Introduction

Nature and its associated benefits to people are in global decline, with critical ecosystem services at risk of collapse. In Australia, it is estimated that half of the gross domestic product is moderately or highly dependent on nature, either directly or indirectly through value chain exposure. Recent policy responses have attempted to address this crisis, including the international Kunming-Montreal Global Biodiversity Framework (GBF) and Australia’s Nature Positive Plan. These developments introduce significant transition risks for the real estate sector, as activities like land and housing development lead to biodiversity loss and increasingly require rigorous assessment under shifting environmental laws such as the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).

Regulatory context

The regulatory landscape for nature-risk management in Australia is shaped by legal obligations under the Corporations Act 2001 and emerging private regulatory activities. Companies and directors are legally required to identify, disclose, and manage material financial risks, which includes foreseeable risks posed by biodiversity loss. Frameworks such as the Taskforce on Nature-related Financial Disclosures (TNFD) have categorised these as physical, transition, and systemic risks. Voluntary standards, investor engagement platforms like Nature Action 100, and advocacy from organisations such as the Australasian Council of Superannuation Investors (ACSI) are increasingly pressuring companies to provide robust disclosures on nature-related dependencies, impacts, risks, and opportunities (DIRO).

Empirical insights on nature-related risk disclosure and management

This exploratory study analysed the 10 largest publicly listed real estate companies in Australia by market capitalisation as of March 2025. The sample included Goodman Group, Scentre Group, Stockland, Vicinity Ltd, GPT Group, Mirvac Group, Charter Hall Group, Dexus, Lendlease Corp Ltd, and National Storage REIT. The research used qualitative content analysis of annual, sustainability, and dedicated nature reports from 2021 to 2024 to track how these companies recognise and frame nature-related risks.

Sustainability reporting

All companies in the sample produced climate-related information, but nature-specific reporting is rare. GPT Group was the only company to produce a dedicated nature report, known as a Climate and Nature Statement, in 2023 and 2024. For most other firms, nature-related information was inconsistently integrated into broader sustainability reports or company websites, with no other standalone nature reporting observed during the study period.

Ambition, commitment and integration

While most companies have long-term net zero climate commitments, nature-related commitments are often vague and rarely align with global goals like the GBF. There is evidence of companies winding back or reframing initial ambitions. For example, Stockland reported achieving a target to make a “positive contribution” in 2022 but did not include broader nature commitments in its 2023 or 2024 disclosures. Similarly, Dexus removed references to its “net positive impact” goal in its 2024 reporting. This suggests a cautious approach as companies manage the introduction of mandatory climate reporting and heightened scrutiny regarding greenwashing.

Materiality

Nature and biodiversity are not consistently identified as material issues in corporate assessments. Where identified, they are frequently treated as sub-categories of other environmental issues such as waste or water use. Dexus was the only company to include a materiality matrix explicitly listing biodiversity, yet it ranked the issue as having low importance to both stakeholders and the company. This suggests that nature-related risks are not yet widely perceived as financially material by the sector’s leading firms.

Disclosure of nature-related dependencies, impacts, risks and opportunities in line with TNFD

Adoption of the TNFD framework has been minimal. GPT Group is the only company in the sample to formally adopt the framework and provide granular disclosures, such as quantifying assets situated in areas of high biodiversity value. While companies like Mirvac and Charter Hall initially signalled an intent to adopt the TNFD, many subsequently paused or removed these references, citing the regulatory burden of mandatory climate reporting and technical challenges with data collection.

Targets and risk management strategy

Few companies have established specific, time-bound targets for nature. GPT Group’s targets are the most advanced, covering impacts such as pollution, freshwater use, and land-use change. However, other companies have revised or removed targets previously disclosed. Furthermore, none of the companies mentioned the new national Nature Repair Market or voluntary biodiversity credit markets as part of their strategy, and none showed explicit alignment with the recommended mitigation hierarchy of first avoiding and minimising impacts before resorting to offsets.

Conclusion

The study concludes that engagement with nature-related risks in the Australian real estate sector remains nascent and tentative. Without mandatory sustainability reporting standards that apply to nature and strengthened policy signals to constrain development that impacts biodiversity, companies are unlikely to move beyond high-level, vague commitments. Nature-related risks continue to be treated as a peripheral sustainability issue rather than a core strategic concern.