Clients we worked with

Consultancy & Research

IFRS S2, TCFD, and TNFD: How Sustainability Disclosure Frameworks Fit Together

Share this post

Listed companies in Singapore, Hong Kong, Malaysia, and Australia are now operating under mandatory IFRS S2-aligned climate disclosure requirements. Financial institutions and asset managers face the parallel pressure from investors, regulators, and lenders reviewing climate and nature risk across their portfolios. For both groups, three frameworks keep coming up: IFRS S2, TCFD, and TNFD. The pressing questions remain consistent. Do we need to report under all three? Which one takes priority? How do they relate to each other?

While IFRS S2 climate-related disclosures and TCFD both address climate risk, TNFD specifically targets nature risk. They are not identical, but they share similar disclosure architecture and are increasingly part of the same reporting conversation. Working with a sustainability consultant to map applicable frameworks apply is often the fastest way to cut through the complexity and avoid building parallel processes that duplicate effort without adding analytical value.

Misalignment creates problems in both directions. Redundant data collection wastes resources, whereas missing material disclosures can affect access to capital. The goal is a single reporting architecture that serves multiple audiences without duplication.

From TCFD to IFRS S2

The Task Force on Climate-related Financial Disclosures was established in 2015 and became the standard reference for climate disclosure across developed economies. In July 2023, the Financial Stability Board confirmed that the TCFD’s work was complete. It disbanded in October 2023, with the IFRS Foundation taking over through the ISSB.

IFRS S2 (Climate-related Disclosures) is the direct successor. Effective for annual reporting periods beginning on or after 1 January 2024, it builds on TCFD’s four-pillar structure while adding specific data requirements, industry-based metrics, and a requirement that climate disclosures be linked to financial statements and subject to assurance.

Companies reporting under IFRS S2 meet TCFD recommendations automatically. A separate TCFD reporting track is therefore redundant unless a specific jurisdiction or lender still explicitly request it. IFRS S2 also sits alongside IFRS S1, the umbrella standard for all material sustainability risks. Most jurisdictions in the region have started with IFRS S2 and are phasing in IFRS S1 over subsequent reporting periods.

TNFD and Nature-Related Disclosures

The Taskforce on Nature-related Financial Disclosures released its final recommendations in September 2023. TNFD is not a climate framework. It uses the same four-pillar structure but focuses on biodiversity loss, water security, ecosystem degradation, land use, and deforestation.

TNFD is currently voluntary, but adoption is gathering rapid momentum. Over 733 organisations across 56 countries have committed to nature-related reporting, including asset managers overseeing USD 22.4 trillion in assets under management. The ISSB is targeting an exposure draft for nature disclosures in October 2026, with finalisation expected in 2027 to 2028. When that standard is released, nature disclosures will sit within the same mandatory framework as climate.

TNFD and IFRS S2 are complementary. For financial institutions with exposure to the agriculture, infrastructure, or resource sectors, climate risk and nature risk often sit in the same portfolio. For listed companies in energy, mining, or manufacturing, both sets of risks run through the same value chains. Integrated risk management across both frameworks is more efficient than treating them separately.

Why the Confusion? Regulatory Patchwork Across the Region

Companies operating across multiple jurisdictions face significant planning complexity, as implementation timelines differ by country. 

Singapore requires Scope 1 and 2 greenhouse gas emissions disclosure for all listed companies from FY2025, with STI constituents leading ISSB-based climate disclosures and Scope 3 applying from FY2026. Hong Kong’s IFRS S2-based requirements take effect from the 2025 reporting year in phases, beginning with Scope 1 and 2 for relevant listed issuers. Malaysia’s National Sustainability Reporting Framework uses IFRS S1 and S2 as the baseline with a phased rollout, beginning with larger Main Market listed issuers. Australia’s climate-related financial reporting rules commenced 1 January 2025, with three tranches of companies phasing in through to 2027. 

 Regarding  TNFD, the European Union has embedded nature disclosure requirements into the Corporate Sustainability Reporting Directive under ESRS E4. Companies with EU operations face mandatory nature disclosure. Elsewhere in the region, TNFD remains voluntary for now. 

 A listed company or financial institution operating across multiple jurisdictions may need to apply IFRS S2 on different timelines in each market while simultaneously preparing for TNFD if it has EU exposure or significant holdings in nature-dependent sectors. 

What Sets These Frameworks Apart 

All three frameworks share a cohesive  four-pillar structure. Their differences lie in depth, scope, and current regulatory standing. 
IFRS S2 is more data-intensive than TCFD. It requires specific industry-based metrics, Scope 3 emissions disclosure, financial statement integration, and assurance.

TNFD provides the LEAP assessment framework (Locate, Evaluate, Assess, Prepare) for identifying and measuring nature-related risks. Financial statement integration is not yet required under TNFD, though that is expected to change as the ISSB’s nature standard develops. 

 

How to Decide Which Frameworks Apply 

For listed companies, the starting point is your listing jurisdiction. If you are listed in Singapore, Hong Kong, Malaysia, or Australia, IFRS S2-aligned climate disclosures are mandatory once listing thresholds are met. The timeline varies by market and company size, but the strategic direction is consistent across all four. 

For financial institutions and asset managers, the question is not just about your own reporting obligations. Investors and lenders are increasingly assessing borrowers and investee companies against IFRS S2 and TNFD criteria. Building internal capability to evaluate climate and nature risk across your portfolio is becoming as important as meeting your own disclosure requirements. 

For companies in agriculture, forestry, mining, energy, or infrastructure, TNFD disclosures are becoming material regardless of whether they are legally required in your jurisdiction. Supply chain partners, project lenders, and institutional investors are already asking for them. A sustainability consultant with sector and jurisdictional experience can help identify where genuine exposure lies and what level of disclosure is proportionate to your risk profile. 

Build Once, Report Multiple Ways 

Because these frameworks share the same four-pillar architecture, a single reporting process can serve multiple disclosure requirements. A climate risk assessment covering physical and transition risks feeds IFRS S2 and any remaining TCFD-aligned requirements simultaneously. A nature risk assessment using the TNFD LEAP framework can be mapped to ESRS E4 for EU reporting. 

The strategy is simple: collect data once ,structure it to map across frameworks. Avoid parallel processes that consume resources without adding analytical depth. 

The regulatory direction across the region is consistent. Around 30 jurisdictions have introduced, or are taking steps to introduce, ISSB Standards into legal or regulatory frameworks. Organisations building reporting architecture around IFRS S1, S2, and TNFD now are making an investment that holds as requirements expand. Those relying on TCFD-only approaches or fragmented reporting will need significant remediation as mandatory requirements broaden. 

How ESC Can Help 

ESC works with listed companies, financial institutions, and asset managers across Asia Pacific on sustainability disclosure and climate risk advisory. We help clients identify which frameworks apply to their business and jurisdictions, design data collection processes that serve multiple reporting requirements, and build reporting capability that holds up under investor and regulatory scrutiny. 

Our regional presence across Singapore, Malaysia, Indonesia, Hong Kong, Vietnam, and the Philippines means we understand how each jurisdiction is implementing IFRS S2, where nature risk becomes financially material by sector, and what integrated reporting looks like across different business structures and portfolios. 

If your organisation is preparing for mandatory sustainability disclosure requirements or looking to strengthen existing frameworks ahead of increasing investor scrutiny, our team is available to discuss.  

Visit our Sustainability and Climate Change services page to learn more. 

Related Insights

Every client’s challenge is unique. Our purpose-fit solutions can help you overcome your EHS and Sustainability challenges.