Key point: ISSB is consulting until 19 February 2027 on a voluntary Nature Practice Statement that specifies how to apply IFRS S1 to material nature-related risks (ISSB, 6 Oct 2026). HKEX Part D remains climate-focused. Build one finance–sustainability nature-dependency register now; do not wait for a Part D nature mandate.
On 6 October 2026, live from the UN Convention on Biological Diversity (COP17), the International Sustainability Standards Board (ISSB) invited stakeholders to a webinar marking the launch of an Exposure Draft proposing an IFRS Practice Statement on nature-related disclosures (ISSB, 6 October 2026). The webinar is scheduled for 22 October 2026. The consultation is open for 120 days and ends on 19 February 2027. IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information already requires companies to disclose material information about sustainability-related risks and opportunities, including those related to nature. The Practice Statement is intended to support companies in applying that existing requirement with more specificity, drawing on the work of the Taskforce on Nature-related Financial Disclosures (TNFD).
For Hong Kong-listed issuers, the instinctive next question is whether HKEX will add a “nature” chapter to Part D of the ESG Reporting Code. That is the wrong clock. Part D is climate-related disclosure built on IFRS S2. It has not adopted a nature Practice Statement, and nothing in the ISSB’s published description requires HKEX to do so before issuers start the practical work. Material nature-related dependencies already sit under an S1-style materiality lens. Where nature and climate interconnect, some of that work also sharpens Part D strategy and risk-management narrative. The useful response is not to wait for a mandate. It is to build one shared artefact now.
Our view: The ISSB’s proposed Nature Practice Statement is voluntary guidance supporting IFRS S1 and S2, not a new Hong Kong listing rule. Waiting for HKEX Part D to grow a nature chapter misses the point. Material nature-related risks and opportunities already belong in an S1-style materiality assessment, and climate–nature links can be mapped into existing Part D strategy and risk practice without inventing a Part D nature duty. Boards should put one nature-dependency register on the table now, co-owned by finance and sustainability, and reuse it when Hong Kong Standards or HKEX later add nature specificity.
A nature-dependency register is an issuer-level inventory of how the group’s operations, supply chain and markets depend on, and affect, natural systems that could reasonably be expected to influence the group’s prospects, together with the owner of each line, the evidence base, and how that line maps into strategy, risk management and—where climate intersects—Part D climate disclosure. It is a working register, not a published report chapter.
What the ISSB has put on the table
The form matters as much as the topic. In April 2026 the ISSB agreed to propose nature-related disclosures as a Draft IFRS Practice Statement, not as a new ISSB Standard and not as amendments to IFRS S1 or IFRS S2. An IFRS Practice Statement is subject to the same public consultation due process as a Standard. Companies may apply it voluntarily; jurisdictions may mandate it. Applying the Practice Statement is not required to assert compliance with IFRS Sustainability Disclosure Standards. If a company does apply it and wishes to assert compliance with it, it must meet all of the Practice Statement’s requirements, and the effect is then equivalent to applying an ISSB Standard with that content.
The ISSB’s published explanation is clear on the architecture. IFRS S1 already requires material information on sustainability-related risks and opportunities that could reasonably be expected to affect prospects, and that already covers nature when material. The Practice Statement is designed to add specificity on how to report those nature-related risks and opportunities, while leaving S1 and S2 unchanged at this stage so that ongoing adoption is not disrupted. Staff materials for the Sustainability Standards Advisory Forum in October 2026 describe the proposals as incremental requirements used together with S1 and S2, drawing on the TNFD framework to reduce fragmentation and support proportionate implementation. They also note that entities applying the Practice Statement alongside the Standards would assert compliance with both.
At the time of writing, the ISSB’s 6 October notice and the accompanying staff and FAQ materials describe the form, the relationship to S1 and S2, the TNFD draw, and the consultation calendar. The full Exposure Draft text and Basis for Conclusions are being launched around the COP17 webinar window; where detailed proposal wording is not yet in the public domain, we do not invent it. What is already public is enough for boards to decide whether to wait.
What Part D already asks — and what it does not
Part D of the HKEX ESG Reporting Code sets climate-related disclosure requirements developed with reference to IFRS S2. For financial years commencing on or after 1 January 2026, Hang Seng Composite LargeCap Index constituents report those Climate Requirements on a mandatory basis; other Main Board issuers report on a comply-or-explain basis; every issuer discloses Scope 1 and Scope 2 emissions. FAQ Series 17.2 confirms implementation reliefs, including a financial-effects relief that allows qualitative instead of quantitative information where specified conditions are met. HKEX guidance also maps IFRS S1 conceptual foundations—materiality among them—into how issuers prepare Part D climate disclosure.
None of that is a nature chapter. Part D asks about climate-related risks and opportunities, their effects on the business model and value chain, strategy and decision-making, current and anticipated financial effects, risk management, and metrics and targets. It does not require a TNFD-style nature assessment, and it does not incorporate the ISSB Nature Practice Statement. Claiming that Part D “already mandates nature disclosure” would be false.
The practical bridge is narrower and more useful. First, under an S1-style materiality lens—which Hong Kong’s climate guidance already treats as foundational for decision-useful sustainability-related financial information—material nature-related risks and opportunities are not optional merely because Part D is silent on nature. Second, climate and nature often travel together: water stress, land use, biodiversity loss around physical assets, and transition measures that affect ecosystems can all sit inside climate physical or transition risk narratives that Part D already expects issuers to reason about. Building a nature-dependency register does not create a new Part D duty. It improves the evidence base for strategy and risk disclosures issuers are already writing, and it prepares the same evidence for the day Hong Kong Financial Reporting Standards for sustainability, or HKEX, add nature specificity.
The register: what finance owns and what sustainability owns
The failure mode we see most often is two teams producing two inventories: sustainability builds a nature or biodiversity spreadsheet for the ESG report; finance builds a separate risk register for the board and the auditor. By year-end the language has diverged, and no one can say which dependencies would actually move cash flows, access to capital, or licence to operate.
We would rather see one register with clear ownership lines.
Finance owns the link to prospects: which dependencies could reasonably affect cash flows, assets, liabilities, cost of capital or access to finance; which assumptions sit inside impairment, provisioning or going-concern discussions; and how any quantified range is consistent with the numbers that already appear in the financial statements. Sustainability owns the evidence base: which natural systems the group depends on or affects across operations and the value chain; which locations matter; which data sources and engagement trails support each line; and how the register connects to any climate scenario or physical-risk work already under way for Part D. The company secretary or disclosure committee owns the map from register lines into Part D strategy and risk wording, and into any broader sustainability narrative that rides on S1-style materiality.
The register itself need not be long. For a first cut, each line should name the dependency or impact, the business unit and geography, whether the primary channel is operations, supply or market, the climate intersection if any, the evidence owner, the last review date, and whether the line is material to prospects on the board’s current judgement. Industry-specific metrics can come later; TNFD metrics that the ISSB may permit as a source of guidance are background the ISSB itself cites, not a shopping list we invent here.
The Hong Kong and A+H angle
H-share, red-chip and A+H issuers live in more than one disclosure clock. Mainland exchange sustainability guidelines, the MOF’s Corporate Sustainability Disclosure Standards and industry guides, and Hong Kong’s Part D climate rules will not move in lockstep on nature. That is precisely why a single internal register beats three parallel narratives.
For an A+H issuer, the register should be designed so that the same dependency line can be presented under mainland sustainability reporting language and under Hong Kong Part D climate–nature interconnection language without changing the underlying judgement. For an H-share or red-chip issuer whose operations and supply chain sit mainly onshore, water, land and ecosystem dependencies that already shape physical climate risk for Part D should appear once in the register and once in the board pack, not as a separate “ESG nature project” that finance never sees. Where Hong Kong later aligns more closely with ISSB architecture beyond climate, the same register becomes the readiness file. Where it does not, the issuer has still improved the quality of the climate and materiality work it must already do.
We are not asking boards to assert voluntary compliance with a Practice Statement whose full Exposure Draft text is only now entering public consultation. We are asking them to treat the consultation window—from the 22 October webinar through 19 February 2027—as the period in which the internal artefact is built, stress-tested against real operations, and owned.
Key dates
6 October 2026: ISSB COP17 notice announcing the nature-related disclosures consultation and webinar. 22 October 2026: ISSB webinar (16:00 CEST / 18:00 AMT) marking launch of the Exposure Draft proposing a Practice Statement on nature-related disclosures. 19 February 2027: end of the 120-day consultation. FY2026 onwards: HKEX Part D Climate Requirements in force on the timetable above for HSCLI constituents and other Main Board issuers. Part D remains climate-focused; no HKEX nature chapter has been adopted as of this writing.
Sources for dates above: ISSB COP17 notice, 6 October 2026; HKEX ESG Reporting Code Part D and FAQ Series 17.2 (April 2026).
FAQs
- What did the ISSB announce in connection with COP17 in October 2026?On 6 October 2026 the ISSB invited stakeholders to a webinar on 22 October 2026 marking the launch of an Exposure Draft proposing an IFRS Practice Statement on nature-related disclosures. The consultation runs for 120 days and ends on 19 February 2027. IFRS S1 already requires material information about sustainability-related risks and opportunities, including nature-related ones when material.
- Is the proposed Nature Practice Statement a new ISSB Standard?No. The ISSB is proposing it as an IFRS Practice Statement, not as a new Standard and not as amendments to IFRS S1 or S2. It can be applied voluntarily or mandated by a jurisdiction. Applying it is not required to assert compliance with IFRS Sustainability Disclosure Standards, but if applied with a compliance assertion, all of its requirements must be met.
- Has HKEX Part D adopted nature-related disclosure requirements?No. Part D sets climate-related disclosure requirements developed with reference to IFRS S2. It has not adopted the ISSB Nature Practice Statement or a separate nature chapter. Climate–nature interconnections may still inform Part D strategy and risk narrative where they are climate-related; that is not the same as a Part D nature mandate.
- Why build a nature-dependency register before any Hong Kong mandate?Because IFRS S1-style materiality already asks whether nature-related risks and opportunities could reasonably affect prospects, and because a single register co-owned by finance and sustainability prevents divergent inventories when mainland, Hong Kong and voluntary TNFD-style requests arrive on different clocks.
- Does applying TNFD recommendations equal applying the ISSB Practice Statement?No. The ISSB states that it is drawing on TNFD to specify particular aspects of material nature-related information. TNFD remains useful background. Asserting compliance with the Practice Statement, once final, would be a separate decision under the Practice Statement’s own requirements.
Conclusion
The ISSB has chosen a Practice Statement so that nature-related disclosure can gain specificity without rewriting S1 and S2 or forcing every adopting jurisdiction to take nature on the same day as climate. Hong Kong’s Part D remains a climate code. The wrong response is to wait for a Part D nature chapter that has not been proposed. The right response is to build one nature-dependency register now, co-owned by finance and sustainability, mapped into the strategy and risk work issuers already do under Part D where climate and nature meet, and held ready for whatever Hong Kong Standards or HKEX later require. The consultation closes on 19 February 2027. The register should exist before that date, not after a mandate arrives.
Edited / written by: Amanda Cheung, Founder, AMMO Group
