WBA responds to TNFD Draft Sector Guidance – Alternative Fuels
The World Biogas Association (WBA) submitted its response to the Taskforce on Nature-related Financial Disclosures (TNFD) Draft Sector Guidance – Alternative Fuels consultation on Tuesday, 5 May 2026.
The TNFD Alternative Fuels guidance is a sector-specific document that can be used by companies to identify and disclose nature-related risks and opportunities across the fuel transition value chain. For the biogas sector, it is relevant because it provides tailored metrics for assessing dependencies on land, water, and organic feedstocks while highlighting the environmental benefits of waste-to-energy circularity. Biogas stakeholders can utilise this in their reporting on biodiversity and ecosystem impacts to meet the growing transparency demands of green investors.
After attending a closed roundtable discussion to better understand TNFD’s requirements, we drafted a letter in response to the draft sector guidance. In our response we welcomed the development of this framework and its recognition of value chain impacts, as well as the extent to which biogas had already been incorporated into the draft guidance. However, we also highlighted several areas where the framework could be strengthened. WBA provided recommendations to improve its clarity, proportionality, and applicability for the biogas sector.
Key points included:
- Recognition of avoided impacts: The draft guidance should better account for avoided impacts, particularly methane capture from waste and the negligible land-use footprint of waste-based feedstocks.
- Improved metrics and clarity: Recommendations include clearer treatment of waste-based and rotational crop-based feedstocks in land-use metrics, refinement of pollution and allocation methodologies, and inclusion of additional metrics such as landfill diversion and methane leakage.
- Digestate as a nature-positive outcome: Greater recognition is needed for digestate’s role in replacing synthetic fertilisers and improving soil and water health.
- Biogas as a circular economy catalyst: Biogas should be treated not just as a fuel, but as part of an integrated circular economy linking waste management, energy, and agriculture.
- Alignment with existing frameworks: Greater alignment with existing standards (e.g. RED III, ISCC) is encouraged to reduce reporting burden and improve consistency and feasibility.
- Proportionate reporting requirements: The framework should reflect the structure of the sector, including SMEs, through tiered reporting, use of proxy data, and phased implementation timelines.
Overall, WBA’s response emphasised that biogas should not be treated simply as an alternative fuel, but as an integrated circular economy solution linking renewable energy, waste management, agriculture, soil regeneration and methane mitigation. Ensuring that TNFD guidance reflects this role will be important for enabling fair, credible and practical nature-related disclosures for the sector.
We would like to encourage WBA members to continue engaging with us for such processes. Your feedback helps ensure that WBA’s final responses reflect the practical realities and nature-positive opportunities of the global biogas industry.