TNFD Disclosure for Fashion Brands: A Practical Guide to the Four Pillars

What is TNFD and why does it matter for fashion?

The Taskforce on Nature-related Financial Disclosures (TNFD) is a global framework for organisations to report on their nature-related dependencies, impacts, risks, and opportunities. Released in final form in September 2023, it has been adopted by over 730 organisations across 56 countries including major institutional investors, banks, and corporates — and the number is growing fast.

TNFD is voluntary. But "voluntary" is doing less work than it used to. Institutional investors representing over $20 trillion in assets have signed commitments to require nature-related disclosure from portfolio companies. In the EU, CSRD ESRS E4 is mandatory and closely mirrors TNFD's structure. And the ISSB — which sets the global baseline for sustainability reporting standards — has confirmed it will integrate nature into its framework, using TNFD as a reference.

For fashion brands, the case for disclosure is unusually strong. The sector has direct, documented dependencies on nature (clean water for wet processing, stable land for fibre production) and significant impacts (deforestation, water pollution, biodiversity loss). Investors and procurement teams are increasingly asking for evidence that these risks are being managed. A TNFD-aligned disclosure is the clearest way to provide that evidence.

The LEAP approach: how to assess your nature exposure

Before you can disclose under TNFD, you need to assess your nature-related risks and opportunities. TNFD provides a structured methodology for this called LEAP: Locate, Evaluate, Assess, Prepare.

Locate. Where does your business interface with nature? For a fashion brand, this means mapping your supply chain geographically — which countries and production regions does each commodity come from? This step requires supplier location data at minimum to country level, and ideally to site level (GPS coordinates or polygons). TNFD recommends screening against the IUCN Global Ecosystem Typology — the apparel guidance names ten biomes as typical interfaces for the sector and proximity to biodiversity-sensitive areas including IUCN Protected Areas and Key Biodiversity Areas.

Evaluate. What are your dependencies on and impacts on ecosystem services? TNFD uses the ENCORE database (Exploring Natural Capital Opportunities, Risks and Exposure) to map industry sectors to their ecosystem service dependencies and impact drivers. For fashion, the primary dependencies are on water supply, land, and genetic resources; the primary impacts are on soil quality, freshwater use, water pollution, and land conversion.

Assess. Which of these dependencies and impacts translate into material risks and opportunities for your business? Risk assessment follows two lenses: physical risks (how do changes in ecosystems affect your operations — water scarcity disrupting cotton yields, for example) and transition risks (how do regulatory and market changes create liability — EUDR compliance costs, investor divestment from nature-risk sectors).

Prepare. What is your strategic response? This feeds directly into your disclosure — the targets you set, the actions you take, and the governance you put in place.

The four disclosure pillars

TNFD disclosure is structured around four pillars, mirroring the TCFD climate framework that many sustainability professionals will already be familiar with.

Pillar 1: Governance. How does your board oversee nature-related risks and opportunities? TNFD asks for the board's oversight of nature-related dependencies, impacts, risks and opportunities (Disclosure A), management's role in assessing and managing them (B), and — the one most organisations miss — your human rights policies and engagement with Indigenous Peoples, Local Communities and affected stakeholders, and how the board and management oversee them (C). Executive remuneration is not among TNFD's governance disclosures, though linking it is good practice. For most fashion brands, this means formalising what may already be happening informally — a sustainability committee with board representation, a quarterly nature risk review, and at least one nature-linked KPI in senior leadership scorecards.

Pillar 2: Strategy. What are the actual and potential impacts of nature-related risks on your business model and strategy? This pillar requires scenario analysis — considering how your business performs under different nature-related futures. For fashion, the most relevant scenarios are: a world where water stress significantly reduces cotton yields in South Asia by 2035; a world where deforestation regulation expands beyond EUDR to cover cotton and synthetic fibres; and a world where biodiversity loss triggers ecosystem service collapse in key sourcing regions. TNFD does not mandate specific scenarios but does require that you explain your methodology and time horizons.

Pillar 3: Risk and Impact Management. How do you identify, assess, and manage nature-related risks? This pillar covers your processes: how you screen new suppliers for nature risk, how you engage existing suppliers on mitigation, how you integrate nature risk into procurement decisions, and how you escalate material risks to board level. It also covers your impacts — what processes do you have for identifying where your operations and value chain cause harm to nature, and how do you manage those impacts?

Pillar 4: Metrics and Targets. What do you measure, and what are you committing to? TNFD publishes fourteen core global indicators that all disclosing organisations are encouraged to report, plus sector-specific metrics for high-impact industries. The ones most relevant to fashion are C1.0 total spatial footprint (including area in protected areas and Key Biodiversity Areas); C1.1 extent of land, freshwater and ocean-use change; C3.0 water withdrawal and consumption from water-scarce areas (m³); C3.1 quantity of high-risk natural commodities sourced (tonnes); and C5.0 state of nature — ecosystem condition and species extinction risk. Note there is no such thing as a “nature-positive standard”, and no TNFD metric measures certification against one.

The nine sector metrics for apparel, accessories and footwear

TNFD's Additional sector guidance: Apparel, Accessories & Footwear (v1.0, January 2025) sets out three core sector metrics and six additional ones. They are reported on a comply-or-explain basis — where you cannot yet produce the primary data, you explain why rather than substituting a proxy.

Core sector metrics:

• AT.C2.0 — Microfibre release (g/kg average mass loss, TMC Test Method)
• AT.C3.0 — Priority materials from recycled sources (tonnes)
• AT.C23.0 — Land deploying practices with measurable regenerative outcomes (%)

Additional sector metrics:

• AT.A1.0 — Deforestation- and conversion-free products (% of production volume)
• AT.A23.0 — Circular sourcing (tonnes and %)
• AT.A23.1 — Circularity: use phase
• AT.A23.2 — Circularity: end of functional life
• AT.23.3 — Circularity: value chain
• AT.A5.0 — Concentration of pollutants around key water basins

Certification percentages — Leather Working Group, FSC or PEFC — are useful supporting evidence for your risk assessment, but they are not TNFD sector metrics and should not be presented as though they were.

Not all of these will be reportable in your first disclosure — and TNFD does not expect perfection in year one. What it expects is a clear description of your data landscape: what you can measure now, what you are working to measure, and what is genuinely beyond your current reach.

How TNFD relates to CSRD ESRS E4 and EUDR

The three frameworks are designed to be complementary. TNFD provides the investor-facing disclosure framework. CSRD ESRS E4 mandates the same disclosure for large EU companies under a regulatory standard. EUDR creates a legal compliance obligation for specific deforestation-related commodities.

The underlying data requirements overlap significantly. Supplier geolocation, commodity risk assessment, certification coverage, and pressure severity ratings serve all three purposes. Brands that build their data infrastructure with all three frameworks in mind — rather than treating each as a separate workstream — avoid duplicating effort and produce more coherent, consistent disclosures.

One practical implication: if you are preparing a TNFD disclosure, your EUDR due diligence data (deforestation screening against GFW, proximity to WDPA protected areas) feeds directly into TNFD Pillars 3 and 4. Your CSRD double materiality assessment maps directly onto TNFD's LEAP Assess step. The work is the same work.

What a first TNFD disclosure looks like in practice

TNFD early adopters are not expected to have perfect data or complete coverage of all recommended disclosures in their first year. What reviewers — investors, analysts, NGOs — are looking for is evidence of a credible process: a genuine LEAP assessment, honest disclosure of data gaps, and a trajectory toward improved coverage.

A realistic first TNFD disclosure for a mid-size fashion brand might include: a completed LEAP assessment covering your top five commodities by volume; a governance section documenting your sustainability committee structure and board oversight; a strategy section with two or three nature risk scenarios qualitatively described; a risk management section covering your supplier screening and engagement process; and a metrics section with four to six quantitative datapoints and a clear gap log for metrics you are working to add.

That is a meaningful, credible disclosure. It is also achievable in a single reporting cycle if you have your sourcing data assembled and a structured assessment methodology in place. The brands publishing TNFD disclosures in 2027 that investors will take seriously are the ones that started the LEAP process in 2026.