Nature, Biodiversity, and TNFD: SPK CSMS1000:2026 Requirements

Quick Read

Nature-related risks are now material to corporate governance and financial performance, with TNFD's LEAP methodology providing the framework for identifying dependencies and impacts that map directly onto SPK CSMS1000:2026's IRO assessment process. ESRS E4 mandates biodiversity disclosure for CSRD-reporting companies, while the standard itself requires organisations with material nature exposures to assess actual and potential impacts across operations and value chains through five primary drivers of nature loss. Organisations can meet both TNFD and SPK CSMS1000:2026 requirements simultaneously by integrating nature-related assessment into their IRO identification and evaluation processes.

Executive Summary

Nature and biodiversity-related risks are moving from the periphery to the mainstream of sustainability management. The Taskforce on Nature-related Financial Disclosures (TNFD) published its final recommendations in September 2023. ESRS E4 (Biodiversity and Ecosystems) creates mandatory disclosure requirements for CSRD-reporting companies. Investor demand for nature-related disclosure is growing. And the scientific consensus on biodiversity loss as a systemic risk is hardening. SPK CSMS1000:2026 addresses nature through the IRO assessment framework — but for organisations with material nature-related dependencies or impacts, the standard's requirements go further than many practitioners expect.

This paper explains what the standard requires on nature and biodiversity, how TNFD's LEAP methodology connects to the IRO assessment process, what ESRS E4 requires in terms of disclosure, and how organisations with material nature-related exposures should approach implementation.

Nature is not only an environmental issue. It is a financial risk issue. Organisations that depend on ecosystem services — clean water, pollinator activity, climate regulation, soil fertility, coastal protection — are exposed to financial risk when those services degrade. TNFD makes this visible. SPK CSMS1000:2026 requires it to be managed.

1. Why Nature Belongs in the IRO Assessment

Nature-related risks and impacts are precisely the kind of issue that the SPK CSMS1000:2026 IRO assessment is designed to capture. They are actual and potential negative impacts on the natural environment (impacts on ecosystems, habitat, species, soil, water). They are financial risks (business disruption from ecosystem service degradation, regulatory transition risk from nature-related policy, reputational risk from nature-damaging practices). And they are potential financial opportunities (sustainable sourcing premiums, nature-positive business models, preferential financing from nature-aware investors).

The TNFD LEAP framework — Locate, Evaluate, Assess, Prepare — provides the methodology for identifying and assessing nature-related dependencies and impacts. It maps directly onto the IRO identification and assessment process in Clauses 6.3 and 6.4 of SPK CSMS1000:2026. Organisations implementing TNFD as part of their IRO assessment process are meeting both requirements simultaneously.

2. The TNFD LEAP Framework and SPK CSMS1000:2026

3. Nature-Related Impacts — What to Look For

Nature-related impacts arise through five primary drivers of nature loss: land use change and land degradation; freshwater use and pollution; marine and coastal resource use; climate change (which has direct biodiversity impacts); and pollution (air, water, soil). Organisations must assess their actual and potential contribution to these drivers across their own operations and value chain.

3.1 High-dependency sectors

Certain sectors have particularly significant nature-related dependencies and impacts. Agriculture and food production: direct dependency on soil health, pollinator activity, freshwater availability, and climate stability. Mining and extractives: direct land use impacts, habitat destruction, water contamination. Consumer goods with agricultural supply chains: upstream land use, deforestation, water use. Real estate and construction: habitat loss, urban heat island effects, stormwater management. Tourism and hospitality: direct dependency on natural environments and biodiversity.

For organisations in these sectors, nature-related risks and impacts will almost always be material through the IRO assessment. The importance determination (Clause 6.6) should reflect this, and the controls and risk assessment (Clause 6.7) should identify what controls exist for material nature-related risks.

3.2 Nature in the value chain

For organisations not directly operating in nature-intensive sectors, nature-related risks may be concentrated in the supply chain. Agricultural commodity supply chains carry deforestation, land conversion, and freshwater use risks. The human rights due diligence requirements of Clause 10.10 address some of these — but nature-specific assessment using TNFD's sector-specific guidance for agricultural supply chains may be needed for comprehensive coverage.

4. ESRS E4 — Biodiversity and Ecosystems

ESRS E4 requires disclosure on: the material impacts, risks, and opportunities arising from biodiversity and ecosystems; the organisation's policy on biodiversity and ecosystem protection; targets and metrics for biodiversity management; and the actions being taken to address material impacts. For organisations subject to CSRD, E4 disclosure is triggered by the double materiality assessment — if biodiversity and ecosystems is identified as a material topic (either through significant impact or significant financial risk), E4 disclosure requirements apply.

The connection to SPK CSMS1000:2026 is direct. The IRO assessment (Clauses 6.3–6.6) produces the materiality determination that triggers E4 disclosure. The CSMS objectives and actions (Section 8) produce the targets and actions disclosed under E4. The monitoring and dashboard systems (Clauses 12.1–12.2) produce the metrics disclosed under E4. An organisation with a well-implemented CSMS will find E4 disclosure largely follows from existing management system outputs.

5. Nature Targets and Metrics

Setting nature-related targets requires an understanding of the organisation's biodiversity impact and dependency baseline — which requires the LEAP assessment or equivalent. Without a baseline, targets cannot be meaningfully set or measured. Key metrics typically relevant for nature-related management include: land use footprint (hectares of natural habitat affected by operations and supply chain); freshwater withdrawal in water-stressed areas; proportion of sourcing from certified sustainable sources for key agricultural commodities; and, where relevant, species count or biodiversity index data for material sites.

The TNFD metrics framework provides sector-specific guidance on appropriate metrics for different business types. These metrics connect to the SMART goals requirement of Clause 8.2 and the energy performance indicator equivalent for nature — documented baselines, specific targets, consistent measurement methodology, and annual tracking.

Speeki Meridian™ — Auditor Expectations

For Speeki Meridian™ assessments where biodiversity and ecosystems is identified as a material topic through the IRO assessment, assessors will test: whether the nature-related IRO identification engaged TNFD or equivalent methodology; whether the significance assessment addressed the specific dimensions of nature-related impacts (ecosystem service dependencies, habitat impact drivers); whether objectives and targets for material nature-related topics are established in Section 8; and whether the supply chain sustainability programme (Clauses 10.4 and 10.10) addresses nature-related risks in high-dependency commodity categories. For organisations in high-dependency sectors, the absence of any nature-related consideration in the IRO assessment will be a Stage 1 finding — nature-related impacts are too material for these sectors to be absent from the assessment.

Implementation Guidance

Use the TNFD LEAP framework as the methodology for nature-related IRO identification and assessment. The TNFD has published sector-specific guidance for agriculture, chemicals, energy, financial services, food and beverage, forestry, mining, real estate, and other sectors — use the relevant guide as your starting point. For the location step, use the TNFD's ENCORE tool (Exploring Natural Capital Opportunities, Risks and Exposure) to map which of your business activities interface with specific ecosystem services. This tool provides publicly available data that makes the location assessment more systematic and defensible. For high-risk supply chains, engage your sector's sustainability certification scheme (FSC for forestry, RSPO for palm oil, ASC for aquaculture, Rainforest Alliance for agricultural commodities) — these schemes provide both a supply chain risk management mechanism and a nature-related performance metric that can be integrated into your CSMS objectives.

About Speeki

Speeki is an accredited certification body operating across more than 100 countries. Speeki certifies organisations against SPK CSMS1000:2026 and a range of other management system standards through the Speeki Meridian™ certification programme. Speeki is a certification body — it does not provide sustainability consulting or advisory services of any kind.

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