The IIF has published a public comment letter on issues pertaining to nature-related transition planning, in response to the Taskforce on Nature-related Financial Disclosures (TNFD) consultation on its Discussion Paper on Nature Transition Plans, and the Glasgow Financial Alliance for Net Zero (GFANZ) consultation on its Supplemental guidance on Nature in Net-zero Transition Plans.

The IIF and its members are concerned that current proposals relating to nature-related transition planning may not be able to achieve their intended objectives. This is due to conceptual, methodological, and practical issues, including:

• The core role of financial institutions as enablers, not drivers, of economic transition, and the need for government policies which enable nature-related real economy activity to be economically viable;
• The suitability of the goals and targets of the Kunming-Montreal Global Biodiversity Framework (GBF) as a basis for private sector strategies; and
• Conceptual differences affecting the transferability of a climate-based transition planning approach to the nature sphere, and the potential feasibility—and market acceptance—of a pathway-based approach in the nature sphere.

Beyond these foundational issues, other strategic challenges affect the suitability of guidance proposed in the two consultation documents. While the initial efforts from both TNFD and GFANZ provide a helpful starting point for this discussion, and are welcomed as voluntary resources where relevant, these challenges should be considered before expectations are advanced regarding implementation.

IIF members appreciate and acknowledge the significant effort that GFANZ/TNFD have dedicated to preparing their draft guidance. However, in light of the many challenges, in particular the current lack of agreement on the feasibility of a pathway-based model of nature transition planning, we believe there is merit in 'pausing' this guidance to enable an interval period during which the foundations for transition plans could develop further, such as including national-level policies, location-specific nature data, including state of nature data, and methodologies, after which the approach could be re-evaluated.