TNFD Disclosures for Land-Intensive Companies
TNFD explained for plantation, forestry and commodity companies in Indonesia: the LEAP approach, what to disclose, the data you need and common mistakes.
TNFD is a disclosure framework that helps companies report how they depend on and affect nature, and which financial risks and opportunities follow. For land-intensive companies in Indonesia, such as palm oil, pulp and paper, rubber, coffee, cocoa and mining, the heart of TNFD is location-specific data: where your sites and suppliers are, what ecosystems they sit in, and how those ecosystems are changing.
The Taskforce on Nature-related Financial Disclosures published its final recommendations in 2023. Its structure mirrors the climate-focused TCFD, with disclosures grouped under governance, strategy, risk and impact management, and metrics and targets. Uptake is voluntary, but investors, lenders and EU customers increasingly expect nature information alongside climate data.
The LEAP approach in practice
| Phase | Question | Land company example |
|---|---|---|
| Locate | Where do we interface with nature? | Map concessions, smallholder supply areas and mills against forests, peat, mangroves and protected areas |
| Evaluate | What do we depend on and affect? | Water for mills, pollination, soil health; land conversion, pollution, fire |
| Assess | What risks and opportunities follow? | Regulatory risk from EUDR, fire liability, water scarcity, restoration revenue |
| Prepare | How do we respond and report? | Targets, restoration plans, supplier programmes, disclosure |
Step-by-step: preparing a first TNFD disclosure
- Set scope. Decide which operations and supply chains to include. Start with owned sites and the highest-risk sourcing regions.
- Build the location layer. Use concession boundaries, plot polygons and supplier mill lists. Overlay with land cover, peat maps, protected areas and HCV/HCSA assessments.
- Identify sensitive locations. TNFD asks companies to flag sites in areas important for biodiversity, ecosystem integrity, water stress or Indigenous and community use.
- Assess dependencies and impacts. Water use, land conversion, emissions, pesticide use, fire. Use ecosystem service valuation where money values help decisions.
- Link to financial risk. Market access under the EUDR, physical risk from drought and fire, legal and reputational risk.
- Set metrics and targets. Use TNFD’s core metrics where they apply, and add sector metrics such as deforestation-free volumes and area restored.
- Disclose and improve. Publish what you have, explain gaps, and plan data improvements.
Data you will need
- Accurate boundaries for owned land and supplier plots.
- Land cover change history, including status on 31 December 2020 for EUDR overlap.
- Peat depth and drainage information for peat sites.
- Biodiversity data: HCV assessments, species surveys, and where possible acoustic or eDNA monitoring.
- Water and pollution data from operations.
- Community and customary land information.
Much of this overlaps with EUDR due diligence and carbon project data. Building it once saves cost (see one field dataset for carbon and EUDR).
Indonesia specifics
Indonesia’s sustainable finance rules from OJK already require sustainability reporting from listed companies and financial institutions; nature-specific expectations are developing. Many Indonesian plantation groups already hold RSPO or ISPO certifications and HCV assessments, which give a head start on Locate and Evaluate. Smallholder supply chains remain the biggest data gap, as for EUDR.
How TNFD links to nature markets
Companies that identify nature impacts often look at restoration, conservation and biodiversity credits as part of their response. TNFD does not require buying credits. Investments in your own landscapes, such as restoring riparian zones or protecting HCV areas, often address material risks more directly.
Sector priorities for Indonesian land companies
| Sector | Likely material issues | Useful metrics |
|---|---|---|
| Oil palm | Land conversion, peat drainage, fire, water pollution from mills | Area converted since cut-off, peat area under management, fire hotspots, HCV area maintained |
| Pulp and paper | Plantation expansion, peat, landscape connectivity | Conservation area within concessions, restoration progress |
| Coffee and cocoa sourcing | Smallholder encroachment into forest, pesticide use, pollination | Share of volume traced to mapped plots, agroforestry area |
| Rubber | Conversion of jungle rubber, supply chain opacity | Traceability coverage, area under rubber agroforestry |
| Mining | Clearing, sedimentation, biodiversity offsets | Area disturbed and rehabilitated, water quality |
Pick the metrics that match your material issues. A small set of reliable numbers is better than a long list of estimates.
Wherever possible, use the same boundaries and definitions as your EUDR due diligence, certification audits and any carbon projects in your landscapes. Investors compare these documents, and inconsistent numbers across them damage credibility more than honest gaps do.
Common mistakes
- Reporting only at company level with no site data.
- Ignoring supply-chain land, where most impact sits for traders and manufacturers.
- Treating TNFD as a biodiversity narrative rather than a risk assessment.
- Using global datasets without field checks in Indonesian landscapes.
- Presenting credit purchases as a substitute for reducing impacts.
Read more in the biodiversity hub, or talk to us about biodiversity valuation for your sites.
Frequently asked questions
What is TNFD?
The Taskforce on Nature-related Financial Disclosures is a market-led initiative that published recommendations for companies and financial institutions to assess and disclose nature-related dependencies, impacts, risks and opportunities. Its structure mirrors the climate-focused TCFD.
Is TNFD mandatory in Indonesia?
TNFD itself is voluntary. Some jurisdictions and exchanges are moving nature disclosure into rules, and buyers and investors increasingly ask for it. Check current Indonesian sustainability reporting rules from OJK for what is required of listed companies.
What is the LEAP approach?
LEAP stands for Locate, Evaluate, Assess and Prepare. It is TNFD's guidance for identifying where a company interfaces with nature, what it depends on and affects, which risks and opportunities follow, and how to respond and report.
Why does location matter so much in TNFD?
Nature impacts depend on place. Clearing a hectare near a protected area or on peat has very different consequences from the same activity on degraded land, so disclosures need site-level data.