Investor-led engagement initiative Nature Action 100 (NA100) has reported “considerable progress” among its focus companies against a set of nature-related investor expectations, with its latest benchmark assessment published during COP17 in Yerevan, Armenia. The findings suggest that while corporate commitments and target-setting on biodiversity continue to increase, investors are placing greater emphasis on whether those commitments are being translated into credible governance, risk management and operational action.

The assessment arrives as nature-related financial risks move further up the investor agenda. A separate report coordinated by Ceres highlights the growing scale of investor stewardship activity on biodiversity issues, while the International Sustainability Standards Board (ISSB) has launched a consultation on proposed nature-related disclosure requirements. Together, the developments point to a market increasingly focused on evidence of delivery, stronger accountability and more comparable disclosure rather than commitments alone.

Corporate progress, but uneven implementation

NA100's second benchmark assesses the initiative's 100 focus companies against six investor expectations covering governance, strategy, risk management, disclosure and action on nature-related impacts. Published during the first week of COP17, the assessment identifies broad improvements across several key indicators since the inaugural benchmark.

Among the headline findings, 95 companies now disclose a commitment to avoid and reduce at least one major driver of nature loss and/or support ecosystem restoration and regeneration, up from 69 in 2024. Meanwhile, 76 companies report at least one quantified and time-bound target relating to nature-related dependencies, impacts, risks or opportunities, compared with 48 two years ago.

However, the benchmark's most important message may be less about the growth in commitments and more about the continuing challenge of implementation. Assessing nature-related dependencies, impacts, risks and opportunities remains difficult for many companies, despite such assessments forming the foundation for risk management, transition planning and capital allocation decisions. The results suggest that investors are increasingly using biodiversity commitments as a starting point rather than an end point, with greater scrutiny now falling on execution, governance arrangements and evidence of progress.

Investor engagement efforts amid growing regulatory scrutiny

NA100 is a global investor-led initiative that encourages 100 focus companies across eight key sectors, including the likes of Amazon and Nestlé, to reverse nature and biodiversity loss by 2030 while addressing associated financial risks. The initiative brings together more than 250 investor participants representing over U$32 trillion in assets under management or advice.

Widely viewed as the biodiversity-focused counterpart to Climate Action 100+ (CA100+), NA100 is expanding at a time when collaborative investor engagement continues to attract regulatory attention. Earlier this month, the US Securities and Exchange Commission raised concerns about the activities of certain CA100+ members surrounding ExxonMobil’s 2021 board election, while declining to pursue enforcement action and signalling continued scrutiny of coordinated investor engagement initiatives. Ceres - the organisation which coordinates CA100+'s work in North America and was scrutinised by the SEC – also co-leads the NA100’s Global Secretariat and the Corporate Engagement Working Group.

For NA100 participants, this outcome may therefore be watched closely as a potential indicator of how stewardship efforts addressing systemic sustainability risks could be treated in future.

Investor action and policy gaps spotlighted

A separate report coordinated by Ceres conducted a wider analysis of how investors themselves are engaging with nature-related risks and the constraints they continue to face. It found that more than 400 institutional investors representing US$60 trillion in assets under management have collectively engaged over 300 companies on nature-related risks.  

According to the report, although stewardship efforts are growing rapidly, stronger policy frameworks, better disclosure and more aligned incentives will be necessary if those efforts are to achieve economy-wide biodiversity goals. More than 160 investors have also advocated for supportive public policy measures, including the EU Deforestation Regulation. Nature Action 100 is identified as one of the key engagement platforms through which investors are coordinating these efforts.

Policymakers such as the European Union have committed to pushing for faster implementation of the Kunming-Montreal Global Biodiversity Framework, including: stronger integration of biodiversity considerations across policy areas and sectors, and greater mobilisation of public and private finance. However, negotiations have continued to expose divisions over biodiversity financing, corporate responsibilities associated with genetic resources, and the distribution of conservation costs. The European Council earlier this month also proposed significant cuts to climate- and nature-related spending.

ISSB opens nature-related disclosures consultation

Separately, the ISSB used COP17 to launch a consultation on proposed nature-related disclosure requirements - including whether those requirements should be mandatory - with feedback open until 19 February 2027.

The proposals are intended to help companies provide investors with material information about nature-related risks and opportunities, including those arising from their dependencies and impacts on nature. Companies already applying IFRS S1 are required to disclose material sustainability-related risks and opportunities that could affect their prospects, including those linked to nature. The consultation therefore represents an effort to provide more detailed guidance and consistency in this area rather than creating an entirely new reporting obligation.

The significance for investors lies in the potential for greater comparability. The proposals draw extensively on the work of the TNFD and, if adopted, could provide a more consistent basis for assessing how companies identify, evaluate and manage nature-related risks across sectors and markets. In that sense, the consultation addresses a different issue from both the NA100 benchmark and the Ceres-coordinated report: not corporate performance or investor engagement, but the quality and consistency of information available to the market.

What investors should watch in nature stewardship and biodiversity reporting

Taken together, these developments show different parts of the nature-related stewardship ecosystem advancing at different speeds. Corporate commitments are increasingly being tested through implementation and investor scrutiny, while reporting remains focused on building common standards, improving data and establishing comparable disclosure practices.

The NA100 benchmark showcases growing corporate engagement but persistent execution challenges. The Ceres-coordinated report finds substantial investor stewardship constrained by policy and market barriers, while the ISSB consultation could improve assessment through more consistent reporting standards.

Overall, the market is becoming less concerned with whether companies make nature commitments than with whether they can evidence, govern and compare them. Implementation quality may increasingly distinguish leaders from laggards.