The story so far

In 2017, the Taskforce on Climate-Related Financial Disclosures (TCFD)’s recommendations initiated a wave of change for climate-related reporting. Since then, steady progress has been made to integrate climate-related disclosures across corporate reporting and within the breadth of sustainability disclosure frameworks, driving transparent ESG reporting worldwide.  

As such, it came as a shock when the TCFD announced it was disbanding in late 2023, leaving companies wondering what the next steps should be. However, as we will explore below, the work of the TCFD remains extremely relevant; climate-related financial reporting is here to stay. 

The Taskforce on Climate-Related Financial Disclosures

The TCFD was established to support informed, efficient capital allocation decisions and direct resources towards the transition to a lower carbon economy. Since its 2017 release, it has been the foremost source for recommendations designed to enhance the consistency, quantity and quality of climate-related financial information reported. The TCFD’s recommendations help companies understand and communicate the resilience of their strategy against a range of potential climatic futures, considering both the physical and transitional risks and opportunities that may arise. Additional guidance relating to implementation, metrics and targets, scenario analysis, and more have become key resources for businesses that integrate the TCFD’s recommendations.  

The impact has been a steady uptake in climate-related financial reporting, but much work remains to be achieved. In October 2023, the TCFD released its sixth and final status report, describing both the progress made to date and the gaps that still need to be filled.¹ The report disclosed that between 2020 and 2022, the percentage of companies reporting on climate-related risks or opportunities, board oversight and climate-related targets increased by 26, 25 and 24 percentage points, respectively. However, only 4% of public companies disclosed in line with all 11 TCFD disclosures. 

The International Sustainability Standards Board

The TCFD’s recommendations were key resources used in developing the International Sustainability Standards Board’s sustainability standards, IFRS S1 and S2, released in June 2023.² The IFRS S2 standard focuses entirely on climate-related disclosures. Combined with the requirements of IFRS S1, relating to general sustainability-related financial disclosures, these new IFRS standards provide a holistic framework for investor-focused sustainability reporting. The standards are considered a culmination of the TCFD’s work, and the IFRS has therefore been asked to take over the monitoring of corporate progress on climate-related financial reporting. 

What’s next

Although the TCFD is no longer monitoring the progress of climate-related financial reporting, its mandate continues to gain momentum. Climate-related reporting has been adopted into regulations spanning the globe. To date, many of these have applied solely to publicly traded companies; of the 121 stock exchanges monitored through the UN Sustainable Stock Exchanges Initiative, 31 have TCFD-aligned disclosure requirements.³ However, requirements for large private entities and small and medium enterprises are growing too. Below are a subset of the jurisdictions embracing climate disclosures within their regulations. 

IFRS

Since their release in 2023, jurisdictions worldwide have committed to adopting the IFRS S1 and S2 standards or aligning their bespoke reporting frameworks to the IFRS. Countries including Brazil, Costa Rica, Sri Lanka, Nigeria and Turkey have already committed to adopting or using the IFRS standards. Due to its recent release, countries including Canada, Japan, and Singapore remain in consultation to ensure the frameworks suit their regional needs.⁴  

United Kingdom

Since 2022, the UK has mandated climate-related financial disclosures within the annual reporting of public companies, large private companies, and LLPs.⁵ Although premium-listed companies had already been required to provide TCFD-aligned disclosures since 2021, this guidance expanded the requirements to a larger subset of businesses. The UK climate-related financial disclosures (CFD) were adapted from the TCFD but modified for inclusion in UK legislation. 

The UK has also committed to adopting IFRS S1 and S2 by releasing its UK Sustainability Disclosure Standards (SDS). The UK SDS are projected to be released in July 2024. How the UK SDS will interact with or replace the existing UK CFD is unknown, but we expect this will be clarified upon its release. 

EU

Released in 2021 and adopted in 2023, the Corporate Sustainability Reporting Directive (CSRD) has defined the requirements for sustainability reporting for EU businesses through its European Sustainability Reporting Standards (ESRS).⁶ Like the IFRS standards, the ESRS takes a holistic approach to sustainability; climate change is one of five environmental standards and is considered mandatory for companies in scope. Unlike the IFRS standards, the CSRD’s focus goes beyond financial materiality. Double materiality is a central requirement of the CSRD, considering both impact materiality and financial materiality. Reporting requirements under the CSRD are staggered, with initial reporting beginning in 2025 for fiscal years effective 1 January 2024 onwards. 

United States

In March 2024, the US Securities and Exchange Commission (SEC) adopted new rules for publicly reporting companies, requiring disclosures about climate-related risks and greenhouse gas (GHG) emissions beginning in 2025 and 2026, respectively.⁷ The SEC’s climate disclosures lack the ambition of other jurisdictions but represent a necessary step forward from the second largest GHG emitter worldwide. 

As the above illustrates, this is an evolving space, and its complexity continues to increase; no two jurisdictions have the same approach. For those responsible for risk management, sustainability, and financial reporting at their businesses, understanding the applicable regulations in their respective jurisdictions will be critical to maintaining compliance in the years to come. Furthermore, going beyond compliance to embed climate risk management across the business can create resilience amidst an uncertain future and no two jurisdictions have the same approach. Simply Sustainable is well-versed in the complexities of regulations worldwide, and we support our clients in going beyond compliance and raising the bar.

Please contact our team to see how we can support with your climate-related risk analysis. 

Author: Andrea Gamble, Senior Consultant, Simply Sustainable

1. TCFD 2023 Status Report
2. IFRS – ISSB issues inaugural global sustainability disclosure standards
3. TCFD Activities Database | Sustainable Stock Exchanges (sseinitiative.org)
4. 2024 ISSB progress and consultantion update
5. Climate-related financial disclosures for companies and limited liability partnerships (LLPs) – GOV.UK (www.gov.uk)
6. The Commission adopts the European Sustainability Reporting Standards – European Commission (europa.eu)