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You can build a defensible biodiversity baseline without pretending your company has complete ecological data. Use the TNFD LEAP process to locate interfaces with nature, evaluate dependencies and impacts, assess risks and opportunities, and prepare a response. Treat the baseline as a dated benchmark with an explicit reference condition, attach a confidence and limitations record to every important data point, and direct new measurement toward the sites and activities where uncertainty could change a decision.
That produces a working baseline for management and disclosure. It is not a universal biodiversity score or a claim that every species, ecosystem and value-chain activity has been measured.
What a biodiversity baseline is—and what it is not
TNFD defines a baseline as “the starting point or benchmark against which changes in the state of nature attributed to the business activity can be compared.” That wording appears in Guidance on the identification and assessment of nature-related issues: the LEAP approach, v1.1 (October 2023), Box 16 (TNFD LEAP v1.1 PDF). A baseline therefore has three essential properties:
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- A reference condition: the prior or desired state against which change is judged.
- A traceable evidence record: what was observed, modelled, inferred or used as a proxy, by whom, when and with what limitations.
It is not a single number that can be compared across every company. A watershed-dependent plant, an agricultural buyer and a software company with leased offices have different interfaces with nature and require different evidence. “No data” is not the same as “no impact”; it means the relevant condition or pressure has not yet been established well enough to support a particular decision.
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As of October 2026, TNFD’s assessment page identifies LEAP v2.0 as the current framework. The update expands material on state-of-nature measurement across land, freshwater and ocean realms, invasive alien species, risk and opportunity assessment, environmental crime, transition planning, landscape and seascape approaches, and interoperability with the Science Based Targets Network (current TNFD LEAP page). The specific baseline definition quoted above is from v1.1; use the current v2.0 document for technical implementation details that have changed.
Set the scope before you collect more data
Write a one-page scope statement and have the sustainability, operations, procurement, risk and finance owners approve it. The statement should answer:
- Decision: Is the baseline for TNFD disclosure, site risk management, capital allocation, target setting, permitting, lender diligence, or several of these?
- Organizational boundary: Which subsidiaries, joint ventures, leased or operated sites and financial interests are included?
- Value-chain boundary: Which upstream inputs, logistics, processing, customers and end-of-life stages can materially affect the decision?
- Geography: Which countries, watersheds, ecoregions, marine areas or site buffers are covered?
- Activities and pressures: Which land conversion, water use, pollution, resource extraction, disturbance, invasive-species pathways or other pressures are plausible?
- Time: What reporting year, season and historical period are represented, and when will the baseline be refreshed?
- Materiality rule: What threshold makes a dependency, impact, risk or opportunity significant enough to investigate?
Do not expand the boundary simply because a dataset is available. Conversely, do not exclude an important supplier or ecosystem because its data are inconvenient. Record every inclusion and exclusion, the reason, and the person who approved it.
Use LEAP as the backbone
LEAP gives the work a repeatable order. The table below translates the four phases into practical outputs; the detailed questions and sector guidance should come from the current TNFD materials and the relevant sector or biome guidance.
| LEAP phase | Questions to answer | Minimum output for an incomplete-data baseline |
|---|---|---|
| Locate | Where does the company, its value chain or its financing interface with ecosystems and ecosystem services? | A geocoded site and activity map, a value-chain screening map, and a list of locations requiring better resolution. |
| Evaluate | What does each location depend on, and what pressures could the activity place on nature? | A dependency-and-impact register linking each pressure to an ecosystem, service, species or process, with evidence quality noted. |
| Assess | Which nature-related risks and opportunities could affect strategy, cash flow, assets, liabilities, people or reputation? | A risk and opportunity register with likelihood, consequence, time horizon, affected location, assumptions and data gaps. |
| Prepare | What action, governance, targets, controls and disclosure are appropriate? | An action plan, owners, deadlines, selected metrics, limitation statements and a schedule for improving the baseline. |
If value-chain coverage is incomplete, start with the stage that has the greatest potential dependencies and impacts rather than averaging weak evidence across every stage. TNFD’s risk-register guidance explicitly supports assessing risks as far as possible when data are lacking or assumptions are significant (TNFD nature-related risk and opportunity registers).
Locate interfaces with nature
Map owned, operated and financed locations
Begin with a master location file containing the address, latitude and longitude, ownership or control status, activity, operating dates, water sources and receiving waters. Add extraction points, discharge points, storage areas, transport corridors and restoration or offset areas where they could change the nature interface. A site that appears to be in an urban industrial zone may still depend on a shared aquifer or affect a downstream wetland.
Screen the value chain without creating false precision
For suppliers, start with known production countries, commodities, processing steps and spend or volume categories. If supplier coordinates are unavailable, retain the geography at the coarsest level actually supported and label it as a screening layer. Do not present a country-level ecosystem overlay as evidence about an individual farm or mine.
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Identify likely high-sensitivity places
Flag locations near protected areas, key biodiversity areas, intact or threatened ecosystems, water-stressed basins, species ranges, migration routes, wetlands, reefs and other sensitive contexts using appropriately documented external layers. These flags prioritize investigation; they do not prove that the company caused a biodiversity impact. Record the layer’s publication date, spatial resolution, geographic coverage, licensing and update schedule.
Build a source register that preserves uncertainty
Create one row per dataset, survey, permit, supplier record or model output. TNFD’s recommendations for upgrading the nature-data value chain emphasize discoverability, quality, metadata, licensing, accessibility and measurement comparability (TNFD nature-data recommendations, version 1.0, November 2025). The following fields are a practical implementation, not a mandatory TNFD form.
| Field | What to record |
|---|---|
| Owner and custodian | Business owner, external provider, repository and contact responsible for updates. |
| Collection and reference period | Survey dates, reporting year, season, model run date and the period the observation represents. |
| Spatial coverage and resolution | Site, parcel, watershed, country, grid size or marine area; include positional accuracy where known. |
| Scope | Ecosystem types, ecosystem services, taxonomic groups, pressures, dependencies and activities covered. |
| Method and provenance | Field observation, remote sensing, administrative record, model, proxy or expert inference; document methods and transformations. |
| Observed versus estimated | Separate measurements from modelled or extrapolated values. Keep the original value and any adjustment. |
| Access and licence | Public, restricted, commercial, permitted users, reuse conditions and expiry or version terms. |
| Assumptions and limitations | Missing seasons, detection limits, unverified supplier statements, boundary mismatches, taxonomic gaps and known biases. |
| Confidence and decision use | State what the evidence can support: screening, prioritization, site action, quantitative target, or disclosure only. |
Use plain evidence labels such as direct, modelled, proxy and inferred. These labels are an internal evidence convention, not a prescribed TNFD taxonomy. A coarse model may be fit for locating priority watersheds but unfit for claiming a site-level species trend.
Separate company-pressure data from nature-state data
Company records usually describe pressures or responses: water abstraction, emissions, land area, chemical use, restoration, incidents and controls. External or field data describe the condition of ecosystems and species. Keep both, and link them through a location and time key. A discharge volume without receiving-water condition cannot establish ecological change; a species observation without activity and pressure data cannot attribute change to the company.
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TNFD’s v1.1 guidance says a reference condition may be a previous state or a desired state. For a species, it may use a target population or habitat size as a proxy; the appropriate choice depends on the business and environmental context (LEAP v1.1, Box 16).
Write the choice in one sentence for every material measure:
“For [location and ecosystem], the 2026 baseline compares [measure] during [period] with [prior observed condition, desired condition or proxy], because [decision and ecological rationale].”
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A historical condition may be unsuitable where land use, climate or hydrology has changed irreversibly. A desired condition may be more useful for restoration, but it must be defined well enough to test progress. “Pristine nature” is not automatically the correct comparator. Explain whether the reference is a legal requirement, an ecological target, a management objective or a practical proxy.
Select metrics that match the material question
TNFD’s metrics architecture distinguishes core global disclosure metrics, sector metrics, additional metrics and assessment metrics used internally (TNFD metrics guidance). Select only measures that answer a defined dependency, impact, risk or opportunity question and state the boundary and denominator.
State of ecosystems
TNFD encourages reporting ecosystem condition by ecosystem type and business activity. Possible measures include condition dimensions relevant to the ecosystem—such as extent, structure, composition, hydrology or connectivity—but no single indicator captures every dimension. Measurement consensus is still developing, so explain the selected dimensions, method and limitations rather than implying that one index represents “biodiversity.”
Species and extinction risk
Species extinction risk can serve as a placeholder indicator where a more complete state-of-nature measure is not yet feasible. Record the taxonomic source, assessment date, geographic applicability and whether the company’s activity is linked to the species. A species listed as at risk in a broad range map is a prioritization signal, not proof of a local population decline.
Ecosystem services and pressures
Choose service-specific measures for the location: for example, dependable water flow for a water-dependent operation or pollination capacity for a crop supply chain. Pair them with pressure measures such as land conversion, abstraction, nutrient load, toxic release, disturbance or invasive-species introduction. Define units, spatial boundary, frequency and acceptable data quality.
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Prioritize missing information by decision value
Do not rank gaps by how easy they are to fill. Rank them by the chance that better evidence would change a material decision, combined with ecological sensitivity and the feasibility of improvement.
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| Priority question | High-priority signal | Typical next action |
|---|---|---|
| Could the gap change a material risk or impact conclusion? | The current proxy could move a site from low to high concern, alter a financing decision or change a mitigation requirement. | Commission a targeted survey, obtain supplier coordinates, validate the model or run a sensitivity analysis. |
| Is the location ecologically sensitive? | Protected or threatened ecosystem, scarce water, important habitat, high endemism or known cumulative pressure. | Improve spatial resolution and consult qualified local ecological expertise. |
| Is the evidence decision-useful at the current resolution? | A country or watershed average is being used to make a parcel or discharge decision. | Replace or supplement the layer with site-level observations or a defensible downscaling method. |
| Can the gap be reduced proportionately? | The information is accessible through permits, suppliers, monitoring or a repeatable survey. | Assign an owner, budget, method and completion date. |
| Would improved data be comparable over time? | The proposed method has a clear protocol, metadata and repeat frequency. | Lock the protocol and preserve raw data before collecting a new baseline. |
Maintain a gap log
For each unresolved question, record:
- the exact ecological or business question the evidence must answer;
- affected sites, suppliers, activities and reporting boundaries;
- the current proxy or assumption and its evidence label;
- uncertainty, potential consequence and any sensitivity range;
- the action needed to improve evidence, including method and access requirements;
- the accountable owner, budget, target date and review trigger; and
- the interim control or decision rule while the gap remains.
This log is a practical control derived from TNFD’s data and risk-register principles, not an official required template. Keep material assumptions in the risk register so a reviewer can see how conclusions were reached despite incomplete data.
Assess risks and opportunities without overstating certainty
For each priority interface, connect the chain: driver or pressure → change in nature → dependency or impact → business risk or opportunity → response. For example, a water-intensive activity may depend on reliable seasonal flow; abstraction during a low-flow period can increase ecological and operational risk. If flow and ecosystem condition are not measured, record the plausible pathway, the assumption and the consequence of being wrong. Do not assign a false numerical confidence merely to complete a spreadsheet.
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Assess physical, transition, liability and systemic dimensions where relevant. Include time horizons, severity, likelihood, reversibility, cumulative effects and who may be affected. A lack of confirmation should lower confidence in the conclusion, not automatically lower the underlying risk. Where data are insufficient to quantify likelihood, use a qualitative category with a written rationale and a plan to improve it.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Report data gaps under “comply or explain”
TNFD’s metrics guidance uses a “comply or explain” approach for core disclosure metrics. It states that not all organisations are expected to report all core metrics immediately and that an organisation should explain when a relevant and material metric cannot be measured because of methodology, data access or commercial-sensitivity constraints, including how it plans to address the limitation in future reporting (TNFD metrics guidance).
A useful limitation statement contains five parts:
- Metric and boundary: identify what was intended to be measured and which activities or locations are missing.
- Reason: distinguish method, access, licensing, commercial sensitivity, coverage or quality constraints.
- Current treatment: state whether you used a proxy, model, qualitative assessment or no estimate.
- Effect on interpretation: explain what decision or comparison the limitation prevents.
- Improvement plan: name the action, owner, target period and trigger for revising the baseline.
Never convert an unavailable measurement into zero impact, zero dependency or zero risk. If a metric is not yet measurable, say so and preserve the uncertainty in the register.
Compare evidence options before commissioning work
When choosing between a supplier declaration, public dataset, remote-sensing layer, model, field survey or specialist study, compare the options on the same axes:
| Axis | Questions to ask |
|---|---|
| Spatial suitability | Can it support the site, watershed, landscape or seascape decision, or only broad screening? |
| Coverage | Which geographies, ecosystems, taxa, pressures and activities are represented or omitted? |
| Time | What period and season does it represent, how often is it updated, and can it show annual change? |
| Observation type | Is it field-observed, remotely sensed, modelled, proxy-based or inferred? |
| Transparency | Are methods, uncertainty, calibration, version and provenance documented? |
| Access and licence | Can the company reuse, publish, combine and retain the data for the intended purpose? |
| Business fit | Does it match the activity, material issue, sector guidance and reporting boundary? |
| Proportionality | Is the cost and effort justified by the decision and ecological sensitivity? |
A field survey is not automatically superior: it may cover a small area or one season. A model is not automatically weak: it may provide consistent regional screening. The defensible choice is the one whose resolution, uncertainty and licence match the decision.
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Illustrative example: a manufacturer with incomplete supplier data
Imagine a manufacturer with two operating plants, a water-intensive process and suppliers identified only by country for one raw material. Its first baseline can still be useful:
- Locate: geocode the plants, intake and discharge points; map receiving waters; screen the supplier countries for likely production regions and sensitive ecosystems.
- Evaluate: link abstraction and discharge records to water-flow and water-quality dependencies; identify land-use and habitat pressures associated with the raw material, while labelling the supplier layer as country-level screening.
- Assess: place the plants in the risk register with the observed operating data, the external ecosystem layers, assumptions about supplier geography and a qualitative consequence if low-flow conditions worsen.
- Prepare: set immediate controls for abstraction and discharge, request production coordinates and practices from priority suppliers, commission targeted ecological work at the most sensitive plant, and disclose which metrics remain unavailable.
The result is a dated, decision-useful baseline with a visible improvement path. It does not claim that every supplier field or species has been measured.
Version, governance and refresh controls
Put the baseline under change control. Record the framework version, metric definitions, spatial layers, model versions, survey protocols, licences, approvals and calculation files. Preserve raw inputs so a future analyst can reproduce the result.
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Set a refresh trigger for new operations, acquisitions, major land-use or process changes, a material incident, a new ecological assessment, a changed metric definition or expiry of a critical dataset. An annual refresh is a useful operating practice where feasible because metrics should be sensitive enough to reflect change, but the reviewed TNFD materials do not establish one universal legal refresh interval. State the actual period represented by each measure and the event that would cause recalculation.
Review the baseline with local ecological and Indigenous or local-community knowledge holders where appropriate, subject to consent, data-governance and confidentiality requirements. Keep commercial restrictions from becoming a blanket excuse: explain what cannot be disclosed publicly while retaining enough internal evidence for oversight and assurance.
A minimum publication-ready baseline package
Before using the baseline in a board paper, financing process or public report, check that the package contains:
- scope, boundary, reporting period and framework version;
- maps of owned, operated, financed and priority value-chain interfaces;
- a source register with provenance, resolution, methods, access and limitations;
- the reference condition and rationale for every material measure;
- dependency, impact, risk and opportunity registers;
- metric definitions, units, denominators and calculation files;
- a gap log with owners, dates, interim controls and decision consequences;
- uncertainty and limitation statements that do not imply zero impact;
- the action, monitoring and improvement plan; and
- recalculation triggers and a retained audit trail.
This package lets a reader distinguish what the company knows, what it estimates, what remains unknown and what will happen next. That distinction is the foundation of a credible biodiversity baseline when company data are incomplete.
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