GRI Biodiversity Reporting

How GRI 304, TNFD, and ESRS E4 relate

Biodiversity has three major disclosure frameworks as of 2026 — and understanding how they relate prevents duplication and identifies genuine gaps.

GRI 304 (2016): The foundational voluntary standard. Covers site identification in protected areas (304-1), significant impacts (304-2), habitat protected or restored (304-3), and IUCN Red List species (304-4). Qualitative and relatively high-level — the data requirements are modest compared to newer frameworks.

TNFD (2023): The Taskforce on Nature-related Financial Disclosures recommendations provide a four-pillar framework (Governance, Strategy, Risk & Impact Management, Metrics & Targets) applied to nature — explicitly modelled on TCFD's climate structure. The TNFD LEAP approach (Locate, Evaluate, Assess, Prepare) provides the site-level assessment methodology. TNFD is voluntary but rapidly gaining adoption momentum.

ESRS E4 (2023): The mandatory biodiversity standard under CSRD — the most comprehensive and demanding of the three. ESRS E4 was designed in parallel with TNFD and adopts the LEAP approach. It adds mandatory financial effects quantification (E4-6), explicit transition plan requirements for biodiversity (E4-1), and XBRL tagging requirements absent from GRI and TNFD.

For companies deciding which to implement: the hierarchy is clear. CSRD companies must implement ESRS E4 — GRI 304 and TNFD compliance follows naturally from E4 implementation. Non-CSRD companies should implement TNFD as the leading edge voluntary standard — GRI 304 is satisfied as a subset. GRI 304 alone is no longer sufficient for companies with material biodiversity exposure.

The TNFD LEAP approach — the common methodology

TNFD's LEAP approach is the shared methodological foundation for both TNFD voluntary disclosure and ESRS E4 mandatory disclosure — making it the single most important biodiversity assessment methodology to implement.

Locate: Where does your business interface with nature? Map all operational locations and significant value chain activities. Screen each location against biodiversity-sensitive area databases — IBAT (Integrated Biodiversity Assessment Tool), Protected Planet (WDPA), Key Biodiversity Areas database.

Evaluate: What dependencies does your business have on ecosystem services? What impacts does your business have on nature? Use the ENCORE (Exploring Natural Capital Opportunities, Risks and Exposure) tool to identify sector-level ecosystem dependencies and impacts. Assess materiality by location — where are dependencies and impacts most significant?

Assess: What risks and opportunities does nature dependency and impact create for your business? Financial risk from ecosystem service decline (water scarcity, pollinator loss, soil degradation); regulatory risk from biodiversity-related policy changes; reputational risk from biodiversity controversy; and opportunity from nature-based solutions investment.

Prepare: Develop strategy, targets, and disclosures. Set SBTN-aligned biodiversity targets. Establish governance for nature-related risks. Prepare TNFD or ESRS E4 disclosures.

Implementing LEAP satisfies: TNFD Disclosure Recommendation B (Location) and C (Impacts and Dependencies) — directly. GRI 304-1 (site identification), 304-2 (significant impacts) — through the Locate and Evaluate steps. ESRS E4-2 (policies), E4-4 (targets), E4-5 (metrics) — through the full LEAP process.

Biodiversity targets — connecting GBF to corporate disclosure

The Kunming-Montreal Global Biodiversity Framework (GBF, adopted COP15, December 2022) set the global biodiversity agenda through 2030. The headline 30x30 target — protecting 30% of the world's land and sea areas by 2030 — creates the policy context for corporate biodiversity disclosure.

SBTN (Science Based Targets for Nature): The Science Based Targets Network is developing a framework for company-level biodiversity targets aligned with GBF — the nature equivalent of SBTi for climate. SBTN target-setting involves: assess (understand your impacts and dependencies); commit (public commitment to set SBTN-aligned targets); set (develop targets aligned with GBF); disclose (report progress annually).

For GRI 304-3 (habitats protected or restored) disclosure: targets for habitat restoration align with GBF Target 2 (restore 30% of degraded ecosystems by 2030). Companies with SBTN commitments can reference their SBTN target as the scientific basis for GRI 304-3 habitat targets.

For ESRS E4-4 (biodiversity targets): SBTN target validation provides the strongest evidence for ESRS E4-4 science-alignment — analogous to SBTi validation for ESRS E1-4 climate targets. Companies with SBTN-validated nature targets can reference this validation without additional alignment documentation.

The corporate-GBF connection: CSRD companies subject to ESRS E4 are required to align their transition plan with relevant GBF targets — the biodiversity equivalent of Paris Agreement alignment for climate. Disclosing which specific GBF targets your corporate biodiversity strategy contributes to provides the link between company-level action and global biodiversity goals.

Frequently asked questions