The Six TNFD General Requirements: Materiality, Scope, Location, Integration, Time Horizons and Engagement

The 14 recommended disclosures describe what information to provide. The six general requirements shape how that information is selected, bounded, located, integrated, timed and informed by engagement. A report can contain all 14 headings and still be weak if its materiality lens is unclear, its value-chain scope is hidden, its locations are aggregated away or its engagement claim lacks evidence.

The most effective implementation method is to treat each general requirement as both a basis-of-preparation disclosure and a review test applied to governance, strategy, risk and impact management, and metrics and targets.

Figure 1. The six general requirements form a compass for every pillar, not six isolated disclosures.

The report should identify the materiality approach used. TNFD recommends the ISSB definition of material information as a baseline and allows impact materiality in addition where chosen or required. The approach should be applied consistently across the recommended disclosures.

Evidence

reporting objective and primary users;

materiality definition or definitions and source edition;

criteria, thresholds and qualitative overrides;

DIRO and impact decision registers;

governance approval and challenge; and

reconciliation of conclusions across pillars and metrics.

Common gaps

calling TNFD automatically double materiality;

using stakeholder ranking as the decision itself;

changing the materiality lens between strategy and metrics;

omitting a materiality conclusion because data are not quantified; and

describing a heatmap as a completed assessment.

The organisation should describe the scope of nature-related issues assessed and disclosed in direct operations and upstream and downstream value chains. It should explain the process used, material exclusions and how coverage will expand where the first cycle is phased.

Evidence

reporting-entity and financial-perimeter reconciliation;

asset, activity, product, portfolio and value-chain universe;

screening and detailed-assessment populations;

covered gases/nature realms, periods and business relationships;

exclusion rationale and data-quality assessment; and

dated expansion plan with owners and resources.

Common gaps

describing direct operations only while implying whole-value-chain coverage;

confusing a sector heatmap with supplier assessment;

omitting downstream products, disposal or financed activities without rationale;

failing to reconcile scope across disclosures and metrics; and

using “data unavailable” without an improvement plan.

Nature-related issues are location-specific. The same activity can have materially different dependencies and impacts depending on ecosystem condition, water basin, protected or sensitive status, cumulative pressure and affected people. The organisation should provide location information at a level of aggregation that does not obscure material differences.

Evidence

coordinates and stable location identifiers;

biome, ecosystem, basin and state-of-nature information;

protected, key biodiversity, sensitive or rights-holder context;

business activity and value-chain relationship;

priority-location criteria and approval;

geospatial source, date, resolution and uncertainty; and

links to material DIROs, metrics, targets and actions.

Common gaps

reporting a country total that hides basin or site differences;

prioritising only by spend or asset value;

treating all sensitive locations as financially material without assessment;

using coordinates without ecological context; and

failing to version geospatial datasets and boundaries.

TNFD encourages integrated reporting rather than a standalone nature silo. Nature-related disclosures should connect with climate, water, pollution, circular economy, human rights, strategy, risk and financial reporting. Integration should identify synergies and trade-offs rather than simply cross-reference another section.

Evidence

common sustainability-risk taxonomy and governance;

climate-nature and other issue crosswalks;

consistent reporting boundary, periods and definitions or explained differences;

shared data dictionary and source controls;

trade-off and unintended-consequence assessments;

financial-statement connectivity and finance review; and

tested cross-references in the final file.

Common gaps

calling data overlap full framework equivalence;

double counting climate and nature actions or benefits;

ignoring trade-offs such as land, water or community effects of a climate action;

using contradictory boundaries across report sections; and

cross-referencing content that does not answer the TNFD disclosure.

The organisation should describe the short, medium and long-term horizons used. These horizons should reflect strategy and financial planning but also the useful lives of assets, infrastructure, contracts and the different pace at which ecological change and nature-related transition can occur.

Evidence

approved definitions of short, medium and long term;

links to budgets, strategic plans, asset lives and procurement contracts;

ecological recovery, degradation or tipping-point considerations;

scenario and resilience timeframes;

target milestones and monitoring frequency; and

period-to-period consistency or explanation of changes.

Common gaps

copying climate horizons without testing nature relevance;

using “long term” without dates;

ignoring risks beyond the current planning cycle;

misaligning targets, scenarios and risk assessments; and

changing horizons without explaining comparative effects.

TNFD asks organisations to describe their processes for engagement in identifying and assessing nature-related issues. Engagement should be meaningful, culturally appropriate and connected to decisions. It is particularly important where rights, knowledge, livelihoods or access to ecosystem services may be affected.

Evidence

stakeholder and rights-holder identification methodology;

engagement plan, consent or rights considerations where relevant;

languages, formats, accessibility and participation records;

issues raised, disagreements and vulnerable-group perspectives;

how evidence affected scope, materiality, locations, actions and targets;

grievance and remedy pathways; and

board/management oversight and feedback to participants.

Common gaps

treating engagement as a one-off survey;

engaging general stakeholders but not affected rights holders;

reporting the number of meetings without outcomes;

using engagement as a substitute for impact assessment;

omitting disagreements or negative feedback; and

failing to show how engagement changed a decision.

Figure 2. A 6-by-4 review matrix turns the general requirements into a practical completeness test.

1. Create one record for each of the six requirements, including source, interpretation, owner and evidence.

2. For each of the 14 recommended disclosures, identify which general requirements affect content and data.

3. Test consistency between assessment records, report wording and metrics.

4. Record findings as materiality, boundary, location, integration, horizon or engagement gaps.

5. Assign remediation, due date, reviewer and independent retest.

6. Approve the basis-of-preparation note and alignment claim only after cross-pillar closure.

An infrastructure operator assesses direct assets and selected construction-material suppliers. It applies financial materiality for investor reporting and an additional impact lens for its broader sustainability report. The team identifies flood-regulation dependence, habitat fragmentation impacts and permitting risks at several locations.

The general requirements change the report materially: scope disclosures clarify the selected supplier categories; location data distinguish coastal and inland assets; climate and nature scenarios are integrated; long-term horizons reflect asset lives; and engagement with affected communities changes the design of two mitigation actions. The result is more than a list of DIROs - it is a traceable reporting basis.

Limitation. This is an illustrative scenario, not a prescribed TNFD outcome.

“We applied the TNFD general requirements across all four disclosure pillars. Material information was identified using the materiality approach described below. The detailed assessment covered the stated direct operations and selected upstream categories; exclusions and the expansion plan are disclosed. Location-specific information is presented where aggregation would obscure materially different natural contexts. Nature disclosures are integrated with climate and other sustainability information. Time horizons reflect strategic planning and asset lives. Engagement with affected stakeholders and rights holders informed the assessment and response decisions described in this report.”

Adaptation warning: this wording is illustrative. A real report should specify the actual materiality definition, scope, locations, horizons, engagement process and limitations.

SRC-01 · Recommendations of the Taskforce on Nature-related Financial Disclosures - TNFD (Version 1.0, September 2023). https://tnfd.global/wp-content/uploads/2023/08/Recommendations_of_the_Taskforce_on_Nature-related_Financial_Disclosures_September_2023.pdf

SRC-02 · TNFD Disclosure Recommendations webpage - TNFD (Current webpage checked 3 August 2026). https://tnfd.global/recommendations/

SRC-03 · Guidance on the identification and assessment of nature-related issues: the LEAP approach - TNFD (Version 1.1, October 2023; webpage last updated June 2026). https://tnfd.global/publication/additional-guidance-on-assessment-of-nature-related-issues-the-leap-approach/

SRC-04 · Getting started with adoption of the TNFD Recommendations - TNFD (Version 1.0, September 2023; webpage last updated July 2025). https://tnfd.global/publication/getting-started-with-adoption-of-the-tnfd-recommendations/

SRC-17 · Guidance on engagement with Indigenous Peoples, Local Communities and affected stakeholders - TNFD (Official guidance page checked 3 August 2026). https://tnfd.global/publication/guidance-on-engagement-with-indigenous-peoples-local-communities-and-affected-stakeholders/

Publication status: Source-grounded publication-ready draft - human technical sign-off pending. This article is educational material and does not replace the official TNFD, GRI or IFRS sources, legal advice or assurance procedures.