The TCFD is the Task Force on Climate-related Financial Disclosures. The Task Force was convened by the Financial Stability Board to produce a common global framework for companies to report how climate change will affect their business.
The TCFD has significant support from businesses, investors, government bodies, asset managers, pension funds, insurers, banks, ratings agencies and accounting firms.
To help investors and wider stakeholders understand how companies are managing climate-related financial risks, the TCFD recommends that companies should make disclosures across four key areas, often referred to as the four pillars. The four pillars are set out below and companies are recommended to disclose:
- GOVERNANCE - the organisation’s governance around climate-related risks and opportunities.
- STRATEGY - the actual and potential impacts of climate-related risks and opportunities on the organisation’s businesses, strategy, and financial planning where such information is material.
- RISK MANAGEMENT - how the organisation identifies, assesses, and manages climate-related risks.
- METRICS AND TARGETS - the metrics and targets used to assess and manage relevant climate-related risks and opportunities where such information is material.
The recommendations are designed to be applicable to any company in the world. By taking a financial focus they are designed to support more effective decision-making by both investors and companies. The TCFD recommends that such disclosures be included in mainstream filings.
Interaction with UK company law reporting requirements
For accounting periods beginning on or after 6 April 2022, mandatory climate-related financial disclosure regulations apply for certain companies and LLPs. Non-binding guidance to help companies and LLPs better understand the requirements has been issued by the Department for Business, Energy and Industrial Strategy (BEIS). A summary of the key aspects of the regulations is set out below.
The new Climate-related Financial Disclosure regulations apply to:
- All UK companies that are currently required to produce a Non-Financial Information Statement. This includes UK companies that have more than 500 employees and are either traded companies, banking companies or insurance companies.
- UK registered companies with securities admitted to AIM with more than 500 employees.
- UK registered companies which are not included in the above categories that have more than 500 employees and a turnover of more than £500m.
- LLPs which have more than 500 employees and a turnover of more than £500m.
Where relevant, the disclosures are required at a group level. This means the reporting requirements and scope thresholds apply on a consolidated basis. For example, where a company was a parent company at any time within the financial year, if in that year a group headed by it had more than 500 employees and an aggregate turnover of more that £500m net, then the parent company would be within the scope of the requirements.
For companies, the information is required as part of the existing Non-Financial Information (NFI) Statement (to be renamed the Non-Financial and Sustainability Information Statement or NFSI Statement) within the Strategic Report.
Not all companies within scope were required to produce a NFI Statement. Such companies are now required to produce a NFSI Statement for the first time but are only required to disclose the new climate-related financial disclosures elements.
For LLPs, the information is also required in a NFSI Statement within the Strategic Report. However, for LLPs not required to produce a Strategic Report (which is likely to be the majority of LLPs) the information should instead be included in the Energy and Carbon Report.
The regulations require in-scope companies and LLPs to provide a description of:
- the entity’s governance arrangements in relation to assessing and managing climate-related risks and opportunities;
- how the entity identifies, assesses and manages climate-related risks and opportunities;
- how processes for identifying, assessing and managing climate-related risks are integrated into the entity’s overall risk management process;
- the principal climate-related risks and opportunities arising in connection with the entity’s operations;
- the time periods by reference to which those risks and opportunities are assessed;
- the actual and potential impacts of the principal climate-related risks and opportunities on the entity’s business model and strategy;
- the analysis of the resilience of the entity’s business model and strategy, taking into consideration different climate related scenarios;
- the targets used by the entity to manage climate-related risks and to realise climate-related opportunities and of performance against those targets; and
- the key performance indicators (KPIs) used to assess progress against targets used to manage climate-related risks and realise climate-related opportunities and of the calculations on which those KPIs are based.
Certain reporting requirements, for example those relating to strategy, metrics and targets, may be omitted in full or in part if the directors (or members in the case of LLPs) conclude that, taking account of the nature of the business and how it is conducted, the information is not necessary for an understanding of the entity’s business. If this is the case, directors/members need to provide a clear and reasonable explanation for not providing the information.
These regulations came into effect on 6 April 2022 and are applicable for accounting periods that begin on or after this date – so for December year ends, 2023 are the first reporting period.
Interaction with the Financial Conduct Authority Listing Rules
The FCA listing rules require premium-listed and standard-listed companies to make disclosures under the TCFD framework. Such companies are required to include a statement in their annual report stating whether they have made disclosures consistent with the TCFD framework on a ‘comply or explain’ basis. For premium-listed companies this requirement has been in effective since 1 January 2021 while for standard-listed companies it came into effect from 1 January 2022.
Both the premium-listed and standard-listed rules now reflect the most up to date TCFD guidance released in October 2021.
The Financial Reporting Faculty hosted a roundtable of senior stakeholders from a range of organisations to reflect on the outcome of the first reporting season since the listing rules were changed. Read our Climate Roundtable Report here.
Interaction with the International Sustainability Standards Board
The International Sustainability Standards Board (ISSB) is a standard-setting board within the IFRS Foundation and sits alongside the International Accounting Standards Board (IASB). The ISSB’s objective is to develop and maintain a global set of sustainability disclosure standards which provide information that is material to the decisions of investors and other participants in the world’s capital markets. The financial Reporting Faculty has set out an overview of these developments.
There is two-way support between TCFD and the ISSB on sustainability reporting and the TCFD framework forms the basis of the ISSB's draft standards on general and climate-related disclosures.
The UK government has indicated an intention to align with international standards in the future, expressing a preference for climate reporting to be prepared in accordance with a global, consistent framework.
Practical tips and next steps
- Keep in mind that climate-related reporting is a journey that will evolve over time - this is something that both investors and regulators understand. The key is to be transparent and clear about where the company is on this journey.
- Assess what relevant climate-related information your company already discloses to map out where there are gaps in current reporting compared with the TCFD recommendations or applicable climate-related reporting regulations.
- Perform an appraisal of how your teams already work together (finance, risk, sustainability and strategy functions) to establish if sustainability and climate-related information can be given the time and resource needed to meet upcoming requirements.
- Put together an internal task-force to kick start a company-wide project for implementing climate-related reporting.
- Understand the needs of the company’s investors by speaking to them to find out their priorities.
The ICAEW has published a practical guide to the TCFD recommendations produced in association with the Carbon Trust.