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TNFD Sensitive Locations: Protected Areas, Ecosystem Integrity, Water Risk and Services

How to apply five non-exclusive criteria, choose the right ecological scale and retain an evidence trail without inventing a universal buffer rule

Who this is for A 9-minute read for reporting teams working through Sensitive locations, priority locations and location data, and for reviewers testing whether the evidence behind it holds.

Published passport

Current as at 10 August 2026
RK Reviewed by Dr Ross KurinkoLinkedIn Strategic ESG Advisor · IFRS S1 & S2 / GRI / ESRS expert GRI Certified Global Trainer · PhD, University of Cambridge · ESG-AI expert 15+ years on FTSE 100 & Fortune Global 500 disclosures Canary Wharf, London LRA educational guidance · Not issued or endorsed by TNFD

Edition written against

TNFD Recommendations v1.0 are voluntary recommendations. LEAP and other TNFD publications provide implementation guidance. Dynamic datasets …

Published

10 Aug 2026

Knowledge Hub guide

Last reviewed

10 Aug 2026

Short answer

The answer, before the reasoning

A TNFD sensitive-location assessment should test five non-exclusive criteria: biodiversity importance; high ecosystem integrity; rapid decline in ecosystem integrity; high physical water risk; and importance for ecosystem-service provision. A protected-area overlap is therefore one signal, not the whole test.

The appropriate geography may be a point, polygon, buffer, ecological corridor, river basin or service area, depending on the causal pathway. TNFD does not prescribe a universal one-, five- or ten-kilometre rule. Each flag should retain the dataset, version, spatial scale, threshold, date, confidence, limitations and reviewer judgement that support it. Screening identifies where deeper Evaluate work is needed. It is not, by itself, a final conclusion that a location is material or a TNFD priority location.

Educational practitioner guidance. Not legal, scientific-validation or assurance advice. Apply TNFD to the organisation's facts, stated materiality approach, ecological context and reporting basis.

Quick orientation

Quick orientation

Applies to
Direct operations and upstream or downstream interfaces being screened through Locate, including known, approximate and proxy locations.
Primary decision
Does this location meet one or more sensitive-location criteria, and what ecological scale should be used for deeper assessment?
Key TNFD anchors
General requirement on location, LEAP Locate L3-L4, Strategy D priority locations and related value-chain guidance.
Core outputs
Sensitive-location register, controlled map layers, evidence record, data-quality grade and escalation/improvement actions.
Common confusion
A protected area, a sensitive location, a material location and a priority location are related but not interchangeable concepts.

1. Why sensitive-location screening is more than a protected-area overlay

Nature-related dependencies, impacts, risks and opportunities vary by ecosystem and geography. A factory may sit outside a protected-area polygon yet depend on water from a stressed catchment, interrupt a migratory route, affect a coastal nursery area or rely on flood protection delivered beyond the legal site boundary. Conversely, an administrative overlap with a large protected landscape does not by itself establish the organisation’s actual interface, pressure or materiality.

The practical task is to connect an activity and potential pathway to the environmental asset, ecosystem service or ecological receptor that matters. A map layer is an input to judgement, not a substitute for the pathway or the review.

Rule

REQUIREMENT AND PRACTICE

<p>TNFD identifies five non-exclusive sensitive-location criteria. The choice of datasets, buffers, spatial resolution, thresholds and review workflow is implementation practice tailored to the biome, pathway and decision.</p>

In practice

2. Keep four location concepts separate

Concept Working meaning What it does not prove
Assessment location A location selected for further Locate/Evaluate work because an interface with nature may be relevant. That a disclosure or materiality threshold has been met.
Sensitive location A location meeting one or more of the five TNFD sensitivity criteria. That the organisation has a material dependency, impact, risk or opportunity there.
Material location A location associated with information material under the organisation’s stated approach. That it is sensitive under every ecological criterion.
Priority location A location prioritised because it is sensitive and/or linked to material nature-related issues. That TNFD prescribes one universal prioritisation formula.

3. The five non-exclusive sensitive-location criteria

The five criteria should be tested with controlled evidence layers. A screening flag identifies where verification or deeper assessment is needed; it is not a final materiality conclusion.

3.1 Areas important for biodiversity

This criterion can include protected or conserved areas, Key Biodiversity Areas, critical or threatened habitats, breeding or feeding grounds, migratory routes and locations significant for threatened or range-restricted species. Record the designation or ecological feature, source, geometry date, relevant species or habitat and why it matters to the activity.

3.2 Areas of high ecosystem integrity

High-integrity ecosystems may be relatively intact, rare or functionally important even when they are not legally protected. Screening can use habitat intactness, fragmentation, connectivity, hydrology or ecological-function indicators, but the metric and scale must be explained.

3.3 Areas of rapid decline in ecosystem integrity

Rapid decline is a trend signal. It requires a time series or defensible comparison period. A single current map cannot establish decline. Record observation dates, classification changes, data comparability and uncertainty.

3.4 Areas of high physical water risk

Physical water risk should normally be assessed at a hydrologically meaningful scale, such as a catchment or river basin. Scarcity, drought, flood, water quality and seasonal variability can produce different results. A global score is screening evidence, not a replacement for local withdrawal, discharge, storage, flood or water-quality evidence.

3.5 Areas important for ecosystem-service provision

A service area may extend beyond the asset boundary. Wetlands can regulate floods downstream, mangroves can reduce wave energy, pollinator habitat can support production across a landscape, and places may have cultural or livelihood importance. Identify who benefits, where the service is produced and received, and whether access or rights are affected.

In practice

4. Protected areas are essential evidence, not a universal answer

Question Control test Evidence to retain
Is the asset inside or adjacent to a protected area? Run a spatial intersection and proximity test using the best available geometry. Dataset/version, designation, geometry date, query and map output.
Does the designation cover the relevant feature? Read designation purpose, zoning and management information where available. Authority source and reviewer note.
Can the activity affect the feature without overlap? Trace water, pollution, noise, light, transport or species-movement pathways. Pathway memo, receptor evidence and selected scale.
Does overlap establish materiality? No. Evaluate the pathway and apply the stated materiality approach. Evaluate record and materiality decision.

Myth

“If the site is outside a protected area, it is not a sensitive location.”

Reality

Sensitive locations also include areas of biodiversity importance outside formal designations, high integrity, rapid decline, high physical water risk and ecosystem-service importance. Pathways cross administrative boundaries.

5. Buffers, corridors, basins and service areas

Spatial scale should follow the ecological pathway. Points, buffers, corridors, basins and service areas answer different questions; no fixed distance is suitable for every activity or receptor.

A fixed distance can be useful as a first operational screen, but it is not a universal ecological rule. One kilometre may be excessive for a contained indoor activity and wholly inadequate for river discharge, groundwater drawdown, a flyway or coastal sediment movement. Treat the buffer as a documented assumption and escalate when pathway evidence requires another scale.

Migratory species require time as well as space

Breeding, feeding, stopover, wintering and movement areas can be used in different seasons. Record species or assemblage, habitat function, relevant route, season and activity timing. An annual-average map can conceal a short but critical interaction.

In practice

Spatial unit Useful when Caution
Point or site polygon Testing direct overlap, footprint or facility exposure. Confirm CRS, geometry source and date.
Buffer or zone Noise, light, dust, disturbance or edge effects extend beyond the site. Distance needs a pathway and receptor basis.
Corridor or route Species movement, pipelines, transmission lines, roads or mobile assets matter. Seasonality and connectivity can matter more than straight-line distance.
River basin/catchment Withdrawal, discharge, flood or water-quality pathways are relevant. Select an appropriate hydrological level.
Service area An ecosystem provides a benefit across a receiving area. Map provider, beneficiaries, flow and access.

6. Practical workflow

1. Define the assessment object. Assign a stable location ID and link it to asset, activity, commodity or value-chain stage.

2. Set the best available geometry. Use a point, polygon, route, basin or proxy and record precision and confidence.

3. Select ecological scales. Determine whether footprint, buffer, corridor, catchment or service area is needed.

4. Test all five criteria. Record each as met, not met, uncertain or not yet assessed.

5. Record datasets and thresholds. Capture source, version, date, resolution, indicator, threshold and licence.

6. Review false positives and negatives. Check geometry, date, edge cases and biome suitability.

7. Add local and rights-holder evidence. Use site teams, specialists and engagement where appropriate.

8. Grade confidence. Separate verified, declared, modelled, proxy and unknown evidence.

9. Escalate. Pass relevant locations to Evaluate and retain separate materiality and priority decisions.

10. Set update triggers. Review after asset/supplier changes, ecological events, new datasets or annually.

In practice

7. Evidence controls

Control field Minimum record Review question
Location identity Stable ID, activity/value-chain link, geometry type and precision. Can the reviewer reproduce what was screened?
Dataset control Publisher, title, version/date, resolution, licence and extraction date. Was a current and suitable layer used?
Spatial method CRS, intersection/proximity rule, buffer or basin selection and query. Does the method match the pathway?
Criterion result Met/not met/uncertain, indicator, threshold and rationale for each criterion. Was every criterion considered?
Local verification Site evidence, specialist input, stakeholder or rights-holder information. Does global screening conflict with local evidence?
Confidence/limitation Verified/declared/modelled/proxy/unknown plus uncertainty. Could the result be mistaken for surveyed fact?
Approval/action Reviewer, date, escalation, improvement action and trigger. Has the flag led to a controlled next step?

Rule

EVIDENCE CONTROL

<p>Keep the raw query, input data, GIS project or script, result table and reviewer decision together. A screenshot without the query, layer version or location geometry is weak evidence.</p>

8. Hypothetical example: food processor near a wetland

A weak assessment closes the case because the site is outside the protected-area polygon. A stronger assessment uses the site polygon for footprint, the tributary and catchment for water pathways, the wetland and beneficiary area for flood regulation, and the seasonal route for migratory species. It records global screening as secondary evidence, adds local hydrology and seasonal ecology, and sends the location to Evaluate without predetermining materiality.

Hypothetical scenario

ILLUSTRATIVE SCENARIO

<p>A food processor is 3.8 kilometres from a wetland boundary. Global screening shows moderate water stress, local catchment data show seasonal low flows, the site discharges to a connected tributary and the wetland provides flood regulation. A migratory bird route crosses the catchment in part of the year.</p>

Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.

In practice

Weak wording Stronger illustrative wording
The site is not in a protected area and therefore has no sensitive-location exposure. The site does not overlap the mapped protected-area boundary. It remains an assessment location because its catchment has seasonal low-flow risk, its discharge reaches a tributary connected to the wetland and the wetland provides flood-regulation services. The screening is based on the datasets and dates in the location register and will be verified through site and catchment evidence.

In practice

9. Common mistakes

Mistake Why it fails Correction
Screening only protected areas It omits the other four criteria and external pathways. Test all five criteria.
One 5 km buffer everywhere Pressures and receptors operate at different scales. Use pathway-based scale; keep default buffer provisional.
Country water risk as site fact Country averages conceal basin and seasonal conditions. Use catchment evidence and record scale/date.
Ignoring migratory seasonality A static map can miss critical periods. Record route, habitat function, season and activity timing.
Every sensitive site is a priority site Sensitivity is an input, not the whole prioritisation decision. Apply materiality and priority criteria separately.
Exact coordinates always published Security, privacy, rights or ecological sensitivity may matter. Retain precise internal data and approve aggregation case by case.
Unknown supplier origins removed Value-chain exposure is understated. Keep unknown/proxy categories and traceability actions.

Readiness

10. Readiness checklist

  • Every location has a stable ID linked to an activity or value-chain stage.
  • Sensitive, material and priority locations are separately defined.
  • All five criteria are considered with documented datasets and thresholds.
  • High integrity and rapid decline are treated as different signals.
  • Water risk is assessed at a suitable basin or catchment scale.
  • Protected-area overlaps are checked for purpose, geometry and zoning where available.
  • Migratory evidence includes route or habitat function and relevant season.
  • Buffers have a documented pathway and receptor rationale.
  • Value-chain locations distinguish verified, declared, proxy and unknown origins.
  • Confidence, confidentiality and reassessment triggers are recorded.
  • Screening passes to Evaluate without being mislabelled as final materiality.
  • 1. Why may a site outside every protected area still be sensitive?
  • 2. Can a reviewer reproduce the spatial query and scale decision?
  • 3. Is the sensitive-location finding separate from materiality and priority-location decisions?

Take it with you

The checklists as a working spreadsheet

Every checklist and table on this page, with empty status, owner and evidence columns for your team to fill in and keep.

Download .xlsx

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