Introduction

This paper provides the Finance for Biodiversity (FfB) Foundation’s feedback on the draft ‘Global Report of Collective Progress’ (Global Report). This report was developed as part of the Global Review under the Convention on Biological Diversity (CBD) to take stock of collective progress towards the Global Biodiversity Framework (GBF) goals and targets. The FfB Foundation aims to strengthen the report with actionable, finance-relevant insights to ensure the Global Review becomes a decision-relevant process ahead of COP17. The foundation, which represents over 200 global financial institutions managing nearly €20 trillion in assets across 30 countries, emphasises that the review must go beyond reporting progress and help drive necessary changes in the financial system.

Overall assessment of the Global Report findings regarding finance-related goals and targets

The draft Global Report presents a mixed picture of progress. While implementation efforts are underway, current progress remains insufficient to achieve the GBF’s 2030 mission to halt and reverse biodiversity loss. Implementation gaps are particularly evident in areas critical for resource mobilisation and the alignment of financial flows with the GBF. Progress remains uneven across Goal D and Targets 14, 15, 18, and 19. Notably, Target 8, focusing on the nature-climate nexus, is the only target assessed as progressing successfully, demonstrating the value of integrated approaches across environmental agendas.

Regarding Target 14, which covers mainstreaming biodiversity in decision-making, progress is reported as uneven and limited. While National Biodiversity Finance Plans (NBFPs) are emerging, there is a persistent challenge in mainstreaming nature across economic sectors. For Target 15, business and finance biodiversity-related assessment and disclosure, progress is weak. Very few countries have established mandatory requirements, and the voluntary nature of corporate reporting has led to data gaps and a lack of standards. Research cited in the report indicates that less than 1% of companies currently disclose nature-related information.

Target 18, relating to harmful incentives and subsidies, shows the least progress. Only around 5% of parties have set quantitative targets to reduce harmful subsidies, with efforts currently concentrated on increasing positive incentives. For Goal D and Target 19, which address resource mobilisation, progress is deemed insufficient relative to the targets. A major challenge remains the scale of public and private financing for biodiversity and the lack of improved tracking methodologies in coordination with national statistical offices and the private sector.

Reflections on the causes of limited GBF implementation and policy asks for progress from the finance sector’s perspective

The FfB Foundation identifies several areas where implementation has fallen short and offers recommendations to course correct. Firstly, the Global Review must drive accelerated and comprehensive implementation by providing actionable insights for governments and ensuring coherent long-term signals to financial institutions. Secondly, the foundation encourages the supervision of nature-related financial risks under Targets 14 and 15. It calls for the recognition of biodiversity loss as a source of systemic risk for financial markets and the real economy, urging central banks and supervisors to include nature in their mandates.

To improve tracking under Target 15, regulators should identify levers to accelerate the uptake of nature-related assessments, supporting frameworks like the Taskforce on Nature-related Financial Disclosures (TNFD). There is a critical need to correct gaps in data comparability, decision-usefulness, and coverage. Furthermore, achieving GBF targets requires building real-economy transitions along sectoral pathways for high-impact sectors such as agriculture, metals and mining, and chemicals. This includes reinforcing the involvement of Ministries of Finance in developing National Biodiversity Strategies and Action Plans (NBSAPs).

Regarding economic incentives, capital deployment remains constrained by a lack of bankable projects and the systemic barrier of limited progress on subsidy reforms. The foundation recommends prioritising the mapping and reform of subsidies as part of the commitment to implement the GBF. Finally, the systematic assessment of the alignment of financial flows must be strengthened. Success in mobilising resources depends on the transformation of financial systems, necessitating improved tracking methodologies for both public and private financial flows in consultation with the private sector.

Text suggestions for the Global Report to provide a systematic assessment of financial system transformation under the GBF

The foundation proposes specific text additions to the Global Report’s summary and ‘Means of Implementation’ sections. These suggestions include linking findings explicitly to economic and financial stability implications and outlining the role of central banks and financial supervisors. It recommends that the report recognise reforming harmful subsidies as a key means of implementation, requiring significant political will. The Global Review should indicate whether governments and financial institutions are contributing to transformation by assessing progress in capital allocation, risk integration, and the reduction of nature-negative financial flows.

Concluding remarks

Historically, governments have fallen short on nature finance commitments, particularly in mobilising funding at the required scale. The FfB Foundation asserts that it is critical for the Global Review to place a more explicit and sustained emphasis on finance-oriented targets. Ensuring substantive progress on these targets is vital for the effective implementation of the GBF. The next Global Review at COP18 must reflect faster and more progressive global action to bridge the gap between policy ambition and financial system transformation, ultimately enabling a credible pathway to aligning global finance with nature-positive outcomes.