Key takeaway
The Biodiversity module is the newest in CDP's framework, drawing on TNFD's LEAP framework and asking how your business depends on and impacts nature. For most companies, biodiversity disclosure starts low and is on a steep learning curve. The 2026 module is more comprehensive than the 2024 version. This lesson explains the LEAP framework, how to start a biodiversity disclosure even with limited data, and how to align with the broader TNFD ecosystem.
What CDP wants on biodiversity
The Biodiversity module asks across roughly four dimensions:
- Material biodiversity dependencies. What ecosystem services does your business depend on? Pollination for crops, water filtration from forests, soil health for inputs, fisheries for ingredients.
- Material biodiversity impacts. Where does your business affect nature? Habitat loss from operations, species impacts from pollution, ecosystem disruption from sourcing.
- Geographic exposure. Which of your operations or supply chains are in or near biodiversity-priority areas (Key Biodiversity Areas, IUCN-listed habitat, indigenous lands)?
- Risk and opportunity. What biodiversity-related risks does your business face, and what opportunities does it have?
The total available points are smaller than climate or water (CDP Module 11 has roughly 36 questions in the 2026 version, with around 20-30 points). The non-disclosure penalty is similarly modest.
TNFD's LEAP framework
The Taskforce on Nature-related Financial Disclosures (TNFD) released its framework in September 2023, and CDP's biodiversity questions explicitly draw on it.
LEAP stands for:
| Step | What it asks |
|---|---|
| L = Locate | Where in the value chain is your nature exposure (operations, suppliers, downstream)? |
| E = Evaluate | What are the dependencies and impacts? Use ENCORE, IUCN tools, biodiversity assessment |
| A = Assess | What are the risks and opportunities? Materiality assessment for nature |
| P = Prepare | What disclosures, targets, and actions follow? |
Companies starting biodiversity disclosure should follow LEAP as a process. The CDP questions essentially ask for outputs from each step.
Analogy
LEAP is to biodiversity what TCFD scenarios are to climate. It is a structured process for identifying and disclosing risk. Without following a framework like LEAP, biodiversity disclosure tends to be either superficial (high-level statements) or exhaustive (every species in every supplier region). LEAP provides the discipline to focus on what matters.
Locating exposure
The first step is mapping where your operations and supply chains intersect with nature.
Practical tools:
- ENCORE (Natural Capital Finance Alliance): sector-by-sector mapping of dependencies and impacts on natural capital
- IBAT (Integrated Biodiversity Assessment Tool): biodiversity priority areas overlay, including Key Biodiversity Areas (KBAs) and IUCN Red List species
- Trase + Global Forest Watch: combined commodity-driven deforestation and biodiversity overlay
- GBIF (Global Biodiversity Information Facility): species occurrence data
- National biodiversity priority maps for India: India Biodiversity Information System; National Biodiversity Action Plan
A scoring-quality "locate" disclosure:
"We have mapped our operations and Tier 1 suppliers against IBAT KBA data. 12 of our 45 operating facilities are within 5 km of a KBA. 200 of our 1,800 Tier 1 suppliers operate in KBA-adjacent areas. Highest-priority sites: 3 manufacturing plants in the Western Ghats biodiversity hotspot; 2 cement quarries in the Eastern Himalayan KBA; cotton cooperatives in 4 KBA-adjacent agricultural districts in Gujarat and Maharashtra. Mapping completed Q3 FY25 with consultancy support."
Evaluating dependencies and impacts
ENCORE provides sector-by-sector dependencies and impacts. For each industry, ENCORE lists the ecosystem services the sector depends on and the ways it impacts nature.
| Sector | Key dependencies | Key impacts |
|---|---|---|
| Food / FMCG | Pollination, soil quality, water provisioning, climate regulation | Habitat loss from agricultural conversion; water pollution from inputs; species impact from pesticides |
| Apparel | Water provisioning, soil quality, raw material biodiversity | Land conversion, water pollution from dyeing, microplastic emissions |
| Construction / Real estate | Soil stability, water provisioning, climate regulation | Habitat fragmentation from siting, embodied biodiversity impact in materials |
| Mining | Local water, geomorphological stability | Direct habitat destruction, water and soil contamination |
| Pharma | Genetic resources from biodiversity (some), water | Pollution from manufacturing, supply chain habitat impact |
| Financial services | Indirect through portfolio | Financed exposure to all the above |
The Leadership-tier disclosure names the specific ENCORE-identified dependencies and impacts most material to your business and discloses how you assess and manage them.
Assessing risk and opportunity
Once dependencies and impacts are evaluated, you move to risk and opportunity assessment, similar to the climate IRO process but applied to nature.
Common biodiversity-related risks:
- Loss of pollination services affecting agricultural inputs (relevant for food and FMCG)
- Soil degradation affecting agricultural productivity
- Water provisioning loss in basins where forest cover decline reduces watershed services
- Reputational risk from operating in biodiversity-sensitive areas
- Regulatory risk from emerging biodiversity disclosure requirements (CSRD ESRS E4, India BRSR Core, country-level)
Common opportunities:
- Nature-based solutions for emissions removal (afforestation, regenerative agriculture, blue carbon)
- Premium pricing for biodiversity-friendly products (bird-friendly coffee, regenerative cotton)
- Risk reduction through nature-positive operations that build resilience
Worked example: a starting biodiversity disclosure
Worked example
FoodCo Ltd, India (synthetic, mid-size FMCG). First biodiversity disclosure cycle.
Locate (Year 1):
- Mapped 18 manufacturing facilities and 1,200 Tier 1 suppliers using IBAT
- Identified 4 facilities within 10 km of KBAs (one cement supplier in Western Ghats; one tomato grower cluster in Maharashtra Sahyadri; one milk supplier cooperative in Karnataka Western Ghats; one wheat farm cluster in Punjab Doaba)
- Tier 2 supply chain mapping deferred to Year 2
Evaluate (Year 1):
- Used ENCORE for FMCG sector dependencies: identified pollination, soil health, water provisioning, climate regulation as key dependencies
- Identified habitat loss, water pollution, species impact from pesticides as key impacts
- Conducted high-level workshop with operations and procurement teams; documented assessment
Assess (Year 1):
- Identified 3 material biodiversity-related risks:
- Pollination decline in tomato-growing regions affecting input quality
- Soil health decline in wheat regions affecting yields
- Reputational exposure from cement supplier KBA proximity
- Identified 1 opportunity: premium pricing potential for "biodiversity-positive" branded products in metro markets
Prepare (Year 1):
- Set commitment: align with TNFD framework and progressively disclose; aim for SBTN-aligned targets by 2027
- Started supplier engagement programme with the 4 highest-priority Tier 1 suppliers on biodiversity
- Joined the India Business and Biodiversity Initiative (IBBI) for capacity building
Disclosure tier achieved Year 1: Awareness on most questions; Disclosure on the IBAT mapping question (specific data given). Total Module 11 score: roughly 8 of 25 available points.
Year 2 plan:
- Extend mapping to Tier 2 suppliers
- Conduct supplier-level biodiversity assessments at the 4 priority sites
- Quantify biodiversity impact in financial terms for at least one risk
- Set first SBTN-style target
This kind of progression from a low base is realistic. The key is following the LEAP framework, not trying to disclose at full Leadership tier in Year 1.
SBTN, the next level for ambitious companies
The Science Based Targets Network (SBTN) is the biodiversity equivalent of SBTi for climate. SBTN releases sector-specific target-setting methodologies for nature, water, biodiversity, and land use.
SBTN-validated targets are not yet widely held (the framework is newer than SBTi), but companies that are submitting targets (typically FMCG, food, FS) gain Leadership-tier credibility. The first wave of SBTN target-setters in 2024-2026 are pioneers; CDP rewards them appropriately.
For most respondents, an SBTN target is a 2027-2028 ambition. The current ambition floor is to start the LEAP process and disclose what you find.
The EU's Corporate Sustainability Reporting Directive includes ESRS E4 (Biodiversity and Ecosystems) as a mandatory disclosure for in-scope companies. ESRS E4 covers many of the same elements as CDP Biodiversity (impacts, dependencies, risks, opportunities, transition plans). Companies subject to CSRD will be reporting much of this anyway. The CDP disclosure becomes a condensed version of the CSRD disclosure. For Indian companies with EU operations or major EU customers, this has practical implications: building the biodiversity disclosure infrastructure for CSRD also serves CDP.
Common pitfalls
- High-level statements without specifics. "We are committed to biodiversity" is the lowest tier of disclosure.
- Skipping the Locate step. Without spatial mapping, the rest of LEAP cannot be done credibly.
- Confusing biodiversity with environmental management. ETP compliance is environmental management; biodiversity is about ecosystem services and species impact specifically.
- Treating biodiversity as a CSR project. CDP treats it as a financial risk and operational matter; framing it as philanthropy weakens the disclosure.
- Reporting on tree-planting only. Tree-planting is one type of nature-based solution, but biodiversity is broader. Pollination support, water recharge, soil restoration, and species-specific protection are all part of biodiversity work.
Key Takeaways
- The biodiversity module follows TNFD's LEAP framework: Locate, Evaluate, Assess, Prepare; this provides the disclosure structure
- Spatial mapping using IBAT, ENCORE, and Global Forest Watch is the foundation; without it, the rest of LEAP cannot be done credibly
- Most companies are starting from a low base; a credible Year 1 disclosure focuses on completing the LEAP process and naming specific dependencies and impacts
- SBTN-validated targets are the emerging Leadership-tier signal; first wave of target-setters in 2024-2026 are pioneers
- CSRD ESRS E4 in Europe overlaps with CDP biodiversity; companies subject to both can build common disclosure infrastructure
Knowledge Check
Test what you just learned
6 questions · check each one as you go
What does TNFD's LEAP framework stand for?
Which tool maps biodiversity priority areas including Key Biodiversity Areas?
True or false: A high-level commitment to 'support biodiversity' is sufficient for Management-tier scoring.
What is SBTN?
Which dependencies are typical for an FMCG / Food company?
Select all that apply
Match each LEAP step to its purpose.
Match each item to its pair
L = Locate
E = Evaluate
A = Assess
P = Prepare