TCFD Status Report 2021 – what you need to know

On Monday 18 October 2021, the Financial Stability Board’s (FSB) Task Force on Climate-related Financial Disclosures (TCFD) released its latest ‘2021 Status Report’ (the ‘Report’) along with two long-awaited annexes and guidance on developing metrics, targets and transition plans. Here, we aim to summarise what we consider to be the key messages and areas of focus for the upcoming reporting cycle.

The timing of release for the report and associated annex and guidance document will make it difficult to incorporate significant changes for December year-end reporters, but nonetheless it offers helpful guidance that can feed into plans for the next reporting cycle. The timing also presents an opportunity for companies with already advanced disclosures, to further improve in line with the new guidance and demonstrate climate leadership during the upcoming reporting season.

Adoption acceleration

It’s clear the momentum behind TCFD is building fast. Since last year’s update the number of organisations endorsing TCFD has risen by 70% and the list of supportive governments, central banks, and regulators makes for impressive reading. TCFD recommendations are being incorporated into official disclosure requirements, including the UK, EU, Switzerland, New Zealand and Hong Kong, marking a real step change in commitment.

With so many countries, organisations and regulators in support of the TCFD, it’s likely that adoption will continue to accelerate in the foreseeable future, especially with the backdrop of the COP26 conference in Glasgow this month where it is anticipated that the International Financial Reporting Standards (IFRS) Foundation will launch the much anticipated International Sustainability Standards Board (ISSB). The TCFD is on the IFRSF’s technical readiness working group (TRWG) and the prototype climate standard they have been working on reflects the TCFD pillars. In the UK, we are on the path to mandatory reporting under ISSB standards as confirmed in the Greening Finance report issued by UK government last week. The increasing quality and uptake of TCFD disclosure is therefore helping to build capacity and readiness for these and other future global sustainability standards.

First and foremost, it’s important to note that the TCFD’s newly released guidance documents do not change the 11 recommended disclosures, however they do provide some fundamental updates and clarifications, along with additional guidance that all organisations should be aware of; not least because the TCFD does require disclosures to take account of supplementary guidance.

Good… but could be better

This seems to be the over-riding message in the report. This won’t come as any surprise for those involved either as preparers or readers of TCFD disclosures; the quality and quantity of disclosure has improved considerably over the last 12 months, but TCFD identify that there is room for improvement.

Having reviewed 1,651 public companies, the TCFD in its report, presents a comprehensive summary of trends and areas for focus going forwards, including:

1. Governance: Governance remains the least disclosed recommendation overall (the two governance disclosures are the 2^nd and 3^rd least disclosed), despite the TCFD’s recommendation to disclose governance regardless of materiality, as well as bodies such as the UN Principles for Responsible Investment (PRI) requiring it of signatories.
2. Strategy: Companies are more likely to disclose information on climate risks and opportunities than any other recommended disclosure. While the disclosure of strategy resilience under different scenarios is still the least reported disclosure within the Strategy pillar, there is a promising 8% increase in the number of companies who reported on this in 2021 compared to 2018. Still, a total of only 13% of companies have successfully disclosed against this recommendation in 2021.
3. Risk management: Disclosures of the processes for identifying, assessing, and managing climate related risks, and the integration with the company’s overall risk management approach remain low, with only around 30% of companies making TCFD aligned disclosures on this.
4. Metrics and targets: The disclosures of metrics and targets remain strong (albeit the tendency is still for a focus on Greenhouse Gas (GHG) emissions figures only); however, the growth has slowed down, with only a 4% increase from 2019 to 2020. Companies are encouraged to go beyond reporting simply on GHG emissions and this is addressed at least partly, by the publication of the Metrics, Targets and Transition Plans guidance document. The TCFD has given clearer guidance on disclosure of Scope 3 emissions by clarifying that if they represent >40% of a business’s total footprint then Scope 3 emissions should be disclosed. It remains to be seen how this will play out, as many preparers don’t yet understand or measure their entire Scope 3 footprint. Scope 1 and 2 emissions reporting are now recommended for all preparers, irrespective of materiality.

Emphasis on financial impact disclosure

The report once again emphasises the need for quantified disclosures that provide insight into climate-related financial performance and position. Investors and other readers of TCFD disclosures are wanting to understand the cost of climate-related transition or exposure, including for example, expenditure or capital investment deployed towards climate-related issues, and that needed to meet targets for addressing climate issues (often disclosed in a transition plan), as well as the link between qualitative disclosures and their financial impact.

Early adopters have tended to begin with qualitative analysis based on strategy and related financial plans which can be translated into estimates of financial impact. Going forwards, there is a need for quantified assessment of financial impact associated with both transition and physical risks, supported by scenario analysis, and considering both risks and opportunities. Though in our experience there remain significant challenges to financial forecasting such as how to isolate climate effects from other effects. Both quantitative and improved qualitative information can allow for enhanced insight into resilience of a company’s strategies, and ultimately therefore the future actions required to mitigate risks and capitalise on opportunities.

One of the barriers often described by preparers, as highlighted in the report, is the lack of availability of robust and consistent data needed to fully assess these risks and opportunities. The TCFD have therefore made the following suggestions from a preparer’s point of view:

• Enhanced data gathering strategies are critical to enable effective assessment of financial impacts;
• Allocating sufficient resources to financial impact assessment helps timely development of decision-useful information;
• Overcoming institutional siloes enables more effective collaboration and alignment on assumptions and methodologies used for estimating financial impacts; and
• Once financial impacts have been estimated, approval from relevant internal stakeholders, including legal teams, is generally required when making public disclosures.

The rise of transition plans

The disclosure of a transition plan has always formed part of the strategy pillar of TCFD, however they have not, until now been a common feature of disclosures. The report and newly published guidance are more explicit in addressing the need for disclosure of plans to transition to a low-carbon economy. For example, how will regulation and policy constraints on emissions, increased carbon taxes, and changes in market demand affect a particular organisation between now and 2050 in terms of risks and opportunities? There is a growing trend for Net Zero transition targets and plans, partly in response to COP26 and the UK Government’s plan to transition the entire economy by 2050 as well as growing investor and stakeholder demand.

For all reporting companies and especially those for whom transition impacts are of greater relevance compared to physical impacts, this is an important clarification.

Introduction of cross-industry climate-related metric categories

The report and associated annexe and guidance documents have published seven metric categories which are considered to be generally applicable to all organisations. These should not be considered in addition to the Metrics and Targets pillar, rather, their value is that they allow for consistent and comparable disclosure on climate-related risks and opportunities, the holy grail for investors and other stakeholders. The cross-industry metric categories are:

• GHG emissions (absolute Scope 1, 2 and 3 emissions and emissions intensity (MT of CO2e)).
• Transition risks (amount or percentage of assets or business activities vulnerable to transition risks).
• Physical risks (amount or percentage of assets or business activities vulnerable to physical risks).
• Climate-related opportunities (amount or percentage of revenue, assets, or other business activities aligned with climate-related opportunities).
• Capital deployment (amount of capital expenditure, financing, or investment deployed toward climate-related risks and opportunities (currency amount)).
• Internal carbon price (price on each ton of GHG emissions used internally by an organisation (currency amount per MT of CO2e)).
• Remuneration (proportion of executive management remuneration linked to climate considerations (percentage, weighting, description or currency amount)).

With the exception of Scope 1, 2 and 3 GHG emissions as well as appropriate intensity metrics, the inclusion of metrics and targets in TCFD disclosures should always be as a result of a materiality review i.e. which metrics help a company to respond to and understand their key climate risks and opportunities. The TCFD has also provided some sector-specific metrics for financial services firms, which (for FS firms) should be considered alongside these cross-industry metrics, but all in the context of what is material to the company’s activities.

Conclusion

The TCFD have reported that the quality and quantity of disclosure has improved considerably over the last 12 months, helping to build capacity and readiness for future global sustainability standards, but that there is still room for improvement. The report and associated annex and guidance documents have raised the bar significantly for companies disclosing against the TCFD framework, enabling organisations to further progress their climate disclosure journey and also highlighting how quickly preparers need to evolve to keep up with peers and the wider market. Early movers, especially those with year ends falling in mid to late 2022 can view this as a great opportunity to use the newly raised bar, to really get ahead of the curve and improve disclosures in line with the latest guidance. Once this happens, it can be assumed that investor and stakeholder expectations will advance further still, with additional scrutiny to be expected for organisations that do not invest in continual improvement of their approach to climate risk and disclosures against TCFD.