The Complete Guide to National Climate-Related Disclosures
5 years ago, a climate strategy was a nice-to-have, an additional brand value. 2 years ago –and for some, still– climate strategy was a long-term commitment. 2022 marks the great shift from nice-to-have to must-have. Starting 2023, 35 nations and regions are rolling out mandatory climate disclosures. How does this affect your company?
35 of the world’s most prominent economies are making disclosures on corporate climate strategy, emissions, targets and roadmaps mandatory, starting with their largest companies. Starting as early as 2023, companies will have to accompany their annual financial disclosures with climate-related disclosures, signaling that corporate climate action is deemed on par with financial action. Depending on a company’s level of climate-preparedness, the mandate may elicit emotions from all over the spectrum.
But let’s put our ducks in a row – Find your question of interest as we go through.
Which markets are making climate disclosures mandatory?
So far, the countries, markets, or regions that have issued a bill or proposal are:
🇭🇰 Hong Kong
🇳🇿 New Zealand
Why are climate disclosures becoming mandatory?
According to the Financial Stability Board and the 35 markets mandating climate disclosures, an organization’s stance on climate change is critical viability information for investors. A company’s strategy on climate change and how robust it is helps investors tell apart a safe investment with growth potential from a risky one.Then, if it is in the best interest of the companies, why do climate disclosures need to be mandated by the market or the government? Primarily because governments and markets are catching up on important conversations happening within the industry.
The first goal of the mandate is to work towards standardization. All 35 countries have identified that the lack of climate-related data comparability and different scopes are detrimental to any financial decision-making. Investors cannot make a solid or rational decision if they are comparing apples with oranges. Using existing frameworks, such as the TCFD guidelines, and streamlining calculation methodologies is a prominent raison d’être in all bills.
The Enhancement and Standardization of Climate-Related Disclosures for Investors, SECURITIES AND EXCHANGE COMMISSION
The second goal of the mandate is national climate target accountability. Nations have climate targets themselves, famously pledged in the annual Conference of Parties (COP). Nations and markets are realizing that these goals are unreachable if the industry is not getting involved.
To involve the industry, governments and markets call for companies to improve climate data quality. Why is data quality so central? High-quality climate data is essential to identify climate risks with clarity and manage them effectively in the committed time span.
Directive amending directive 2013/34/eu, directive 2004/109/ec, directive 2006/43/ec and regulation (eu) no 537/2014, as regards corporate sustainability reporting, THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION
Thirdly, the mandate works as a means for companies to be held accountable for their own pledges. Investors do not perceive mere targets as a safety net anymore – they need to see the follow-up actions and an integration of climate strategies into the core business.
This is evident in the bill and proposal pattern for emissions along the supply chain (or Scope 3). If Scope 3 disclosures are not mandatory overall, they become mandatory based on certain parameters:
- Companies either get buffer time to disclose Scope 3 emissions, or
- Companies are mandated to disclose if they have existing Scope 3 targets themselves.
The bottom line is the same: Holding companies accountable and transparent towards investors.
The Enhancement and Standardization of Climate-Related Disclosures for Investors, SECURITIES AND EXCHANGE COMMISSION
How did it all start?
It all starts with the Financial Stability Board (FSB). The FSB is an international body endorsed by the G20 and created in 2008 to promote global financial stability. Among the FSB’s tasks is identifying vulnerabilities that could destabilize the financial system.
Naturally, climate change is one of the largest financial vulnerabilities they have identified. The FSB assesses that factoring climate risks in financial decisions will enable stability. And the way to do this is with transparent, accurate, comparable disclosures that support investor decisions.
To streamline disclosures, the FSB create the Task Force on Climate-Related Financial Disclosures (TCFD). TCFD’s most notable work is the Recommendations on climate-related financial disclosures. The TCFD recommendations you will see later on are the very foundation of the climate disclosure bills and proposals of all 35 markets.
When are climate disclosures becoming mandatory and for whom?
All proposals are built to scale, starting from the largest investment opportunities with plans to include a larger part of the market. As of now, all publicly listed companies in the 35 markets are mandated to disclose climate-related information alongside their annual financial disclosures.
Regulated Institutions of the National Financial System of Segments 1 to 4 are hard at work already to disclose climate information. These segments categorize to banks in proportion with their share in Brazil’s GDP. As the regulation is today, other industries are not immediately affected. Nevertheless, companies with regulated institutions as investors may have to disclose some climate information indirectly.
Disclosures are implemented in two phases:
- 2021 – Governance, strategy, risk management
- 2022, December – Emissions metrics and targets
For the first reporting year, financial institutions in Canada are required to disclose climate-related information. As explicitly stated, these institutions will need to collect and assess information on climate risks and emissions from their clients as well. At a later stage, the mandate will scale to federal pension plans and the government has committed to roll out the mandate “across a broad spectrum of the Canadian Economy”.
The gradual phase-in will begin in 2024.
🇭🇰 Hong Kong
Financial institutions as well as companies listed on the HKEX will have to disclose the financial impact of climate change on their business in 2025.
For the food industry, this includes Budweiser APAC, beverage company Vitasoy, and meat producer Yurun Group, owner of the brand Haroulian.
Mandatory sustainability disclosures in the EU will begin in 2024 and will scale up in 3 stages
2024, Stage 1: The mandate is in effect for companies and their subsidiaries already submitting non-financial reports. This includes approximately 11,700 publicly listed companies with over 500 employees reporting or non-European companies with a turnover of over €150 million for 2023.
2025, Stage 2: Large companies and their subsidiaries that are currently not subjected to non-financial reports will be required to disclose sustainability and climate information for the fiscal year 2024
2026, Stage 3: Listed SMEs will have to disclose a sustainability report to the EU. SMEs will have the transitional option to opt-out until 2028.
🇳🇿 New Zealand
Large publicly listed companies, insurers, banks, and investment managers will be subject to mandatory climate-related disclosures. While specific industries are not included in the legislation, they may be indirectly affected to provide climate information as investment managers will need to disclose on a fund-to-fund basis.
The legislation will come in effect in 2023 and is open to consultation until September 26th, 2022. In later stages, the government will also require independent assurance on the calculation of greenhouse gas emissions.
For the financial year 2023, listed issuers in 3 sectors are called to disclose climate-related information in their sustainability reporting: Finance, Energy as well as Food, agriculture and forest products – fruit giant Del Monte included.
Two additional sectors, materials & buildings and transportation will be required to report for the financial year 2024.
In line with the EU legislation, the mandate for climate-disclosure in Switzerland concerns publicly listed companies with over 500 employees, over CHF 20 million in assets or over CHF 40 million in turnover. The following parameters include food giant Nestlé, cocoa producer Barry Callebaut, dairy producer Emmi, and meat manufacturer Bell Food Group. Any company that fails to comply may be issued a fine of CHF 100,000.
Companies will need to start reporting in 2024 for the financial year 2023.
The UK is already hard at work with disclosures. Publicly listed companies and private companies with over £500 million in turnover and over 500 employees should already start thinking about the report as it must be filed in 2023 for the financial year 2022. The plan is that the legislation comes in effect across the economy by 2025.
The American proposal is rolled out in phases.
- Large accelerated filers1 are called to disclose their climate-related information in 2024 for the financial year 2023
- Accelerated2 and non-accelerated3 filers will disclose in 2025 for the financial year 2024
- Smaller reporting companies4 will disclose in 2026 for the financial year 2025
All companies will receive an additional year from their first reporting year to disclose Scope 3 emissions.
1 Large accelerated filers: Companies with an aggregate worldwide public float of $700 million or more.
2 Accelerated filers: Companies with a public float of $75 million or more, but less than $250 million in annual revenue; a public float of more than $250 million, but less than $100 million in annual revenue.
3 Non-accelerated filers: Companies that fall under neither 1, 2 nor 4
4 Smaller reporting filers: Companies with public float of less than $250 million with annual revenue of less than $100 million and either (1) no public float or (2) a public float of less than $700 million.
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What information should I include in the climate-related disclosure report?
As history taught us, all legislations and proposals derive from the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD). Climate-related disclosures must cover 4 key areas as suggested by the TCFD. These 4 areas are:
- Board oversight on climate-related risks and opportunities
- Management’s involvement in assessing and managing climate-related risks and opportunities
- Short-, medium-, and long-term risks and opportunities
- The impact of climate risks and opportunities on your business, strategy, and financial planning
- A scenario-based resilience analysis
- Process for identifying risks
- Process for managing risks
- The integration of both these processes in your overall risk management
Metrics & Targets
- Metrics used to assess risks and opportunities and how they fall in line with your strategy (i.e. climate KPIs)
- Scope 1, 2, and Scope 3* quantified emissions
- Targets for risk and opportunity management
- Performance against those targets
*What about Scope 3 emissions?
The challenge of collecting supply chain data and calculating Scope 3 emissions is acknowledged in every single proposal and legislation bill. However, the importance of the emissions along the supply chain is equally in the spotlight. In most cases, companies either receive extra buffer time to report on Scope 3 emissions, are mandated to report Scope 3 only under certain parameters, or Scope 3 remains optional to report.
Dig into the market of your choice below to find out what applies to you.
In plain terms? Companies need to answer –first internally and then externally:
Based on how climate change may unfold in the next few years…
This is what the mandates have in common. However, depending on the market, some directives are more granular, and some are at the moment vaguer. For the latter, filers need to hold on tight until the reporting guidelines are better refined. What should you expect from specific markets?
As laid out on the 2022 budget, Canadian financial institutions –currently the mandated filers– may omit climate-related opportunities. They need only disclose climate-related risks and emissions, but they need to extend beyond their operations and report climate-related risks and emissions for their clients as well.
We can certainly expect broader news regarding climate-related disclosures in Canada as the budget committed additionally to two deliveries:
- Broadening the spectrum of the economy disclosures apply to, and
- Providing 8 million Canadian dollars to the International Sustainability Standards Board, a key player in defining reporting standards in the near future, newly officed in Montreal.
🇭🇰 Hong Kong
The Hong Kong legislation, accompanied by a comprehensive guidance document, makes these additional parameters mandatory
- Board and management accountability and knowledge on climate-related issues
- Classification of risks into Physical (impact from climate patterns) and Transition (market changes and adaptation)
- Scenario-based analysis with a clear scope and boundaries
- Risk prioritization based on a combination of likelihood, impact, adaptability, and recovery
- Selection of metrics based on the following principles: decision-useful, understandable, verifiable, objective, and comparable.
- Definition of targets relative to a baseline and including time horizon
The European Union extends to reporting scope to sustainability overall and the Commission pledged to adopt a set of reporting standards by June 30th 2023 – just in time for the first reporting phase.
The sustainability aggregation means that Governance, Strategy, and Risk management will cover all categories: economic, environmental, and social sustainability. The content of the report follows the TCFD guidelines with the further specification of:
- Physical and transitional risks
- Supply chain resilience
- Scenario-based adaptation plans
- Level and scope of emissions with removals as an addition
- Plans to reduce absolute emissions in all 3 Scopes.
In addition, while the bill underlines the importance of the same level of assurance for both the sustainability and financial reporting, it recognizes the challenge and
- commits to publishing guidelines for reasonable assurance by 2028,
- allows limited assurance for sustainable reporting until then,
- Tackles the issue of limited assurance by requiring reporting companies to obtain assurance from independent, external auditors and broadening to scope of firms who can audit sustainability reporting.
Emissions and climate-related disclosures are highlighted on the European disclosure agenda. Reporting companies need to get rather granular with their climate strategy including:
- Layout of the business model to achieve the transition to carbon neutrality by 2050
- Absolute GHG emission reduction targets for 2030 and 2050, the progress towards these targets, and the relation of the targets to scientific evidence
- Value chain operations and targets, actions to identify the impact of the value chain and minimize it.
It's important to note that this is optional for the first 3 years, however if a company chooses to emit Scope 3 information, it also needs to disclose the planned efforts to obtain it.
The Singaporean report follows the TCFD guidelines with a few clarification additions. Reporters will be asked to:
- Disclose the level of assurance (limited, reasonable)
- Pay extra attention that their data is accurate and complete
- Directors or managers undergo sustainability training
The content of the Switzerland report is explicitly modeled after the European Union guidelines for reporting, with the same standardization directive of climate-related reporting following the TCFD guidelines. This modeling implies that Switzerland relies on the conclusions of EU regarding the level of assurance and the set of reporting standards.
The UK has extensive clarifications on the climate-related disclosures, including comprehensive guidelines. To start with, the climate-related disclosures will be part of the existing strategic report.
When it comes to the content of the report, the how and what are additions to the TCFD guidelines in focus:
- Filers need to address how risks and opportunities
- are identified, assessed, managed, and integrated into the company’s overall risk management, as TCFD suggests,
- Related to the company’s operations, over what time period, and with what impact
- How the company’s climate targets address the identified risks and opportunities and over what time horizon
- The company’s KPIs and metrics to assess progress against the specified targets, as well as the calculations on which the KPIs and metrics are based on.
- Filers must include a scenario-based resilience analysis
The guidelines also specify that companies need to disclose all Scopes with Scope 3 being optional for the first reporting year.
Finally, the guidelines provide additional details for how to manage data gaps in emissions metrics.
- Companies must identify consistent data gaps and prioritize engagement to ensure data quality improvement
- If a company has incomplete data, it may use modeling for the majority in CO2e
- Greenhouse gas emissions must be disclosed in absolute terms and in CO2e
- Greenhouse gas emissions must be disclosed in terms of intensity in climate footprints
Following the TCFD and GHG protocol guidelines, starting 2024, American companies will need to disclose the following:
- Strategic, financial, and operational climate impact including
- methodology, data sources, and assumptions
- Their material impact
- How these risks affect the company’s strategy, business model, and outlook
- How they are identified assessed, managed, and integrated in the company’s overall risk management
- Governance and risk management
- Including responsibilities and expertise per role and the related processes.
- Physical, regulatory, technological and reputational climate-related risks
- GHG emissions on Scope 1 and 2 as well as Scope 3 if it is material* or if the company has a Scope 3 target
- In absolute terms
- In terms of intensity
- Per unit of revenue ($)
- Per unit of product
- Plus, the methodology and breakdown per greenhouse gas
- Targets and transition plans, including
- Offsets – The bill specifies that if offsetting is classified as a primary reduction strategy, the company is flagged by investors as “high risk”. The use of offsets needs to be outlined in detail and the quality of the offsets must be included in the risk identification
- Renewable credits
- Low-carbon product revenue
- Potential internal carbon price – If the company has an internal carbon prices, it needs to specify:
- The measurement boundaries for CO2e
- The price
- The change of price over time, and
- The rationale
*Materiality is not the easiest concept to grasp if one is not already familiar with it but in very broad terms and in this case, it refers to aspects that are relative to climate change –i.e. either affect or are affected– and significant. The bill defines “material” as follows:
"As defined by the Commission and consistent with Supreme Court precedent, a matter is material if there is a substantial likelihood that a reasonable investor would consider it important when determining whether to buy or sell securities or how to vote."
The expectations are set and the trajectory of climate-related disclosures is clearer the entire economy – a climate strategy and consequentially disclosures are becoming a must for every company. The positive response to this is evident in most consultation documents as is also a sense of unease in the market. However it is also apparent that markets expect climate strategies to be a process and a work in progress. Not knowing where to start or where to pick up your climate roadmap from should not send you in a loop. It is prescribed in the manual and you don’t need to build the expertise yourself – the expertise exists and you are encouraged to ask for help!
This is a good place to start! Download our guide, find your square 1 and your next steps to be climate disclosure-ready.
In it for the legal talk? Look through the bills and proposals for every market:
🇧🇷 Brazil – Banco Central Do Brasil
🇨🇦 Canada – National Budget 2022
🇭🇰 Hong Kong – Hong Kong Exchanges and Clearing Limited
🇪🇺 EU – The European Parliament and the Council of the European Union
🇳🇿 New Zealand – New Zealand Parliament
🇸🇬 Singapore – SGX Group
🇨🇭 Switzerland – Swiss Federal Council
🇬🇧 UK – HM Government
🇺🇸 USA – Securities and Exchange Commission