Framework
The TCFD framework
The Task Force on Climate-related Financial Disclosures was set up by the Financial Stability Board so investors, lenders, and insurers could see how climate-related issues affect an organization’s financial position. The recommendations are built to sit in the mainstream financial filing, not in a separate sustainability brochure.
Where the framework stands
- Established
- 2015, by the Financial Stability Board
- Recommendations
- June 2017
- Implementation annex
- Implementing guidance updated October 2021
- Metrics guidance
- Guidance on Metrics, Targets, and Transition Plans, October 2021
The Task Force published its final status report in 2023 and disbanded. The FSB asked the IFRS Foundation to monitor progress. IFRS S2 Climate-related Disclosures incorporates the TCFD recommendations, so the structure below is still the one companies use to get from operations to a climate-related financial filing.
Who should disclose, and on what basis
Who
- Organizations with public debt or equity are the ones the Task Force asks to implement the recommendations, so investors, lenders, and insurance underwriters can use the information.
- Because climate-related issues are not limited to listed companies, the Task Force encourages every other organization to implement them as well.
- Asset managers and asset owners — including public and private pension plans, insurance companies, endowments, and foundations — should implement the recommendations.
Materiality
- Governance and risk-management disclosures give the context in which financial results are produced. They are part of the recommended set so readers can see whether climate-related issues are actually overseen and managed.
- Strategy, and metrics and targets, are subject to a materiality assessment, made the same way the organization judges other risks for its financial filing.
- The 2021 annex asks organizations to disclose Scope 1 and Scope 2 greenhouse gas emissions independent of that materiality assessment. Scope 3 stays subject to materiality; the Task Force still encourages disclosure.
- The Task Force warns organizations not to decide too quickly that climate-related issues are immaterial just because some of them are longer term.
Where it is published
- The recommended home for the disclosure is the mainstream financial filing, at least once a year, under controls comparable to financial reporting.
- If a climate-related event has a material financial impact between filings, the disclosure should be updated.
Four pillars, eleven disclosures
The four recommendations describe how an organization operates: how it is governed, how climate changes its strategy and financial plan, how it manages the risks, and which metrics and targets it uses. The eleven disclosures are the specific information those recommendations ask for. They are meant to be read together.
Governance
Disclose the organization’s governance around climate-related risks and opportunities.
Users of the financial filing want to know whether climate-related issues receive board and management attention, or whether they sit in a side report nobody governs.
Disclosure a
Describe the board’s oversight of climate-related risks and opportunities.
- How, and how often, the board or a board committee (audit, risk, or another) is informed about climate-related issues.
- Whether the board considers those issues when it reviews strategy, major plans, risk-management policies, annual budgets, and business plans, and when it sets performance objectives, oversees major capital expenditure, or weighs acquisitions and divestitures.
- How the board monitors progress against climate-related goals and targets.
Disclosure b
Describe management’s role in assessing and managing climate-related risks and opportunities.
- Whether climate-related responsibilities are assigned to specific management positions or committees, and whether those roles report to the board.
- The organizational structure that supports the work.
- How management is informed about climate-related issues and how it monitors them.
- For the energy, transportation, materials and buildings, and agriculture groups, whether performance metrics for the board and management, including remuneration, take climate-related risks and opportunities into account.
Strategy
Disclose the actual and potential impacts of climate-related risks and opportunities on the organization’s businesses, strategy, and financial planning where such information is material.
This is the pillar that connects climate to the business: what the issues are, what they do to the financial plan, and whether the strategy holds up under more than one climate future.
Disclosure a
Describe the climate-related risks and opportunities the organization has identified over the short, medium, and long term.
- The organization defines its own short, medium, and long term, taking into account the useful life of its assets or infrastructure. Climate-related issues often show up over the medium and longer terms.
- Name the specific issues on each horizon that could have a material financial impact, and say whether each risk is a transition risk or a physical risk.
- Describe the process used to decide which risks and opportunities could be financially material.
- Where it helps, split the description by sector and geography. Use the transition, physical, and opportunity classifications.
Disclosure b
Describe the impact of climate-related risks and opportunities on the organization’s businesses, strategy, and financial planning.
- Impact on businesses and strategy: products and services, supply chain and value chain, adaptation and mitigation, investment in research and development, and operations.
- Impact on financial planning: operating costs and revenues, capital expenditures and capital allocation, acquisitions and divestments, and access to capital.
- How the issues feed the financial plan, and the time periods used.
- For the four non-financial groups, consider revenues, expenditures, assets and liabilities, and capital.
Disclosure c
Describe the resilience of the organization’s strategy, taking into consideration different climate-related scenarios, including a 2°C or lower scenario.
- Say which scenarios were used, including one at 2°C or lower, and how they differ from a publicly available scenario if they were adjusted.
- Describe critical assumptions, time frames, and what the scenarios imply for the organization’s performance and strategy.
- Insurance companies with substantial exposure to weather-related perils should consider a scenario warmer than 2°C for physical effects, in addition to a 2°C scenario.
Risk management
Disclose how the organization identifies, assesses, and manages climate-related risks.
Strategy says what the issues are. Risk management says how they are found, judged, and handled, and whether that work is part of ordinary enterprise risk management or a parallel exercise.
Disclosure a
Describe the organization’s processes for identifying and assessing climate-related risks.
- How the organization decides the relative significance of climate-related risks versus other risks.
- Whether it considers existing and emerging regulation, and factors such as the materiality of a risk, its likelihood, and the size of the impact.
- Banks should consider describing climate-related risks in lending and other intermediary activities, including significant concentrations of credit exposure to carbon-related assets, and framing them in ordinary banking categories such as credit, market, liquidity, and operational risk.
Disclosure b
Describe the organization’s processes for managing climate-related risks.
- The processes for managing risks, including how the organization decides to mitigate, transfer, accept, or control them.
- Insurance companies should describe the tools used to manage climate-related risk in product development and pricing, and the range of climate-related events considered.
Disclosure c
Describe how processes for identifying, assessing, and managing climate-related risks are integrated into the organization’s overall risk management.
- How climate-related processes sit inside the enterprise risk management system, rather than beside it.
Metrics and targets
Disclose the metrics and targets used to assess and manage relevant climate-related risks and opportunities where such information is material.
Metrics make the strategy and risk process checkable. Targets say what the organization is trying to change, over which horizon, and whether it is getting there.
Disclosure a
Disclose the metrics used by the organization to assess climate-related risks and opportunities in line with its strategy and risk management process.
- Metrics should line up with the risks and opportunities the organization actually describes under strategy.
- Include historical periods so a reader can see a trend, and the methodology where it is not obvious.
- Where relevant, cover water, energy, land use, and waste, an internal carbon price, and revenue from low-carbon products and services.
- The 2021 guidance asks all organizations to consider seven cross-industry metric categories, for current, historical, and forward-looking periods.
Disclosure b
Disclose Scope 1, Scope 2, and, if appropriate, Scope 3 greenhouse gas (GHG) emissions, and the related risks.
- Scope 1 is direct emissions. Scope 2 is indirect emissions from purchased electricity, heat, or steam. Scope 3 is other indirect emissions in the value chain, upstream and downstream.
- Since the 2021 annex, Scope 1 and Scope 2 should be disclosed independent of a materiality assessment. Scope 3 remains subject to materiality, and the Task Force encourages organizations to disclose it.
- Relate the inventory to risk: which emissions sit under a carbon price, which depend on sold products, and which sit in the supply chain.
Disclosure c
Describe the targets used by the organization to manage climate-related risks and opportunities and performance against targets.
- A target is a level, threshold, quantity, or qualitative goal over a defined time horizon.
- Targets should be informed by strategy and risk management, quantified where possible, and supported by interim targets when the goal is medium or long term.
- Explain the base year, the boundary, the methodology, and any use of offsets. The 2021 guidance suggests reviewing targets at least every five years.
- A transition plan is not a fifth pillar. It is the actionable path for meeting the targets, under the same governance as the strategy.
Seven principles for effective disclosure
The principles sit under the recommendations. They are how the Task Force describes a disclosure that a user of the financial filing can actually use. They can pull against each other — a methodology change can help comparability and hurt consistency — and the organization has to balance them without burying the reader.
- 1
Disclosures should present relevant information
Write about the effect of climate-related issues on markets, strategy, financial statements, and cash flows. Cut what is immaterial, and avoid boilerplate. If a topic the market cares about is not significant, say so, so the reader can see it was considered.
- 2
Disclosures should be specific and complete
Cover the exposure, its nature and size, and the governance, strategy, risk process, and performance around it. Include history and a forward look, and state the definitions, boundaries, and assumptions behind numbers.
- 3
Disclosures should be clear, balanced, and understandable
A specialist and a generalist should both be able to find the point. Balance qualitative and quantitative information, and describe risks and opportunities without slanting either.
- 4
Disclosures should be consistent over time
Keep formats, language, and metrics stable enough for comparison across periods. When a method changes, explain the change.
- 5
Disclosures should be comparable among organizations within a sector, industry, or portfolio
Give enough detail, in the financial filing, that a reader can compare strategy, activity, risk, and performance with peers.
- 6
Disclosures should be reliable, verifiable, and objective
Base disclosures on objective data and stated methods. Forward-looking statements use judgment; the assumptions should be traceable. The same internal governance used for financial reporting should apply. Independent assurance is not required by the recommendations.
- 7
Disclosures should be provided on a timely basis
Publish at least annually in the mainstream financial report. If a climate-related event has a material financial impact, update the disclosure rather than waiting for the next annual cycle.
How the framework is applied
The recommendations do not publish a separate numbered procedure. They do impose an order. Governance has to exist. Risks and opportunities have to be identified and classified before they can be judged material, tested in scenarios, managed, measured, and disclosed. SUSC-TCFD uses that order when it reads a company.
Step 1
Put governance in place
Decide how the board oversees climate-related risks and opportunities and who in management assesses and manages them. The rest of the framework is not credible if nobody owns it.
Step 2
Identify risks and opportunities
Look across the company and its value chain. Classify each climate-related risk as transition (policy and legal, technology, market, reputation) or physical (acute or chronic), and each opportunity as resource efficiency, energy source, products and services, markets, or resilience. Place them on the short, medium, and long term horizons the organization defines.
Step 3
Judge which issues could be financially material
Use the same materiality judgment the organization uses for other risks in its financial filing. Trace effects through revenues, expenditures, assets and liabilities, and capital and financing. Do not drop an issue only because it sits on a longer horizon.
Step 4
Test the strategy against scenarios
Describe how the strategy holds up under different climate-related scenarios, including a 2°C or lower scenario. State the scenarios, the assumptions, the time frames, and the implications.
Step 5
Integrate the work into risk management
Describe how climate-related risks are identified, assessed, and then mitigated, transferred, accepted, or controlled, and how that process sits inside overall risk management.
Step 6
Select metrics and set targets
Choose metrics that match the strategy and the risk process, including Scope 1 and Scope 2 greenhouse gas emissions and, where appropriate, Scope 3. Set targets over defined horizons, track performance, and describe the transition plan that would meet them.
Step 7
Disclose in the mainstream financial filing
Publish the eleven recommended disclosures in the mainstream financial filing, at least annually, and apply the seven principles. The four pillars are meant to be read together: governance oversees what strategy describes, risk management runs the process, and metrics check it.