From Pledges to Portfolios: Why Biodiversity Still Lags

Dutch banks, insurers, and asset managers have moved biodiversity up the agenda, signing pledges and joining initiatives such as TNFD, the Finance for Biodiversity Pledge, and PBAF. But progress is slow in turning those commitments into portfolio decisions, products, and risk processes. Interviews with senior practitioners and a review of recent biodiversity disclosures show that momentum is currently driven by brand and peer expectations, while binding, enforceable rules remain limited. As a result, firms prioritise visibility over the heavier lift of integrating biodiversity into portfolio construction, product design, and risk models.

What we looked at

During the course of 2025, eight interviews with senior professionals across Dutch financial institutions were conducted, and the 2024 public reports from ten major firms were analysed by Blanca Salvat, sustainable finance researcher at ACE + Company. The review confirmed three things: nearly all organisations have public biodiversity commitments; embedding into portfolio mandates and product pipelines remains rare; and current momentum is driven more by peer signalling than by binding requirements. Interestingly yet hardly surprisingly, this is mirroring early climate adoption patterns before climate-related rules tightened.

What is blocking progress?

1. Data integration is still a plumbing problem
   Even when biodiversity indicators exist (e.g., geospatial footprints, nitrogen/pesticide use), pulling them from reports and vendor feeds into governed, legacy banking systems is slow and resource-intensive. Analysts spend disproportionate time cleaning and reconciling fragmented sources; in some regions, the data is missing altogether. The result: biodiversity remains stuck at the qualitative level, which is good enough for a disclosure, but not robust enough for portfolio-wide insights or consistent impact screens. Institutions don’t just need “more data”; they need infrastructure to standardise, link, and trace it.
2. Client data friction is real
   Relationship managers face drop-offs when requesting detailed biodiversity information. Farmers, corporates, and SMEs often view granular land-use or supply-chain questionnaires as burdensome or commercially sensitive. Some even indicate that it might be enough to push them to competitors, impacting the business commercially. Voluntary collection is patchy, with low coverage and uneven quality. This creates a double bind: institutions are accountable for exposures without reliable client-level data, slowing product rollout and weakening engagement strategies.
3. Nature dependencies don’t price in (yet)
   Unlike climate, biodiversity lacks a single unifying metric (think CO₂) that can flow into credit models or underwriting. Practitioners struggle to translate ecological change (pollinator decline, water scarcity, soil fertility loss) into financial terms. Existing proxies, like sector exposures, biodiversity monitors, or satellite imagery, are too high-level for pricing adjustments. Without a way to monetise nature dependencies, risk committees keep biodiversity in a reputational/CSR bucket rather than a capital allocation one.
4. Regulatory divergence & immature vendor scores
   Teams are navigating uneven expectations across regions (EU, UK, US, APAC). Some rules are advancing (e.g., CSRD’s ESRS E4 in Europe); others remain unclear. Many institutions are waiting for the dust to settle before committing to systems and processes. Meanwhile, biodiversity scores are often sector-based and inconsistent: too coarse for client-level decisions but too prominent to ignore. Together, this uncertainty depresses budgets and slows the shift from pilot to production.

 

What to do now: a practical pathway

• Build the data backbone first

Create a unified biodiversity data model that maps ESRS E4, TNFD, and PBAF requirements to your internal definitions; apply semantic matching; and maintain lineage to source systems. The goal is to reduce manual reconciliation and gain clear coverage views across portfolios, so biodiversity can move from narrative to numbers.

• Lower the “ask” to clients without losing essentials

Before sending another burdensome questionnaire, perform a client data gap assessment: identify what you already hold internally and standardise requests for only what is truly essential. Provide templates that are proportionate and auditable, preserving realationships while improving coverage.

• Lay the groundwork for risk integration

You may not be able to price pollination or soil fertility loss accurately today, but you can capture dependency indicators, document assumptions in a methodology registry, and produce regulator-ready evidence packs. This creates the scaffolding for future integration into risk and valuation as standards inevitably mature.

• Navigate regulatory divergence with living maps

Stand up horizon scanning and adherence assessment across jurisdictions and link requirements to internal datapoints. Maintain a “living overview” of what is mandatory, what’s missing, and where to focus resources so you can move decisively despite moving targets.

Why this matters now

The sector has shown that voluntary commitments can lift awareness, but real change followed in climate only when regulation tightened. Biodiversity sits at a similar crossroads. Institutions that invest early in data infrastructure, streamlined client asks, and regulatory mapping will be ready to convert reputational signals into pricing-relevant insights as the rulebook and methods solidify.

Where we come in

We help financial institutions get biodiversity out of reports and into production systems, building the plumbing, governance, and evidence base to turn ambition into business-as-usual. Not silver bullets; just the right sequence of practical steps that remove the bottlenecks you’re feeling today.

This article summarises the scientific research performed by Blanca Salvat Ruiz – thesis research in collaboration with the Vrije Universiteit Amsterdam and ACE + Company, including interviews with senior professionals and a review of 2024 disclosures from ten Dutch financial institutions.