to nature-related risks and opportunities, whether or not this forms part of a nature-related transition plan.
• Resilience: the resilience of its strategy and business model to uncertainties arising from nature-related risks, informed by nature-related scenario analysis, with the same reliefs available as for climate-related scenario analysis under IFRS S2.
• Vulnerability and alignment metrics: the amount and percentage of assets or business activities vulnerable to nature-related risks and aligned with nature-related opportunities, which align with the equivalent climate metrics in IFRS S2.
• Targets: for each nature-related target, what it relates to, its location-specific aspects and objectives, and whether and how law or regulation informed it.

Two considerations run across the core content areas. Companies would be required to consider the locations of assets and activities throughout the value chain, and to consider interactions, including engagement, with Indigenous Peoples, Local Communities and affected stakeholders. The ISSB states that it drew on TNFD especially to emphasize these two themes.

The draft defines six essential terms: nature-related risks, nature-related opportunities, nature-related physical risks, nature-related transition risks, environmental resources and ecosystem services. To find suitable metrics, companies would be required to consider the SASB Standards and permitted to consider ESRS, the GRI Standards and, as a new source of guidance, the TNFD disclosure metrics.

The draft includes proportionality mechanisms aligned with IFRS S2 and relief from disclosing comparative information in the first annual reporting period. Rather than a mandatory effective date, the Practice Statement would be available for use from its issuance, and a company’s date of initial application would be the beginning of the annual reporting period in which it first applies it.

ISSB Chair Emmanuel Faber framed the rationale in terms of dependencies. Companies rely on water for production, rivers for transportation and bees for pollination, and threats to that access create risks and opportunities that affect their prospects.

How Many Companies Already Report on Nature?

As of October 2026, 836 organizations across 57 countries have committed to TNFD-aligned reporting, a 14% increase in less than a year. Adopters include financial institutions representing more than $26 trillion in assets under management and publicly listed companies accounting for over $10.5 trillion in market capitalization.

TNFD reported that 836 companies and financial institutions have committed to corporate reporting aligned with its recommended disclosures. The committed financial institutions represent more than $26 trillion in assets under management, and the listed companies account for over $10.5 trillion in market capitalization.

Disclosure activity extends beyond formal adopters. TNFD has found that more than 1,100 organizations now make one or more nature-related disclosures aligned with its recommendations, covering a global average of 8 of the 14 recommended disclosures.

For executives, these figures set the peer benchmark. A substantial group of companies already discloses on nature, while the average discloser covers 8 of the 14 TNFD recommendations, which leaves room for companies that build complete and comparable disclosures to stand out with investors.

What Should Executives Do Before February 19, 2027?

The 120-day comment period gives leadership teams time to test their readiness against the proposals. Practical priorities include reassessing nature-related materiality under IFRS S1, mapping exposed assets by location, reviewing targets, planning stakeholder engagement, aligning framework teams and deciding whether to submit a formal comment to the ISSB.

The following actions map directly to requirements or design choices in the Exposure Draft:

1. Reassess materiality. IFRS S1 already requires disclosure of material nature-related risks and opportunities, so confirm whether dependencies such as water, transport routes or pollination are material to your prospects.
   
2. Map exposed assets and activities by location. The draft proposes disclosing the amount and percentage of assets or business activities vulnerable to nature-related risks, and requires companies to consider the locations of assets and activities throughout the value chain.
   
3. Review nature-related targets. Check that each target states what it relates to, its location-specific aspects and objectives, and whether law or regulation informed it.
   
4. Plan stakeholder engagement. The draft requires companies to consider interactions, including engagement, with Indigenous Peoples, Local Communities and affected stakeholders, and to identify the groups of people their disclosures cover.
   
5. Build on existing TNFD work. Continued use of the TNFD framework is a good way to prepare, and the TNFD LEAP approach may be used, though it is not required, to identify nature-related risks and opportunities.
   
6. Involve your GRI and ESRS reporting teams early. The ISSB designed the Practice Statement so that companies applying the GRI Standards or ESRS alongside it can do so efficiently.
   
7. Decide whether to comment. The ISSB is seeking feedback on the content of the proposals and on whether to finalize the Practice Statement or issue nature-related content in another form, for example as a Standard. Comments close on February 19, 2027.

ASUENE’s recommendation goes one step further. Because the ISSB’s approach is designed to connect nature and climate information, ASUENE recommends managing nature data under the same governance and controls as Scope 1, Scope 2 and Scope 3 carbon accounting. ASUENE’s carbon accounting platform provides that climate data foundation.

Nature-Related Risk Strategy: Building Board-Level Readiness

The proposals require companies to explain how nature-related risks shape strategy and decision-making and how resilient the business model is to them. That brings nature into the strategic agenda that boards oversee, supported by investor demand and a regulatory pathway that lets jurisdictions decide whether and when to require the Practice Statement.

Disclosures on strategic response and business model resilience cannot be produced by a reporting team alone. They require leadership to show how nature-related risks and opportunities have informed decisions, and how the company plans to respond.

Investor pressure is already visible. The ISSB framed the proposal as a response to investor demand for nature information, and financial institutions committed to TNFD-aligned reporting represent more than $26 trillion in assets under management.

The regulatory trajectory remains open. Jurisdictions can decide whether and when to require use of the Practice Statement, taking into account the risk of disrupting adoption of IFRS S1 and IFRS S2. The ISSB is also consulting on whether to issue nature-related content in another form, for example as a Standard.

The ISSB has stated that companies using the TNFD framework are well positioned to apply the Practice Statement. Companies that have not yet begun nature-related assessment face a wider gap to close before any jurisdiction adopts the requirements.

Conclusion: Preparing Your Organization for ISSB Nature Disclosure

The ISSB’s Exposure Draft turns an existing IFRS S1 obligation into a specific disclosure structure covering strategy, resilience, exposed assets, location, stakeholder engagement and nature-related targets. With 836 organizations already committed to TNFD-aligned reporting and comments closing on February 19, 2027, the window to shape the final requirements is defined and short.

Chief Sustainability Officers and executive teams should use the comment period to run a nature-related materiality screen, map exposed assets and activities by location, and decide whether to respond to the consultation. ASUENE recommends integrating nature data with Scope 1, Scope 2 and Scope 3 carbon accounting so that climate and nature reporting share one governed foundation. Contact ASUENE to begin planning your nature-ready ESG data strategy.

Why Work with ASUENE Inc.?

ASUENE is a key player in carbon accounting, offering a comprehensive platform that measures, reduces, and reports emissions, including Scope 1-3. ASUENE serves over 56,000 clients worldwide, providing an all-in-one solution that integrates GHG accounting, ESG supply chain management, a Carbon Credit exchange platform, and third-party verification.

ASUENE supports companies in achieving net-zero goals through advanced technology, consulting services, and an extensive network.