For every dollar spent protecting nature in 2023, roughly 30 dollars flowed into activities that damage it. That ratio comes from the UNEP’s State of Finance for Nature 2026 report, which puts total investment in nature-based solutions at $220 billion – set against a far larger tide of capital running the other way. The imbalance isn’t just a moral question about where money goes. It’s precisely the pattern regulators are now asking organisations to account for on their own books.
Nature positive – broadly defined as halting and reversing nature loss by 2030 – has moved from niche sustainability vocabulary into mainstream corporate strategy. As the language appears in annual reports, investor presentations, and procurement frameworks, it carries something beyond aspiration. It implies a baseline, a direction, and a trajectory that can be tested.
Organisations whose public commitments to protecting nature run ahead of what they can measure, demonstrate through structured stakeholder engagement, and hold to account through governance aren’t simply expressing ambition. In that environment, measurement, structured stakeholder engagement, and governance accountability aren’t the operational support for a nature positive strategy. They’re what a nature positive commitment actually consists of.
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The Line Has Moved
Defining nature positive as halting and reversing nature loss by 2030 carries direct operational consequences. A directional, time-bound goal means any organisation endorsing it needs to know its current ecological baseline, track change over time, and connect key decisions to observable outcomes in land, water, and biodiversity. Once that definition appears in corporate materials, the obligation to measure and manage exists – whether or not specific regulation has caught up.
As nature positive language moves from niche sustainability circles into mainstream positioning, the visibility calculus shifts. Publicly aligning with nature-focused commitments signals intent, but it also creates a visibility trap. Declarations are easy to see and compare, and the absence of internal systems to substantiate them becomes more conspicuous under scrutiny, not less. An organisation’s loudest public signal of nature positive commitment is also its most legible invitation for reviewers to look closely.
The commercial scale of nature dependence reinforces why this matters. S&P Global research indicates that 85 per cent of the world’s largest companies rely significantly on nature, with around US$28.9 trillion of revenues at risk from nature-related disruption. At that scale, remaining vague about nature positive commitments isn’t a neutral position. It’s a decision about how much unmanaged risk an organisation is prepared to carry.
The Credibility Gap Has a Price
ASIC and the ACCC have already secured penalties exceeding $34 million in greenwashing cases. That includes a Federal Court-ordered $12.9 million civil penalty against Vanguard, $10.5 million against Active Super for misleading sustainability-related representations, and $8.25 million against Clorox Australia over “ocean plastic” claims for certain Glad products. The legal consequences of unsubstantiated environmental claims are no longer theoretical.
ASIC Chair Joe Longo is explicit on how the regulator evaluates potentially misleading sustainability statements: “It is, in each case, a question of fact, to be determined objectively.” That framing matters. The distinction between deliberate exaggeration and well-intentioned overstatement is not central to the legal analysis. For organisations, the practical implication is direct: the risk attaches to any claim that cannot be substantiated at the time it is made, and good faith is not a defence when the evidentiary record is empty.
Regulators are now applying the same diagnostic logic inside individual organisations. They’re not looking at sector-wide flows. They’re asking whether a gap exists between public nature positive claims and actual allocation of capital, management attention, and controls within specific companies. When it does, and the evidence is thin, it’s treated as a compliance issue.
The enforcement risk doesn’t arise from partial data or imperfect progress in measuring nature-related impacts. It arises when organisations make confident public claims without a defensible evidentiary base. That raises a question worth taking seriously: what does substantiation actually require at the level of data, systems, and governance?
What Substantiation Actually Requires
Once nature positive is defined as halting and reversing nature loss by 2030, endorsing that definition carries an implicit measurement obligation. Organisations need to identify where and how their activities depend on and affect ecosystems, establish baselines for key impacts, and track change over time in a way that connects to operational decisions. Reporting frameworks can help structure disclosure. They cannot, however, substitute for the underlying data, analytical capability, and governance processes that translate technical findings into information boards can actually use.
The collaboration between Earth Blox and Lloyds Banking Group illustrates what this looks like at scale. Earth Blox combines satellite, environmental, and portfolio data in its analytics platform. Working with Lloyds, Earth Blox assessed nature-related risks across 5.1 million hectares of UK farmland, identifying more than 1.2 million hectares where resilience-building measures could be deployed. That is substantiation – not a policy position, but a spatial, testable finding that connects risk exposure to specific land and specific decisions. Finance frameworks are reinforcing exactly this evidentiary direction: the Equator Principles for project finance set expectations for environmental and social due diligence, including loan covenants and independent monitoring and reporting, while the European Banking Authority’s guidelines on ESG risk management treat environmental degradation and biodiversity loss as relevant risk factors and point banks towards sound data processes and counterparty engagement. As these standards become embedded in financial practice, organisations seeking capital face growing expectations to supply defensible nature-related data, not narratives.
Boards that cannot clearly explain their organisation’s material dependencies on nature, key impacts, and mitigation plans are limited in the oversight they can credibly provide over nature positive commitments made on the organisation’s behalf. That limitation is not confined to obviously land-intensive sectors. Procurement and supply chains often carry substantial embedded ecological risks that don’t appear in operational emissions metrics alone. Substantiation requires coordinated work across finance, risk, operations, and sustainability functions – and even organisations that get those internal systems right can still face a different, harder problem with the communities their projects depend on.
Trust Cannot Be Filed Under Communications
In sectors where projects intersect directly with land, water, and local communities – mining, infrastructure, major capital works – social licence functions as a second, equally important dimension of credibility alongside environmental measurement. An organisation can build detailed nature-related datasets and still encounter project delays, conditions, or opposition if affected stakeholders view consultation as superficial or see a gap between what is promised and what is delivered.
That distinction shows up clearly in the International Finance Corporation’s Performance Standards, widely used in project finance as an environmental and social risk framework. The IFC defines engagement as a structured management process, not a communications activity. Performance Standard 1 notes that “Stakeholder engagement is an ongoing process that may involve, in varying degrees, the following elements: stakeholder analysis and planning,” and continues to outline expectations around information disclosure, consultation where communities are affected, and accessible grievance mechanisms. What PS1 defines is not a messaging function but a control that generates records – documentation, decisions, grievance responses – that lenders and reviewers can test against commitments.
Turning that principle into day-to-day practice requires a method, not just intent. In sectors such as mining, infrastructure, and government – where projects sit directly on land and within communities – Monique Chelin, a board director (GAICD) and founder of MJC Sustainability with experience spanning government, mining, and infrastructure projects including in Fiji and Papua New Guinea, applies a five-stage stakeholder engagement process: identifying and assessing stakeholders, prioritising them, developing an engagement plan, implementing engagement activities and key messages, and then monitoring, reviewing, and responding. Most organisations default to consultation when community concern is already visible. A staged process applied from the outset builds a record of responsiveness rather than a record of reaction. Social licence, like measurement, is an evidentiary discipline – and an organisation that cannot demonstrate structured, documented, responsive engagement has not closed the credibility gap; it has shifted it from the measurement dimension to the community dimension.
Boards that lack visibility of which stakeholder groups are affected, what issues are being raised, how grievances are being managed, and where project decisions have been shaped by engagement outcomes cannot credibly oversee social licence claims made on the organisation’s behalf. Without that line of sight, statements about respecting community expectations rest on weak foundations – particularly where financiers and regulators are already familiar with testing stakeholder processes against standards like the IFC Performance Standards.
The governing question for any organisation with nature positive commitments in the public domain is less “how are we communicating this?” and more “what would we produce if asked to prove it?”
The Licence Is Not Given – It Is Demonstrated
The organisations that hold credible nature positive positions long-term are not those with the most ambitious language in their sustainability reports. They’re the ones that can produce, on request, the data behind the claim, the record of community engagement, and the governance trail showing who decided what and why. That combination is harder to build than a declaration and considerably harder to simulate than a well-crafted stakeholder update.
The systemic imbalance between capital that damages nature and capital that protects it is a documented problem; regulators are now asking whether the same ratio shows up inside individual organisations – between public commitments and the resources, controls, and governance arrangements that actually back them. Measurement, engagement, and accountability reinforce each other; none of them alone carries the weight of public commitment in an environment where the test is increasingly applied by people who know what evidence should look like. The licence to operate is not secured by aligning with a framework or adopting the right language – it belongs to organisations that can produce the evidence, not as a retrospective audit exercise, but because the systems that generate it were built before the claim was made.
