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Summary of feedback on v0.3 of the TNFD beta framework

The TNFD is adopting an open innovation approach that encourages market participants to co-create the TNFD framework by reviewing, pilot testing and providing feedback on all aspects of the beta framework. 

For v1, the Taskforce will continue to refine the framework and incorporate further feedback on all framework components from market participants received by 1 June 2023. It will also develop a set of complementary recommendations for policy makers on the enabling environment for application of the TNFD framework, including needs and gaps on data and capability building. 

Overview of feedback on v0.3

Since the release of v0.1 of the TNFD beta framework in March 2022, v0.2 in June 2022 and v0.3 in February 2023, the Taskforce has received significant feedback from a range of market participants n advance of this v0.4 release. A summary of this feedback and the Taskforce’s initial response to that feedback are provided here. There was overall positive feedback on all components of the framework and general appreciation for the material released in v0.3. 

Further feedback on versions of the TNFD beta framework is welcome throughout the open innovation process until 1 June 2023.  

The TNFD is concluding its open innovation process with a 60-day formal consultation where organisations can submit responses to this final beta version of the framework (v0.4). All feedback received will inform the complete framework, which will be published in September 2023. Comment letters received during this formal consultation will be published on the TNFD website, following the approach of international standards organisations.  

In summary:

  • The TNFD beta framework has been viewed over 90,000 times by stakeholders in over 149 countries and territories, since the release of v0.1 in March 2022.
  • Over 750 pieces of topical feedback were received on v0.3 through the TNFD online portal or sent directly to the TNFD, from more than 150 organisations or individuals. This is a 50% increase in feedback compared to that received on v0.1 and v0.2, demonstrating the growing interest in the TNFD framework among market participants. Since the v0.1 release in March 2022 the Taskforce has received [2,200] individual feedback responses through the online framework portal and in the form of written, qualitative submissions to the Taskforce Secretariat.
  • Responses were received from financial institutions and corporates from a variety of sectors, including consumer goods, industrial, utility, materials, energy and information technology, as well as public sector institutions, academic and research organisations, business associations and intergovernmental, civil society and conservation organisations.
  • 78 of the respondents provided detailed, qualitative feedback. The remaining provided quantitative feedback on the utility of different elements of the TNFD beta framework (see Figure 1 below).
  • Based on those respondents who identified their country, feedback was provided from 25 countries across Africa, Asia, Europe, Oceania and North and South America.
  • The top seven countries with the most respondents providing feedback, in order of feedback received, were the United Kingdom, United States, Japan, Australia, Brazil, Germany and the Netherlands.
Additional Content

Overall, respondents found all framework components useful, with over 80% stating they were very useful to fairly useful. Some 19% of respondents found the concepts and definitions to be not that useful, while 18% found the approach to metrics and targets to be not that useful. In response, the TNFD has continued to build out the concepts and definitions and the approach to metrics and targets in this v0.4 beta release.

Key themes of feedback

The Taskforce has reviewed all of the feedback received on v0.3 of the beta framework. Feedback was provided directly to the Taskforce on a confidential basis, so an aggregated summary is provided here.

The feedback on v0.3 follows five broad themes on the need for:

  1. Further clarity on the approach to materiality when following the TNFD disclosure recommendations;
  2. Further alignment of the TNFD framework with key standards and related initiatives;
  3. Specific guidance relevant for financial institutions;
  4. Further improvements to technical aspects of the TNFD’s definitions, disclosure recommendations and LEAP approach, including on metrics, targets and scenarios; and,
  5. A user-friendly guidance and framework structure.

Main feedback themes

The following tables provide additional information on the main feedback themes, the changes the Taskforce has made in response to this feedback in the v0.4 release, and the Taskforce’s plans leading up to the publication of the complete v1 framework in September 2023.

TNFD disclosure recommendations: Clarity on the approach to materiality

An ongoing theme in feedback to the Taskforce since publication of the v0.1 beta framework has been on the approach to materiality, with varied feedback depending on the type of organisation and jurisdiction

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Alignment with key standards and initiatives, including the Global Biodiversity Framework

Building on feedback on previous beta releases, market participants requested further details on how the TNFD framework aligns with other standards, global frameworks and related initiatives. A significant amount of feedback called for alignment with the Global Biodiversity Framework (GBF) of the Convention on Biological Diversity (CBD).

Additional Content

Guidance for financial institutions

A theme of feedback on v0.3 was a need to develop the guidance for financial institutions further, including at a portfolio level, and differentiate how it is distinct from guidance for corporates.

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Feedback on technical aspects of core components of the framework

The TNFD continued to receive feedback on technical aspects of v0.3 beta framework, such as core concept definitions, draft disclosure recommendations and the LEAP approach. The table below addresses the most significant technical feedback.

Additional Content

User-friendly guidance and framework structure

The TNFD continues to receive feedback on the usability of its framework structure and guidance and its ease of implementation and uptake. In response, the TNFD framework site will be updated with additional functionality for the v0.4 release.

Additional Content