TNFD vs GRI 101 Biodiversity: How Nature Disclosure Compares

TNFD and GRI 101 ask nature questions differently, but they screen the same locations.

If your team is preparing nature disclosure, you are probably looking at two frameworks at once. The Taskforce on Nature-related Financial Disclosures (TNFD) is the voluntary framework that treats nature as a risk-management problem: what a company depends on in nature, what it affects, and what that means for the business. GRI 101: Biodiversity 2024 is the reporting standard from the Global Reporting Initiative that many companies already file; it asks a company to report its impacts on nature. GRI 101 is effective for reports published on or after 1 January 2026, so this is a live question for the current reporting cycle, not a future one.

The two frameworks start from different places. That difference is real and it changes what you have to report. But underneath it, they ask the same location question, using almost the same words. So one location screen can produce evidence for both. This piece walks the divergence, then the convergence, then what a reporter actually does with the overlap.

The materiality lenses differ, and that changes what you report

“Materiality” is the test a framework uses to decide what is worth reporting. The two frameworks apply different tests.

GRI 101 is an impact standard. In GRI’s own words, its topic standards are used “to report information about [an organization’s] impacts in relation to particular topics”. In plain terms: GRI asks what the company does to nature. The direction of the question runs from the company outward.

TNFD runs the other way as its baseline. TNFD asks report preparers to “provide information consistent with meeting the material information needs of capital providers as a baseline, consistent with the ISSB and the TCFD”. In plain terms: TNFD’s default test is financial. It asks how nature affects the business and its financial position, the same baseline the climate frameworks use.

This is where a common shorthand goes wrong. TNFD is often described as a “double materiality” framework, meaning it weighs impact and financial materiality equally. The text does not say that. Impact reporting in TNFD is optional and additional: preparers provide it “should they need or choose to do so,” and when they do, TNFD points them to “the impact materiality approach of GRI”. In other words, TNFD itself names GRI as the place to go for the impact lens. The two frameworks are designed to sit next to each other, not to duplicate each other.

There is one more distinction that catches teams out. Whatever materiality test you apply, TNFD “strongly recommends, irrespective of the approach to materiality taken by the report preparer, the identification and assessment of all four types of nature-related issues: dependencies, impacts, risks and opportunities”. In plain terms: the materiality test decides what you report, but TNFD expects you to assess the full picture first regardless. Assessment scope and reporting scope are not the same thing.

GRI measures impact, TNFD measures financial risk by default: GRI 101 reports impacts on nature. TNFD reports, by default, how nature affects the business, and treats impact reporting as an add-on that routes to GRI. If someone tells you TNFD is double materiality, that is the shorthand, and the standard text is more precise.

Both frameworks ask the same location question

Here the two frameworks converge, and the convergence is almost word for word.

TNFD asks a reporter to find its sensitive locations: places where its assets or activities “interface with nature” in any of five kinds of area. GRI 101, in Disclosure 101-5, asks a reporter to report, for each of its most significant sites, “whether it is in or near an ecologically sensitive area, the distance to these areas,” and which of five kinds of area apply. Set the two lists side by side.

Three of the five rows are identical. The other two say the same thing in slightly different order. This is not a coincidence of two teams reaching for the same ideas; the two lists line up criterion for criterion. A location that is sensitive under TNFD is sensitive under GRI 101, and the evidence you gather to prove it is the same evidence.

The overlap does not stop at location. TNFD organizes pressures on nature into “five key pressures or ‘drivers of nature change'” from the IPBES scientific assessment: “land and sea use change; direct exploitation of organisms; climate change; pollution; and invasion of alien species”. (IPBES is the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services, the scientific body that defined this taxonomy.) GRI 101-6 asks a reporter to report its contribution to “the direct drivers of biodiversity loss, such as land and sea use change, exploitation of natural resources, climate change, pollution, and the introduction of invasive alien species”. Same five drivers, same source. Both frameworks also ask a reporter to locate the sites first, in hectares, with coordinates; GRI 101-5-a asks for “the location and size in hectares” of a site and, in its guidance, for “polygon outlines or maps” and “the names and coordinates of its sites”.

So the shared question is concrete: where are your sites, are they in or near these five kinds of area, how far, and which of the five drivers do your activities contribute to.

The same screening data answers both

This is the practical payoff. The five criteria are questions about a location, and location questions are answered with location data. One asset-level screen produces evidence for both frameworks.

Continuuiti’s Biodiversity and Land Use / Land Cover (LULC) analysis is built to answer exactly these location questions. TNFD’s own guidance names the reference datasets it expects a team to use for each criterion; here is how our screen maps onto them, and where it stops.

The World Database on Protected Areas (WDPA) is the global register of protected areas; RESOLVE is a dataset that divides the world into 846 ecoregions; Hansen Global Forest Change tracks annual tree-cover loss; WRI Aqueduct is the World Resources Institute’s water-stress dataset. Each analysis runs on an asset’s coordinates and returns location, hectares, and maps, which is the exact form GRI 101-5-a asks for. Because only one of the five criteria needs to be met for a location to count as sensitive under TNFD, a screen that answers four of them settles most sites quickly.

Where the shared screen stops

A location screen is a location screen. It is worth being clear about what it does not do.

Our analysis screens where a site sits and how the land around it is changing. It does not measure the condition of an ecosystem, only its extent and the site’s proximity to sensitive areas. That matters because both frameworks ask condition questions our screen does not answer: GRI 101-7 asks for “changes to the state of biodiversity,” including ecosystem condition, and TNFD defines the “state of nature” as ecosystem extent and condition plus species population size and extinction risk. We cover extent and proximity, not condition, species, or population.

The same holds for two more criteria. We do not natively provide Key Biodiversity Areas or species-level data, so the biodiversity-importance criterion is covered only at the protected-area layer. And we do not screen ecosystem-service provision to Indigenous Peoples and local communities, which needs stakeholder engagement and field assessment. GRI 101-8 and the dependency side of TNFD’s assessment also ask about ecosystem services as a dependency, which is a valuation question, not a location question. Our results are built for portfolio-level screening and site comparison, not property-level engineering conclusions.

So the practical bound: the location screen is the data spine for the Locate step and the location side of both frameworks. It is not the whole assessment, and it is strongest on the four location-and-land-cover criteria, not on ecosystem condition or dependency valuation.

What a reporter does with both

The workflow that falls out of this is simple. Run one asset-level location screen across your sites. Use the output as shared evidence for both frameworks: it answers TNFD’s sensitive-location question and GRI 101-5’s ecologically-sensitive-area question from the same data, in the same hectares-and-coordinates form. Then route each framework to its own materiality treatment. Under GRI, the sites feed the impact disclosures. Under TNFD, the same sites feed the risk assessment, where you ask how a dependency or impact at that location could affect the business.

You do the location work once. You report it twice, each time through the lens the framework asks for.

For the deeper mechanics, the TNFD framework overview covers the four pillars and where materiality actually lands, and the LEAP approach walkthrough covers the Locate and Evaluate steps in detail. For the deforestation and land-use screening behind the criteria above, see the related EUDR and land use and land cover coverage.

Frequently asked questions

What is GRI 101: Biodiversity 2024?

GRI 101: Biodiversity 2024 is the Global Reporting Initiative’s updated biodiversity reporting standard. It is an impact standard, meaning a company uses it to report its impacts on nature, and it has eight disclosures across management and topic sections covering policies, impacts, locations, drivers of loss, and ecosystem services. It is effective for reports published on or after 1 January 2026, so it applies to the current reporting cycle.

Is TNFD a double-materiality framework?

No, not as a baseline. TNFD’s default materiality test is financial, consistent with the ISSB and the TCFD. Impact materiality is optional and additional, and TNFD points to GRI’s approach when a preparer chooses to include it. What TNFD does require regardless of materiality is the assessment of dependencies, impacts, risks, and opportunities, so assessment scope is broader than reporting scope.

Does GRI 101 replace TNFD, or the other way round?

Neither. GRI 101 reports impacts on nature, while TNFD reports, by default, how nature affects the business. They are built to sit side by side, and TNFD’s own text references GRI’s impact approach as the complement. Most reporters facing both will satisfy the location parts of each from one screen.

What location data do both frameworks need?

Both ask for site locations, in hectares, and whether each site is in or near five kinds of sensitive area: biodiversity importance, high ecosystem integrity, rapid decline in integrity, high physical water risk, and ecosystem-service areas for local communities. The first four are answerable from protected-area, ecoregion, deforestation, land-cover, and water-stress data on the site’s coordinates. The fifth needs stakeholder assessment.

Are GRI standards mandatory?

GRI standards are voluntary in most jurisdictions, but they are the most widely used sustainability reporting standards globally and are increasingly referenced by regulation. GRI 101: Biodiversity 2024 takes effect for reports published on or after 1 January 2026. A company that already reports under GRI and has significant biodiversity impacts will apply GRI 101 from that date.