ACCA welcomes the opportunity to provide views in response to the Taskforce on Nature-related Financial Disclosures (TNFD) discussion paper on ‘Nature Transition Plans’.
As sustainability-related standard-setting progresses, it is important to ensure that the reporting catalyses the necessary systemic change: that operational changes take place in the entities making these disclosures; better quality of information becomes available to investors, who will then use these disclosures to allocate capital more efficiently and responsibly. We thus welcome the TNFD’s approach of starting with climate transition plans and moving towards integrated planning, and believe that for this to happen, widespread application of integrated thinking by entities as well as integrative thinking by finance professionals are necessary, where information connections lead to quality decision-making and sustainable value creation.
ACCA has consistently advocated for a global approach to the development of sustainability disclosure standards which can provide a consistent and comparable global baseline to sustainability reporting around the world. Our research has also found that there is considerable room for improvement in the adoption of nature-related reporting, as well as the quality of the disclosure by early adopters of existing frameworks.
To this end, we welcome how this draft transition plan guidance builds on existing frameworks, methods and tools, such as recommendations by the Task Force on Climate-related Financial Disclosures (TCFD) and Transition Planning Taskforce (TPT) which are now the responsibility of the IFRS Foundation. However, we also recognise that net-zero climate objectives cannot be achieved without nature, and that smaller, lesser-resourced organisations (SMEs) have equally crucial roles in achieving net zero and nature transition, leading to a more sustainable future for all. With the growing amount of sustainability-related regulatory, business and reporting requirements, it is thus important for TNFD’s further work and pilot testing to involve more representative organisations from the SME sector and the Global South, alongside careful considerations on how reporting for value chain purposes is affected.
To read the response in full, please download the response document found on this page.
