Closing the gaps in the Global Biodiversity Framework implementation: Investor actions and policy recommendations
This report analyses actions by over 800 investors to address nature and biodiversity risk. It highlights progress in corporate engagement and disclosure while identifying critical policy gaps. Six key government actions are recommended to accelerate private sector contributions toward the Kunming-Montreal Global Biodiversity Framework targets.
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OVERVIEW
Key takeaways
This report analyses the actions of more than 800 investors addressing nature and biodiversity risk. It highlights progress and gaps in achieving the Kunming-Montreal Global Biodiversity Framework (KMGBF). Nature loss presents a material financial risk, and institutional investors have a critical role in managing these systemic threats. Currently, more than 400 institutional investors representing $60 trillion in assets under management have engaged over 300 companies on nature-related issues. Additionally, over 160 investors have advocated for enabling policies such as the EU Deforestation Regulation. However, voluntary action alone cannot close the implementation gap; coherent policy and aligned economic incentives are essential to accelerate corporate progress.
Progress gaps on finance-oriented targets
The first global review of progress under the Convention on Biological Diversity (CBD) shows that governments cannot meet biodiversity goals without private sector engagement. Significant gaps remain in integrating biodiversity into risk assessments and decision-making. These implementation gaps put the framework’s 2030 targets at risk and limit the potential for private finance to contribute to halting and reversing nature loss.
Notable gaps in KMGBF implementation
Target 14 aims to integrate biodiversity into decision-making at every level, yet progress is limited by insufficient capacity and standardised methodologies. Target 15 requires businesses to assess and disclose risks, but voluntary disclosures remain fragmented without mandatory frameworks. Target 18 seeks to reduce harmful incentives by at least $500 billion per year; however, progress is stalled by political barriers and the difficulty of identifying harmful subsidies. Finally, Target 19 aims to mobilise $200 billion annually. Mobilising and tracking this financing remains difficult, and private investment in biodiversity was estimated at just $32.8 billion between 2020 and 2023, which is likely a vast underestimate.
The roles of institutional investors
More than 50% of global investors are “very concerned” about the impact of nature loss on financial markets. Approximately 500 financial institutions have committed to taking action, including signing the Finance for Biodiversity Pledge and committing to adopting recommendations from the Taskforce on Nature-related Financial Disclosures. Over 680 institutional investors across various initiatives are deploying approaches such as capital allocation, policy engagement, and stewardship to support KMGBF implementation.
An analysis of investor action that supports KMGBF targets
A 2025 global survey found that 54% of investors have assessed their portfolios’ exposure to nature-related risks. While 98% of institutions surveyed by the Finance for Biodiversity Foundation integrated biodiversity into sustainability policies, adoption varies by jurisdiction. In North America, 52% of the largest investors integrate nature issues into stewardship, while 42% of investors surveyed by the Asian Investor Group on Climate Change (AIGCC) have disclosures or strategies on nature, up from 33% in 2024. Despite this, a World Benchmarking Alliance analysis of 400 financial institutions found only 14% show evidence of nature-related impact assessment or strategy development.
Investor engagements can shift corporate behaviour and capital allocation
Stewardship allows investors to align corporate capital with long-term value creation. Over 400 unique investors are participating in initiatives like Nature Action 100 and PRI Spring, engaging over 300 global companies across all sectors. A case study involves Ajinomoto, a Japanese food and biotechnology corporation. Through engagement with Nature Action 100 Investor Participants, the company improved its disclosures and prioritised high-impact agriculture commodities including palm oil, soybeans, beef, and paper in 2025, while strengthening its commitment to prevent deforestation.
Investors signal need for policy reforms
Investors are increasingly advocating for policies that accelerate nature-positive investment. Ahead of COP30, 51 investors managing $4.5 trillion endorsed the Belém Investor Statement on Rainforests. Furthermore, 160 signatories with $20 trillion in assets supported the robust implementation of the EU Deforestation Regulation, and 88 institutional investors with $14.2 trillion participate in the Investor Policy Dialogue on Deforestation. Additionally, 32 investors with $7.2 trillion called on G20 finance ministers to repurpose their agriculture subsidies in line with climate and nature goals.
Priority policy actions to further enable investor contributions
Six government actions are identified to accelerate private sector contributions: turning global targets into national implementation via National Biodiversity Strategies and Action Plans (NBSAPs); integrating biodiversity across all government decision-making; providing regulatory certainty and coherence across jurisdictions; moving toward mandatory, comparable disclosure; aligning public finance and incentives with biodiversity goals, particularly regarding Target 18; and establishing structured dialogues with investors. Aligning financial flows is essential to reducing nature-related financial risks and supporting the scale of capital required to halt biodiversity loss by 2030.