Category: disclosure

Expectations for corporates and financial institutions on climate risk analysis and disclosure continue to evolve and grow

Expectations for corporates and financial institutions on climate risk analysis and disclosure continue to evolve and grow

By Robin Hamaker-Taylor


Despite the grave conditions many economies are facing due to 2020’s rolling COVID-19-induced lockdowns, expectations for corporates and financial institutions on climate risk analysis and disclosure have not slowed. In fact, climate risk and reporting mandates only appear to be increasing.

2021 will see a continued focus on climate risk analysis in the private sector, in the lead up to the 26th Conference of the Parties to the UN Framework Convention on Climate Change (UNFCCC). COP 26 will be held here in the UK and is set to have a strong focus on private sector finance. Mark Carney, special finance advisor to the UK Prime Minister has made clear that the objective for the private finance work for COP 26, is to “ensure that every financial decision takes climate change into account”. Finance is also one of five campaigns of the UK COP 26 presidency.

As 2020 comes to a close, this article summarises major developments expectations for corporates and financial institutions on climate risk analysis and disclosure in the last quarter of this year. Other reviews of progress in this space – and there has been a lot – are available here and here.

US Federal Reserve, Treasury Department, and the Securities and Exchange Commission have all indicated in various ways that they are on-board with their counterparts in other countries, who have long since been making progress toward mandating climate risk analysis and disclosure. (e.g., the dozen or more central banks and supervisors around the world who are undertaking climate-related stress testing.). This is no doubt in part due to President-Elect Joe Biden, who has made climate one of four priority areas in his Administration. The US is also set to re-join the Paris Agreement, and the expectation is that the US Federal Reserve will soon join the Network (of Central Banks and Supervisors) on Greening the Financial System (NGFS) (more information is available here and here.)

Importantly, there is ample evidence that President Biden and his Administration may not need congressional approval for any further climate-related laws or regulations, which would not be likely, given the Republican stronghold on the US Senate. There is, however, a growing call by some Republicans to take climate action, which represents an important shift.

There are now 75 central banks covering 60% of global emissions who are members of the NGFS. Members are already taking action, with central banks now requiring climate stress testing, e.g., Bank of England.

To celebrate its three year anniversary in December 2020, the NGFS published two reports on 15th December:

  • A progress report on sustainable and responsible investment practices by central banks; and
  • The findings of a survey on monetary policy operations and climate change.

Both are available here

The guide explains how the ECB expects banks to prudently manage and transparently disclose such risks under current prudential rules. The ECB will now follow up with banks in two concrete steps. In early 2021 it will ask banks to conduct a self-assessment in light of the supervisory expectations outlined in the guide and to draw up action plans on that basis. The ECB will then benchmark the banks’ self-assessments and plans, and challenge them in the supervisory dialogue. In 2022 it will conduct a full supervisory review of banks’ practices and take concrete follow-up measures where needed.

A new alliance between 30 international asset managers with $9tn in assets under management (AUM) has formed, setting net-zero emissions targets. The group of asset managers pledges to support investing aligned with net-zero emissions target by 2050 or sooner. More asset managers are due to join in the coming months. More information is available here.

This new initiative complements the Net-Zero Asset Owner Alliance, an international group of 33 institutional investors delivering on a bold commitment to transition investment portfolios to net-zero GHG emissions by 2050. More information is available here.

  • The International Financial Reporting Standards (IFRS) Foundation released a Consultation Paper on global sustainability standards, including climate risk reporting, open for public comment until 31 December 2020. More information is available here.
  • The TCFD is holding a public consultation on decision-useful, forward-looking metrics to be disclosed by financial institutions. The Task Force’s 90-day public consultation solicits input on forward-looking climate-related metrics for the financial sector. The consultation asks questions about the usefulness and challenges of such metrics and what may be necessary to enhance their comparability, transparency, and rigour. The consultation is open for public comment until 27 January 2021. More information is available here.
  • The UK’s Financial Conduct Authority (FCA) announced that it is going to be consulting on rules in early 2021, which would introduce TCFD obligations for asset managers, life insurers and pension providers by 2022. These extended rules would build the FCA’s new requirement that by 1 January 2021, premium listed companies will be required to disclose how climate change affects their business, consistent with TCFD, or explain why not.
  • The European Insurance and Occupational Pensions Authority (EIOPA) published a consultation on the use of climate change risk scenarios in the Own Risk and Solvency Assessment (ORSA) in the form of a draft supervisory Opinion. EIOPA invites stakeholders to provide their views on the consultation paper by filling in the survey by 5 January 2021. More information is available here.

Many banks, asset managers, asset owners, insurers, and at very least listed companies are already getting out ahead of the curve of emerging climate risk reporting. Acclimatise has now been acquired by WillisTowersWatson, where we offer joined up services on both physical and transition risk-related analysis. Please contact Robin Hamaker-Taylor (r.hamaker-taylor at acclimatise.uk.com).

Landmark legal case sees Australia’s biggest superannuation fund commit to strong action on climate change after 25-year old Brisbane man sues

Landmark legal case sees Australia’s biggest superannuation fund commit to strong action on climate change after 25-year old Brisbane man sues

By Will Bugler

Australia’s largest super fund, Rest, has agreed to test its investment strategies against various climate change scenarios and commit to net-zero emissions for its investments by 2050, after a legal case brought by a 25-year-old man from Brisbane. Mark McVeigh sued Rest in 2018 for failing to provide details on how it will minimise the risk of climate change. The landmark case represents the first time a superannuation fund has been sued for failing to consider climate change.

Mr McVeigh alleged Rest had breached Australia’s Superannuation Industry Act and the Corporations Act, after it failed to provide him with information on how it was managing the risks of climate change. These risks include physical climate risks that threaten Rest’s investments, and also transition risks which arise from the decarbonisation of the global economy.

Climate change is a ‘material, direct and current financial risk’

Australian law requires trustees of super funds to act with “care, sill and diligence to act in the best interest of members – including managing material risks to its investment portfolio”. In its settlement Rest agreed that its trustees have a duty to manage the financial risks of climate change.

In Rest’s statement about the settlement it said: “The superannuation industry is a cornerstone of the Australian economy — an economy that is exposed to the financial, physical and transition impacts associated with climate change.” and went on to emphasise that “climate change is a material, direct and current financial risk to the superannuation fund”.

Rest also agreed to take immediate action by testing its investment strategies against various climate change scenarios, publicly disclose all its holdings, and advocate for companies it invests in to comply with the goals of the Paris Agreement.

Mr McVeigh’s lawyer, David Barnden, head of Equity Generation Lawyers, said the case still sets an important precedent globally. “This outcome should represent a significant shift in the market’s willingness to tackle climate risk—a shift which should set a clear precedent for the industry in Australia, and also pension funds around the world,” he said. Mr Barnden is also representing 23-year-old Katta O’Donnell, who is suing the Australian Government for failing to disclose the risks that climate change could have on government bonds.

Growing momentum behind regulation

The latest cases in Australia are part of a global movement towards stricter regulation governing the financial risks posed by climate change (see Acclimatise’s timeline charting the rise of climate law). In 2015, for example, France introduced laws mandating climate disclosure for institutional investors and asset managers and in 2017 the Financial Stability Board’s Taskforce on Climate-related Financial Disclosure published recommendations for corporate climate disclosures. In 2019, National Instrument 51-102 Continuous Disclosure Obligations set out new requirements for firms reporting in Canada to disclose material risks in their Annual Information Form.

The implication of landmark cases such as the Rest settlement, is that super funds, pension funds, banks and other investors will increasingly require companies to understand and manage their climate risks. Earlier this year, Acclimatise worked Working with Asia-Pacific’s largest law firm, MinterEllison to produce a primer on physical climate risk aimed at Non-Executive Directors. The primer was published by Chapter Zero a global voluntary programme that connects and supports Non-Executive Directors to improve oversight and action on the issue of climate change.

Download the primer here.


Cover photo by Sippakorn, on Pixabay.
Australian corporate regulator updates guidance on climate-related disclosure

Australian corporate regulator updates guidance on climate-related disclosure

Earlier this month the Australian corporate regulator, ASIC published updates to clarify the application of its existing regulatory guidance to the disclosure of climate change-related risks and opportunities.

ASIC reviewed its guidance following the recommendations of a Senate Economics References Committee report on Carbon Risk and the Government’s response which encouraged ASIC to consider whether its high-level guidance on disclosure remained appropriate.

While ASIC’s review found that its existing, principles-based regulatory guidance remains fit for purpose, to help stakeholders to comply with their disclosure obligations, the organisation has updated its guidance to, amongst other things:

  • incorporate the types of climate change risk developed by the G20 Financial Stability Board’s Taskforce on Climate-Related Financial Disclosures (TCFD) into its list of examples of common risks that may need to be disclosed;
  • highlight climate change as a systemic risk that could impact an entity’s financial prospects for future years and that may need to be disclosed in an operating and financial review (OFR);
  • reinforce that disclosures made outside the OFR (such as under the voluntary TCFD framework or in a sustainability report) should not be inconsistent with disclosures made in the OFR; and
  • make a minor update to INFO 203: Impairment of non-financial assets: Materials for directors to highlight climate change and other risks that may be relevant in determining key assumptions that underly impairment calculations.

The guidance has also been updated to make clear that in ASIC’s view, the risk of directors being found liable for a misleading or deceptive forward-looking statement in an OFR is minimal provided the statements are based on the best available evidence at the time, have a reasonable basis and there is ongoing compliance with the continuous disclosure obligations when events overtake the relevant statement made in the OFR.

ASIC’s review of regulatory guidance follows last year’s publication of ASIC Report 593: Climate Risk Disclosure by Australia’s Listed Companies targeting listed companies, their directors and advisors. High-level recommendations set out in REP 593 included to:

  • adopt a probative and proactive approach to emerging risks, including climate risk;
  • develop and maintain strong and effective corporate governance which helps in identifying, assessing and managing risk;
  • comply with the law where it requires disclosure of material risks; and
  • disclose meaningful and useful climate risk-related information to investors –the voluntary framework developed by the TCFD has emerged as the preferred standard in this regard and ASIC strongly encourages listed companies with material exposure to climate change to consider reporting voluntarily under the TCFD framework.

ASIC commissioner John Price said, ‘Climate change is an area which ASIC continues to focus on. The updates to our regulatory guidance, together with the publication last year of Report 593, round out ASIC’s response to the Senate Report on Carbon Risk. Our updates will help stakeholders to comply with their disclosure obligations in prospectuses and the operating and financial review for listed companies’.

ASIC welcomes the continuing emergence of the TCFD framework as the preferred market standard, both here in Australia and internationally, for voluntary climate change-related disclosures. ASIC considers this to be a positive development and we again strongly encourage listed companies with material exposure to climate change to consider reporting voluntarily under the TCFD framework.

‘While disclosure is critical, it is but one aspect of prudent corporate governance practices in connection with the mitigation of legal risks. Directors should be able to demonstrate that they have met their legal obligations in consideringmanaging and disclosing all material risks that may affect their companies. This includes any risks arising from climate change, be they physical or transitional risks.’ Mr Price said.

In the coming year, ASIC will conduct surveillances of climate change-related disclosure practices by selected listed companies. ASIC will also continue to participate in the Council of Financial Regulators’ working group on climate risk and participate in discussions with industry and other stakeholders on these issues.


Read ASICS updated regulations here:

Acclimatise becomes an official signatory of TCFD

Acclimatise becomes an official signatory of TCFD

Acclimatise today became an official signatory of the Financial Sustainability Board’s (FSB) Taskforce on Climate-Related Financial Disclosure (TCFD). The initiative, established by Mark Carney and Michael Bloomberg, has been central in providing momentum for climate change action in the financial services industry.

Acclimatise has worked with UNEP FI and the world’s leading banks to help consider how they might implement the TCFD recommendations. Through its work, Acclimatise has helped develop methodologies for assessing physical climate risk to loan portfolios and is a leading advisor on climate risk and opportunity to the financial services industry.

The company’s supporting statement under the TCFD reads:

“Aligning strategies to stabilise our financial and climatic systems is vital. Corporate and financial institutions have a significant role to play in this. The incorporation of TCFD recommendations in their governance systems and decision-making processes is in fact key if we are to ensure a sustainable and climate compatible future, particularly in light of unmet governmental climate targets. We are proud to support this initiative and we will continue to excel at developing methodologies and metrics to help corporates and financial services organisations to identify, quantify, and disclose physical climate risks and opportunities.”


For more information about Acclimatise’s work on climate risk and financial services click here.


Image: World Economic Forum: Mark Carney, Governor of the Bank of England. World Economic Forum, Davos, Switzerland. CC by 2.0.

Embracing uncertainty: How disclosing uncertain information on climate risk can reduce legal liability exposure

Embracing uncertainty: How disclosing uncertain information on climate risk can reduce legal liability exposure

By Marcela Scarpellini, right. based on science UG

As climate related damages increase, the need to allocate funds and apportion blame will inevitably follow. In this context, the mechanisms used for determining responsibility are likely to become, to say the least, very creative.

Pressure for proactive climate action and better response is mounting thanks to legislation and regulation, litigation, shareholder demands, citizens calling for more action, carbon taxes and concrete mitigation and adaptation plans.

The status and intent of current regulations relating to climate change and the legal infrastructure that is expected to support or deter the transition to a low carbon economy, provide a good indication of the stringency and certainty of the measures that will follow.

After Bank of England Governor Mark Carney’s famous warning in his 2015 speech regarding the threat climate change posed to our financial systems, financial institutions and governments started to wake up to the issue. This meant paying attention to – and developing an understanding of – how climate risks might play out and affect businesses future profitability and the stability of the wider financial system. In response, the G20’s Financial Stability Board established the Task Force on Climate-Related Disclosures (TCFD).

Point in time: Disclosure

The TCFD‘s purpose is to provide corporates and financial institutions with a framework for climate risk disclosure in two key respects. First, with regard to the analysis of the physical and transition risks and opportunities they may face due to climate change. Second, with regard to the development of appropriate strategies to respond to the consequences of those risks materialising.

This initiative, which already has 513 official supporters across businesses, advisory firms, and financial institutions, is a voluntary framework. The main political intention behind it – in combination with the EU Directive on Non-Financial Disclosures, EU Shareholders Directive and other upcoming EU financial regulation – is to foster transparency by requiring corporates and financial institutions to disclose information on material impacts of the physical and policy risks (transition risks) connected with climate change.

The TCFD recommendations are just a first step. Increasing transparency is a means to an end, not an end in itself: boilerplate and vague disclosures will not cut it. The intention of climate risk disclosures is to provide legislators with a broad understanding of the current state of investments and business bets into a certain world, in order to come up with evidence-based legislation that actually has a chance of reshaping our economies.

In this context, corporates and financial institutions have started to work out the best ways to generate relevant disclosures. The first attempts to generate this information using the TCFD framework have been released, but there is still a long way to go.

Hot topic: scenario analysis

One of the challenges of applying the TCFD framework has been the use of scenario analysis. Scenario-analyses are forward-looking tools intended to allow users to imagine how a range of possible futures could look, the risks and opportunities entailed in those different futures and get its users to pin down how their companies would be affected if any of those futures materialized. The overarching purpose is to enable firms to develop strategic and resilient business plans to incorporate envisioned or possible changes.

A concrete way in which companies make use of scenario analyses is by using them to understand how their capital requirements might be impacted under a range of plausible scenarios. Using scenario analyses, companies can peer into the future and build resilient responses to a world in which extreme events and their financial impacts are no longer sporadic but recurrent.

Scenario analysis is a time and capacity consuming challenge. Despite this, many companies, particularly within the oil & gas sector, have been using these tools for some time, and companies in other sectors are starting to do so too.

Another significant hurdle for companies performing scenario analysis stems from having to disclose the information generated. Many businesses are wary of this since, it is suggested, the information generated by scenario analysis is just hypothetical, which could, in turn, be misconstrued as a fraudulent, deceptive or incorrect disclosure, potentially opening the door to liability exposure. However, in reality, this constitutes a narrow view of the story.

Understanding risk

Properly understood, scenario-analysis is a risk assessment tool, so the information derived from it is the same in nature as information relating to other risks that might affect a company. Risks are hypothetical by nature and gain validity when substantiated through evidence and justification.

What it takes to reduce disclosure-related liabilities is a thorough and well-presented substantiation of the information provided, with clear and precautionary wording regarding how this information ought to be interpreted and construed.

A stream of forward-looking legal experts, within the Commonwealth Climate and Law Initiative, are of the opinion that disclosing forward-looking information in line with the TCFD Recommendations might, on the contrary, reduce liability exposure. Their claim is justified by understanding the core intentions of the TCFD’s recommendations, namely transparency and accountability. Therefore, firms able to demonstrate that they are acting to understand and manage climate risk will be acknowledged for that in the light of corporate responsibilities such as due diligence and good corporate governance. In understanding the purpose of disclosure, firms are allowed to make mistakes, though they are not allowed to be fraudulent, deceptive and manipulative about the future in order to ensure certain business interests.

As more firms get on board with the TCFD recommendations, using them as guidelines for disclosure, it is likely that they become reference points and that national laws start to be interpreted in light of the most advanced practices. In jurisdictions such as the UK, where an objective test applies to determine the extent and manner in which directors have exercised their duty of care and due diligence, this determination is likely to be done on the basis of what others in the industry are doing. If and when TCFD becomes best-practice, this is likely to become the yardstick against which these determinations will be made[1].

Good practice to reduce liability

Scenario-analysis remains a beneficial tool, despite the fact that it is still becoming an established best practice and mandated by law. To reduce firms’ concerns around liability associated with scenario-analysis, and to encourage them to start using it and disclosing climate risk information prudently, a series of recommendations follows:

  • Use proper cautionary language.
  • Use a variety of scenarios, at least three would be advisable.
  • Place all scenarios within the same section and under the same fonts in your disclosure as to avoid that any be interpreted as being favoured.
  • Use multiple sources for data and narratives and seek insights from new sources.
  • Use current data and justify your choice of providers.
  • Ensure your scenarios reflect the variance (climate, political, social, regulatory) and are relevant to the entirety of the company´s operations.
  • Use information derived from scenarios in order to justify likelihood and not infallible certainty.
  • Not disclosing any forward-looking information under the false pretence that it might make your company liable is a greater risk than disclosing uncertain information.
  • If you are not sure of how to go about it, hire consulting services to guide you along the way.

Further reading:

https://www.right-basedonscience.de/2017/08/04/better-safe-than-sorry/

Marcela Scarpellini studied law at the Universidad Católica Andrés Bello in Caracas (Venezuela) and has an LL.M. from the University of Stockholm (Sweden) in the field of environmental law. Within right.based on science (“right.”) she works at providing the legal context upon which right.´s X-Degree Compatibility (“XDC”) model and other metrics are developed.

right. based on science is a data provider founded in August 2016, which measures a single economic entity’s contribution, be that of e.g. a company or a lending project, to manmade climate change. With a team of experts with backgrounds in law, science, economics, psychology and mathematics, right. is devoted to the development of the XDC Model, which calculates science-based climate metrics on the basis of latest climate research and regulatory requirements, in order to deduct an entity’s X-Degree Compatibility.


[1] Concerns misplaced: Will compliance with the TCFD recommendations really expose companies and directors to liability risk? Alexia Staker, Alice Garton & Sarah Barker. Commonwealth and climate law initiative.


Photo by Krissana Porto on Unsplash

PRI makes TCFD-style climate disclosures mandatory in 2020 reporting cycle

PRI makes TCFD-style climate disclosures mandatory in 2020 reporting cycle

By Robin Hamaker-Taylor

In February 2019, the Principles for Responsible Investing (PRI) initiative, announced it will make several of its climate risk indicators mandatory for PRI signatories. PRI requires signatories to annually report various environmental, social, and governance (ESG) metrics via the PRI reporting tool. In 2018, the PRI introduced TCFD-aligned indicators to its Reporting Framework, including reporting on four indicators of climate risks: governance, strategy, risk management, and metrics and targets. Until now, this reporting has been voluntary and disclose.  

Which indicators will be mandatory?

Starting in 2020, the PRI’s strategy and governance (SG) indicators will be mandatory to report, though it will remain voluntary to disclose responses publicly. These indicators include:

  • SG 01 CC: outline overall approach to climate-related risks;
  • SG 07 CC: provide overview of those in the organisation that have oversight, accountability and/or management responsibilities for climate-related issues; and
  • SG 13 CC: outline how strategic risks and opportunities are analysed.

PRI may require further climate risk reporting in the future

PRI currently has over 2,300 signatories, includingasset owners, investment managers, and service providers that collectively manage over $83 trillion in assets. This change in their reporting framework will greatly increase the amount of climate-related reporting within in its framework by signatories. This move also indicates the direction of travel regarding reporting on climate risks: the PRI has indicated that the remaining PRI climate risk indicators will stay voluntary with a view to becoming mandatory as good practice develops.

The climate change indicators of the overall Reporting Framework can be found here [pdf].

What is the PRI?

The PRI is a non-profit independent organisation that works to understand the investment implications of environmental, social and governance (ESG) factors. The PRI supports its international network of investor signatories in incorporating these factors into their investment and ownership decisions. The organisation acts in the long-term interests of its signatories, of the financial markets and economies in which they operate and ultimately of the environment and society as a whole.

What are the Principles for Responsible Investment?

The six Principles for Responsible Investment are a voluntary and aspirational set of investment principles that offer a menu of possible actions for incorporating ESG issues into investment practice:

Principle 1: We will incorporate ESG issues into investment analysis and decision-making processes.

Principle 2: We will be active owners and incorporate ESG issues into our ownership policies and practices.

Principle 3: We will seek appropriate disclosure on ESG issues by the entities in which we invest.

Principle 4: We will promote acceptance and implementation of the Principles within the investment industry.

Principle 5: We will work together to enhance our effectiveness in implementing the Principles. Principle 6: We will each report on our activities and progress towards implementing the Principles


Photo by Sean Pollock on Unsplash

PRA and FCA establish a joint Climate Financial Risk Forum

PRA and FCA establish a joint Climate Financial Risk Forum

By Robin Hamaker-Taylor

The Financial Conduct Authority (FCA) and the Prudential Regulatory Authority (PRA) of the Bank of England have established the Climate Financial Risk Forum (CFRF) in early March 2019. The Forum is comprised of firms from across the financial system. The fill list of 17 current members is as follows:

  • Banks: BNP Paribas; HSBC; JP Morgan; RBS; Yorkshire Building Society
  • Insurers: Aviva; Legal & General; Lloyd’s of London; RSA Insurance Group; Zurich
  • Asset Managers: Blackrock; Hermes; Invesco; Schroders; Standard Life Aberdeen
  • Others: Greening Finance Initiative; London Stock Exchange Group

Four working groups have been set up, which will develop guidance in each of the following areas: risk management, scenario analysis, disclosure, and innovation. Working groups will allow wider membership, including academics and other members of industry, in order to allow them to draw on expertise as necessary.  

Bank of England Governor, Mark Carney, explained the reasoning behind the establishment of the CFRF during his 21st March speech at the European Commission High-Level Conference. The Prudential regulation Authority (PRA) and the Financial Conduct Authority (FCA) established the Forum as it recognised the need for capacity building within the finance industry and need to develop best practices.

Regulators understand that despite the progress of firms toward climate-related risk management, there is still work to do with regards to their strategic approach to minimise these risks, including scenario analysis. The Forum aims to allow progress in this area by “developing practical tools and approaches to address climate-related financial risks,” according to a statement to the press. The Forum will meet three times per year and will report back to executives of both the PRA and FCA. Each of the four working groups will be chaired by a member of the Forum and will meet more frequently than the CFRF, reporting back at each CFRF meeting.


Photo by Colton Jones on Unsplash

Bank of England Governor indicates new climate risk rules are imminent

Bank of England Governor indicates new climate risk rules are imminent

By Robin Hamaker-Taylor

On 21st March, 2019, Bank of England Governor Mark Carney gave a speech at the European Commission High-Level Conference in Brussels, where he indicated that new rules from the UK’s financial regulators on climate risk are imminent.

Carney’s speech gives several indications as to the content of the upcoming PRA supervisory statement (SS) on banks’ and insurers’ approaches to managing the financial risks from climate change. The PRA’s SS will apply to banks, insurers and investment firms and will set out the PRA’s expectations regarding firms’ approaches to managing the financial risks from climate change, including with respect to: 

  • Governance, where firms will be expected to embed fully the consideration of climate risks into governance frameworks, including at board level, and assign responsibility for oversight of these risks to specific senior role holders;
  • Risk management, where firms will need to consider climate change in line with their board-approved risk appetites;
  • The regular use of scenario analysis to test strategic resilience; and
  • Developing and maintaining an appropriate disclosure of climate risks.

There have been important advances in both the supply and demand for climate reporting following the release of the final TCFD recommendations in 2017; support from both finance actors and companies has been resounding. Yet actual action on disclosure is lacking. According to Carney, financial implications are often not yet disclosed, and where they are, they are made in multiple reports making comparisons harder. Disclosures also vary considerably by industry and region.

Carney set out a vision for climate disclosure and made the case for regulatory action relating to it, stating that “in the future, disclosure will move into the mainstream, and it is reasonable to expect that more authorities will mandate it.” The role of financial regulators was delineated as well, suggesting that it is not their role to drive the transition to a low-carbon and resilient economy. Instead, financial regulators such as the PRA need to smooth the flow of investment into green technologies and encourage firms to plan over longer time horizons than normal; they ultimately operate within the climate policy frameworks that governments set.

A call was made for financial institutions to take a more strategic approach to climate, which Carney suggested requires scenario analysis; firms will need to consider scenario analysis as part of their assessments of the impact of climate risks on their balance sheet and broader business strategy. Specifically, Carney suggested scenarios should be:

  • Comprehensive, rigorous and challenging;
  • Transparent: the assumptions and methodologies in the models – such as the assumed global temperature rise, the energy mix, or whether the transition happens smoothly or abruptly – should allow for comparisons and external challenge; and  
  • Scenarios should be implemented consistently across the business, linking identification of risks and opportunities to both strategy and disclosure.

Scenario developments will be assisted by the PRA and FCA joint Climate Financial Risk Forum, which will work with industry to review tools and metrics, for the publication of reference scenarios and standard assumptions.

Finally, Carney explains that supervisors will require climate-related stress testing that links ‘high-level data-driven narratives on the evolution of physical and transition risks to quantitative metrics to measure the impact on the financial system.’ In conducting these stress tests, financial institutions would aim to:

  • Consider whether, across the financial system, financing flows are consistent with an orderly transition to the climate outcome set out in the Paris agreement. These long-term scenarios can facilitate discussions between firms and their clients about possible risks across different sectors and geographies; and
  • Consider whether the financial system would be resilient to shorter-term shocks – including a climate “Minsky moment” when climate risks materialise suddenly. 

The Bank of England will also work closely with colleagues in the Network for Greening the Financial System (NGFS) to develop a small number of high-level scenarios. Following the issuance of the draft supervisory statement and subsequent consultation in October 2018-January 2019, the final supervisory statement will be released in mid-April 2019.


Cover photo by Robert Bye on Unsplash.

Event summary: Advancing TCFD guidance on physical climate risks and opportunities

Event summary: Advancing TCFD guidance on physical climate risks and opportunities

On 31st May 2018, the European Bank for Reconstruction and Development (EBRD), in partnership with the Global Centre of Excellence on Climate Adaptation (GCECA), held the conference Advancing TCFD Guidance on Physical Climate Risks and Opportunities. The EBRD welcomed the opportunity to host this event as a supporter of the Task Force on Climate-related Financial Disclosures (TCFD). The EBRD is the first multilateral development bank to officially join over 280 supporter organisations in becoming a supporter of the TCFD and of its recommendations on including climate-related information – both risks and opportunities – in financial disclosures.

The event launched the EBRD-GCECA report that builds on the TCFD recommendations and presents practical guidance for corporates looking to disclose their risks and opportunities with regard to physical climate impacts. This report is the result of a six-month dialogue between industry-led working groups composed of representatives of corporates, financial institutions and regulators.

In light of the report’s 18 recommendations, the conference facilitated discussion and reflections on the relevance of physical climate-related risks and opportunities to financial markets. Three panels, gathering corporations, banks, regulators, asset managers, rating agencies, and others were convened to discuss the practical implementation of physical climate-related disclosure metrics by corporations.

Download the flagship conference report and other conference materials.

Event summary

The conference was opened by Josué Tanaka, EBRD Managing Director, and Pierre Heilbronn, EBRD Vice President, who welcomed the audience and set the scene by highlighting EBRD’s long-standing commitment to financing the transition to a low-carbon and climate-resilient economy.

Henk Reinders, speaking on behalf of the Dutch Central Bank DNB, stressed the role that regulators must play regarding physical risk. Curtis Ravenel, Global Head of Sustainable Business and Finance at Bloomberg, presented TCFD recommendations related to physical climate risks and opportunities, and the challenges related to their eventual identification on balance sheets. Roelfien Kuijpers, Head of Responsible Investments and Strategic Relationships at DWS, encouraged investors to address physical climate disclosures through shareholder engagement to support a “just transition” that addresses the equity implications of repricing exposed assets. She also called on regulators to support this effort by requiring sector-based climate-related disclosure protocols and helping develop a new climate analytics industry.

The first panel ‘Advancing TCFD recommendations on physical climate risks and opportunities’ gathered the three chairs of the working groups who presented the EBRD-GCECA report’s findings. Murray Birt, DWS, stressed the importance of assessing climate risks over longer timeframes of assets and instruments, disclosing information on the location of critical facilities, providing detailed information on the financial impacts of recent extreme weather events and weather variability on facilities and value chains, as well as forecasting financial impacts of future physical climate risks. Simon Connell, Standard Chartered Bank, focused on opportunities, defined as increasing the resilience of existing assets to current and future physical climate risks, along with identifying new markets and product demand that may emerge as a result of shifting climate patterns. He highlighted the importance of identifying and disclosing physical climate-related opportunities at the segment level as well as wider co-benefits from climate resilience investments. Greg Lowe, Aon, explained that physical climate scenarios constitute a critical tool to ensure better capital allocation, as they provide useful views of plausible futures. As such, the analysis of physical climate scenarios requires an exploration of different GHG pathways and their impacts on climate and weather systems. Finally, Craig Davies, EBRD, presented the Bank’s efforts to support market transformation toward climate resilient economies by mobilising wider market action through developing new ways of sharing market information about physical climate change impacts.

The second panel ‘Managing physical climate risks and opportunities – experience to date’ brought together physical climate risk disclosure preparer and user perspectives, as Maersk, Citi, Bank of America Merrill Lynch, and Moody’s shared their experiences on the management of physical climate risks and opportunities. While their experiences to date varied, panellists all welcomed the TCFD framework as a means to bring physical climate risks and opportunities under deeper scrutiny in their organisations. The need for engagement emerged as an important theme from the panel. The interdependencies between financial institutions and corporates, and in turn between corporates and their supply chains, was said to require new relationships and engagement at multiple levels – both externally and internally. Another takeaway was the desire to strike the right balance between disclosures that are useful for financial institutions and for corporates’ strategic purposes. In these early stages of physical climate risk analysis and disclosure, what is truly ‘decision useful information’ is yet to be determined, though panellists maintained that the new EBRD-GCECA report goes a long way to provide guidance on this issue.

The third panel ‘How to include physical climate risks and opportunities in financial disclosure’ capped the event, bringing together financial regulators and government actors, as well as the voluntary disclosure perspective. Jean Boissinot, French Treasury, noted that while there is now room for further regulation on physical climate risk disclosures, regulators need to think carefully about it to ensure it results in information that is complementary, enabling information flows, and is aligned with other initiatives such as the TCFD. Mark Cornelius, Bank of England, discussed the Bank’s current information gathering initiative in the insurance and banking sectors and ensured the Bank and its regulatory functions are highly supportive of initiatives like TCFD that are by and for the market. Simon Messenger, Climate Disclosure Standards Board, commented that stronger regulation can help standardise physical climate-related disclosures. Antoine Begasse, European Commission, agreed that regulators have a role to play, but that regulation needs to be fit for purpose to generate comparable information from industry. In this light, the Commission is launching a public consultation on strengthening reporting requirements, and developing a taxonomy of adaptation (and mitigation) finance including metrics to be used in climate-related disclosures, to be integrated into regulation and to support climate-related reporting.

Closing remarks were provided by Roald Lapperre, Deputy Minister at the Netherlands Ministry of Infrastructure and Water Management, Curtis Ravenel of Bloomberg, and Josué Tanaka of EBRD. The host concluded that the disclosure process is happening, and that TCFD and the emerging EU sustainable finance approach provide useful frameworks. It was also recognised the tension between the need for consistency and the need for sector-specific metrics. Ultimately, there is high demand to translate awareness of physical climate risks and opportunities into metrics that can influence the decisions made by businesses and financial institutions.

Key Takeaways

  • Physical climate-related disclosures are part of an iterative process and constitute a learning exercise for corporations and financial institutions. They will need to include both quantitative and qualitative elements, to avoid the publication of commercially-sensitive data related to the provision of detailed climate risk information.
  • Disclosures and scenario analysis are not an end per se. The analysis of physical climate risks and opportunities should be about strategic analysis as much as it should be about disclosure.
  • There is a general need for better and more granular data provision on corporates’ facilities, their importance and their location. The information can come from universities and analytics firms as well as from better engagement between investors and clients.
  • Better disclosures of physical climate risks and opportunities will arise from a cooperative working process to ensure learning and awareness-raising between the following actors: banks (involving all teams including credit risk, industry teams and sustainability departments), investors asking questions to companies in which they invest, along with the latter assessing their whole value chain.
  • The long-term horizon is relevant for physical climate scenario analysis, as due diligence processes usually entail longer timeframes, and relationships with clients extend over the longer term.
  • The development of guidance and protocols on physical climate-related disclosures should be pursued. They should support market participants in increasing their climate risk awareness and the focus includes both acute and chronic physical climate risks. Regulators need to ensure that any new climate disclosure regulation results in information that is complementary, enabling information flows, and aligned with other initiatives such as TCFD.
  • MDBs have a role to play in ensuring that emerging economies are not left behind as new regulatory and market practices on climate-related disclosures emerge. They can support businesses and financial institutions in emerging markets to adopt and keep up with evolving best international practices on climate-related disclosures, for example through supporting skills transfer, capacity building and policy dialogue, as well as exploring the development of new financing instruments that include e.g. the appropriate use of concessionality and calibrated loan pricing.
  • The TCFD provides a useful framework for the analysis of climate risk and opportunities. Together with the EU sustainable finance approach, it is the push many corporates need to get started on their journey to uncover physical climate risks and opportunities. Growing awareness on physical climate risks and opportunities needs to translate into the development and use of robust metrics that inform better market decisions and the more rational allocation of capital in the light of information about physical climate change impacts.

Download the flagship conference report and other conference materials.


More on the initiative

The initiative was hosted by EBRD which also funds its technical secretariat. The GCECA provided a secondment to the technical secretariat. The technical secretariat was facilitated by Acclimatise, a specialist consulting company advising major corporates and financial institutions on climate risk and resilience, and by Four Twenty Seven, a firm providing market intelligence on the economics of climate change.

Participants involved in the expert working groups included: Agence Française de Développement, Allianz, APG Asset Management, AON, the Bank of England, Barclays, Blackrock, Bloomberg, BNP Paribas, Citi, Danone, the Dutch National Bank, DWS Deutsche AM, European Investment Bank, Lightsmith Group, Lloyds, Maersk, Meridiam Infrastructure, Moody’s, S&P Global Ratings, Shell, Siemens, Standard Chartered, USS and Zurich Alternative Asset Management.


Information about further updates and events will be posted on the website www.physicalclimaterisk.com. If you require further information about any of these activities, please contact physicalclimaterisk@ebrd.com.

The event attracted significant media attention and was reported by the New York Times, Reuters and Environmental Finance.

Major new report on physical climate risk to financial sector released

Major new report on physical climate risk to financial sector released

Financial institutions should undertake comprehensive climate risk assessments and disclose material exposure to climate hazards such as flood risk, water stress, extreme heat, storms, and sea level rise, according to a new report released today by the European Bank for Reconstruction and Development. The report focusses specifically on physical climate risks to the financial sector and calls for firms to integrate climate impacts into investment decisions.

The report, published today at a conference hosted by EBRD and the Global Centre for Excellence on Climate Adaptation (GCECA), presents guidance and recommendations developed over the last year by industry-led working groups that include representatives from AFD Allianz, APG, Aon, Bank of England, Barclays, BlackRock, Bloomberg, BNP Paribas, Citi, Danone, DNB, DWS, The Lightsmith Group, Lloyds, Maersk, Meridiam Infrastructure, Moody’s, the OECD, S&P Global, Shell, Siemens, Standard Chartered, USS and Zurich Asset Management. An expert team led, by Acclimatise and Four Twenty Seven served as the secretariat to the working groups throughout the course of the meetings.

The report, Advancing TCFD guidance on physical climate risks and opportunities”, also recommends that firms investigate benefits from investing in resilience and opportunities to provide new products and services in response to market shifts. In order to do this, the report calls for organisations to use scenario analysis and incorporate long-term climate uncertainties into business planning and strategic decisions.

The report and the conference, respond to calls for strengthening financial stability in the face of climate change uncertainties, through the disclosure of climate-related market information.  This was the core message, delivered last summer, of the Task Force on Climate-Related Financial Disclosures (TCFD), initiated by the Financial Stability Board (FSB) in response to a call from the G20 economies.


The report is available on a dedicated website www.physicalclimaterisk.com, as are opinion pieces from heads of working groups and other leading experts.

Download the report’s executive summary here.

Cover photo by Ryan L.C. Quan/Wikimedia Commons (CC BY-SA 3.0): Looking downtown from Riverfront Ave in Calgary, during the Alberta floods 2013.