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TCFD Explained: The benchmark for climate-related financial disclosure

Written by Pathzero | Jun 26, 2023 4:55:48 AM
The Task Force on Climate-related Financial Disclosures (TCFD) helps financial institutions to make better informed decisions on capital allocation.
In this introductory guide, we explore the TCFD framework and its recommendations for the voluntary disclosure of climate-related risks and opportunities.
We also consider TCFD’s significant influence on standards and rules globally, and how technology is making it easier for private markets to align investment processes and outcomes with TCFD.

Key sections in this guide

What is TCFD?

TCFD refers to the Task Force on Climate-related Financial Disclosures and the framework it established.  
 
The task force was formed by the Financial Stability Board in 2015, with members from across the G20 representing preparers and users of financial disclosures.  
 
As task force Chair Michael R. Bloomberg notes, “increasing transparency makes markets more efficient and economies more stable and resilient.”  
 
The TCFD framework supports this sentiment by increasing the transparency of how well organisations are positioned to respond to climate-related financial risks and opportunities. 

Information disclosed in line with TCFD supports asset owners, asset managers, lenders, insurance underwriters and others in making informed climate-related financial decisions on the future of organisations.

TCFD-aligned disclosures allow financial institutions to evaluate climate-related risks and opportunities that face organisations in the short, medium and long term. This enables them to make better informed decisions on where and when to allocate capital.  

 

Is TCFD mandatory?

The TCFD is not a regulator, and it does not set standards – and the framework itself is not mandatory. However, the private sector group has provided a framework that legislators, regulators, standard-setters and bodies are using and building upon around the world.  

Engaging with TCFD now gives organisations, including asset owners and asset managers within private markets, a practice run, and head start on climate-related financial disclosures that are set to become mandatory. 

Since the taskforce’s inception in 2015, and subsequent framework release in 2017, TCFD has become the foremost voluntary regime for climate-related financial disclosures globally. 

What type of organisations use TCFD?

The TCFD recommendations are designed to apply to any organisation type across jurisdictions and sectors. However, there are important distinctions in what the recommendations look like in practice for different organisation types. 

Organisations that provide goods and services use TCFD to disclose the financial impacts of climate-related risks and opportunities on their income, cash flow, and balance sheet.

Investors, underwriters, and lenders are the primary users of TCFD information. They can directly use this information to assess the climate-related risks and opportunities associated with existing or potential investments. This enables them to guide their capital allocation to specific industries, regions, and asset classes.

They can also make their own disclosures in line with TCFD. The disclosures of investors, underwriters and lenders focus on their approach, processes and outcomes to both reduce climate-related risks; and to take advantage of climate-related opportunities across their investment and lending books.

What are the 4 pillars of TCFD?

The TCFD framework is structured around four pillars that represent core elements of how organisations operate. By ensuring climate change is genuinely considered across these four pillars, climate can be elevated to a strategically essential topic. 

The four pillars of TCFD 

1. Governance

The organisation’s governance around climate-related risks and opportunities. 

2. Strategy

The actual and potential impacts of climate-related risks and opportunities on the organisation’s businesses, strategy, and financial planning. 

3. Risk management

The processes used by the organisation to identify, assess, and manage climate-related risks.

4. Metrics and targets

The metrics and targets used to assess and manage relevant climate-related risks and opportunities. 

Importantly, the four pillars of TCFD strengthen processes that embed climate change consideration into the fabric of an organisation, as well as processes that track progress and demonstrate outcomes to investors, lenders, and underwriters. 

The 4 pillars of TCFD

What are the 11 TCFD recommendations?

TCFD makes 11 recommendations within its four pillars of governance, strategy, risk management, and metrics and targets.  
 
TCFD provides supplemental guidance for different organisation types, including asset owners, asset managers, insurance companies, and banks. 
 
In this guide, we’ll explore the complete suite of TCFD recommendations, along with supplemental guidance for asset owners and asset managers. 

Governance

TCFD makes the following recommendations within the governance pillar. 

  • Describe the board’s oversight of climate-related risks and opportunities. 
  • Describe management’s role in assessing and managing climate-related risks and opportunities. 

Strategy

TCFD makes the following recommendations within the strategy pillar. 

  • Describe the climate-related risks and opportunities the organisation has identified over the short, medium, and long term.
  • Describe the impact of climate-related risks and opportunities on the organisation’s businesses, strategy, and financial planning. 
Supplemental guidance

Asset owners

Asset owners should describe how climate-related risks and opportunities are factored into relevant investment strategies.  
 
This could be described from the perspective of the total fund or investment strategy, or individual investment strategies for various asset classes.

Asset managers

Asset managers should describe how climate-related risks and opportunities are factored into relevant products or investment strategies.  
 
Asset managers should also describe how each product or investment strategy might be affected by the transition to a lower-carbon economy.


  • Describe the resilience of the organisation’s strategy, taking into consideration different climate-related scenarios, including a 2°C or lower scenario. 
Supplemental guidance

Asset owners

Asset owners that perform scenario analysis should consider providing a discussion of how climate-related scenarios are used, such as to inform investments in specific assets.

Asset managers

NA

In a technical supplement published in 2017, TCFD details how organisations can use scenarios in their efforts to implement the TCFD recommendations. The supplement covers key considerations, analytical choices, descriptions of scenarios, and additional resources around understanding and conducting scenarios. 

Risk management

TCFD makes the following recommendations within the risk management pillar.

  • Describe the organisation’s processes for identifying and assessing climate-related risks. 
Supplemental guidance

Asset owners

Asset owners should describe, where appropriate, engagement activity with investee companies to encourage better disclosure and practices related to climate-related risks.  
 
This will improve data availability and asset owners’ ability to assess climate-related risks.

Asset managers

Asset managers should describe, where appropriate, engagement activity with investee companies. This is to encourage better disclosure and practices related to climate-related risks, to improve data availability and asset managers’ ability to assess climate-related risks.  
 
Asset managers should also describe how they identify and assess material climate related risks for each product or investment strategy. This might include a description of the resources and tools used in the process. 

  • Describe the organisation’s processes for managing climate-related risks. 
Supplemental guidance

Asset owners

Asset owners should describe how they consider the positioning of their total portfolio with respect to the transition to a lower-carbon energy supply, production, and use.  
 
This could include explaining how asset owners actively manage their portfolios’ positioning in relation to this transition. 

Asset managers

Asset managers should describe how they manage material climate-related risks for each product or investment strategy. 

  • Describe how processes for identifying, assessing, and managing climate-related risks are integrated into the organisation’s overall risk management. 

Metrics and targets

TCFD makes the following recommendations within the metrics and targets pillar. 

  • Disclose the metrics used by the organisation to assess climate-related risks and opportunities in line with its strategy and risk management process. 
Supplemental guidance

Asset owners

Asset owners should describe metrics used to assess climate-related risks and opportunities in each fund or investment strategy.  
 
Where relevant, asset owners should also describe how these metrics have changed over time.  
 
Where appropriate, asset owners should provide metrics considered in investment decisions and monitoring.  

Asset managers

Asset managers should describe metrics used to assess climate-related risks and opportunities in each product or investment strategy.  
 
Where relevant, asset managers should also describe how these metrics have changed over time.  
 
Where appropriate, asset managers should provide metrics considered in investment decisions and monitoring. 

Supplemental guidance

Asset owners

Asset owners should provide the weighted average carbon intensity, where data are available or can be reasonably estimated, for each fund or investment strategy. 
 
In addition, asset owners should provide other metrics they believe are useful for decision making along with a description of the methodology used. 

Asset managers

Asset managers should provide the weighted average carbon intensity, where data are available or can be reasonably estimated, for each product or investment strategy. 
 
In addition, asset managers should provide other metrics they believe are useful for decision making along with a description of the methodology used.  

  • Describe the targets used by the organisation to manage climate-related risks and opportunities and performance against targets. 

What are the 7 disclosure principles of TCFD?

The TCFD developed seven principles for effective disclosure. The effective disclosure principles help to achieve high-quality and decision-useful disclosures that enable financial institutions to understand the financial impact of climate change on organisations. 

TCFD principles for effective disclosure 

1. Disclosures should represent relevant information. 
2. Disclosures should be specific and complete. 
3. Disclosures should be clear, balanced, and understandable. 
4. Disclosures should be consistent over time. 
5. Disclosures should be comparable among companies within a sector, industry, or portfolio. 
6. Disclosures should be reliable, verifiable, and objective. 
7. Disclosures should be provided on a timely basis. 

Climate-related risks

TCFD categorises climate-related risks in two ways:

  • Risks related to the transition to a lower-carbon economy
  • Risks related to the physical impacts of climate change 

Transition risks

The TCFD framework structures transition risks into four categories:

  • Policy and legal 
  • Technology 
  • Market 
  • Reputation 

Transition risk 1: Policy and legal 

Policy transition risks can include the restriction of business actions that contribute to climate change, or promotion of adaptation to climate change.  
 
Examples include policies that introduce carbon pricing mechanisms, shifts to lower emissions energy sources, and more sustainable land-use practices. Policy transition risks can impact the reporting business directly, as well as its supply and distribution chains. 
 
As loss and damage from climate change grows, legal and litigation transition risk is on the rise. Examples of reasons for litigation include the failure of organisations to play their part in mitigating the impacts of climate change, or insufficient disclosure of material financial climate-related risk.  

Transition risk 2: Technology 

The development and deployment of new technologies poses a transition risk to organisations. Technology is disrupting the competitiveness of organisations – from production and distribution costs to end-user demand. Note that this can present an opportunity for those able to innovate in a context of disruption. 
 
Examples of low-carbon technologies that are displacing old systems include renewable energy, and energy efficient technologies. 
 

Transition risk 3: Market 

As the economy and market forces shift to align to a low carbon economy, the supply and demand for certain products and services are shifting. This creates disruptions and associated risks and opportunities.

 
Transition risk 4: Reputation 

Customers and the community are increasingly scrutinising how companies contribute to, or detract from, the transition to a lower-carbon economy.  
 
Those failing to transparently measure their greenhouse gas emissions, set reduction targets, and communicate progress face the risk of reputational damage. 
 
In Australia, regulators are applying a particular focus on greenwashing. This can cause immense reputational damage to organisations found to have given a false impression, or over-promised and under-delivered, on their environmental commitments and actions. 
 

Physical risks

The TCFD framework structures physical risks into two categories. This includes acute physical risk, and chronic physical risk. Both forms of physical risk can cause direct damage to assets and disrupt supply chains.

Physical risk 1: Acute 

Acute physical risks are driven by the increasing severity and frequency of extreme weather events such as:

  • Flooding
  • Bushfire
  • Drought
  • Cyclones
  • Storms

Physical risk 2: Chronic 

Chronic physical risks are driven by long-term shifts in climate patterns such as sustained higher temperatures. This may cause sea level rise and, for example, chronic changes in established ocean currents.  

Climate-related opportunities

In addition to climate related risks – which often have a converse opportunity for those that can take advantage of disruptions – TCFD identifies five areas of climate-related opportunities for organisations to disclose. These opportunities should not be considered as exhaustive and include: 

  1. Resource efficiency
  2. Energy sources
  3. Products and services
  4. Markets
  5. Resilience  

Opportunity 1: Resource efficiency

Organisations can reduce operational costs and contribute to global efforts to decarbonise and transition to a net zero economy by improving the efficiency of production and distribution processes.  
 
Examples include energy efficiency innovation in heating, lighting, and transport, as well as innovation in broader materials, waste, and water management.  

Opportunity 2: Energy sources

As renewable energy costs continue to decline, organisations who procure renewable energy can potentially reduce operating costs. 
 
Low emissions alternatives include wind, solar, wave, tidal, hydro, geothermal, nuclear, biofuels, and carbon capture and storage.  

Opportunity 3: Products and services

Consumer and producer preferences are shifting towards low emissions products and services. Organisations that innovate and respond to these preferences may improve their competitiveness.

Examples include consumer products and services that emphasise emissions reductions in marketing and labelling; financial institutions that measure, report, and reduce their financed emissions; and producer goods that emphasise reducing emissions along the supply chain. 

Opportunity 4: Markets

Markets will change, sometimes very quickly, as a result of a shift towards a low carbon economy. Organisations able to anticipate and take advantage of these shifts, will fare better and be able to gain market share over less prepared or adaptable competitors.

Examples include financing green infrastructure such as low-emissions energy production, energy efficiency, and grid connectivity. 

Opportunity 5: Resilience

Resilience relates to an organisation’s capacity to respond to climate-related transition risks and physical risks.

This may be especially relevant for organisations that require longer-term financing and investment, along with those that depend on utility and infrastructure networks or natural resources.

How TCFD influences standards and rules

Almost without exception, major standards, proposed standards, regulatory bodies, and draft rules and legislative requirements for climate disclosure globally builds upon or references the TCFD’s work. This includes: 

Voluntary standards 

Mandatory rules and legislative requirements 

How TCFD influences corporate bodies and networks

TCFD is also supporting bodies and networks. As part of Climate Action 100+, over 700 investors with over $68 trillion in assets under management are using TCFD. The investors are engaging the world’s largest corporate greenhouse gas emitters to strengthen their climate-related disclosures by implementing the TCFD recommendations.  

The Climate Action 100+ Progress Update 2022 revealed that 91 per cent of the 161 focus companies have aligned with TCFD recommendations. This has increased from 72 per cent in March 2021.

The UN Principles for Responsible Investing (UNPRI) has created a TCFD for private equity general partners technical guide.

In addition, over 680 financial institutions with more than $130 trillion in assets have asked over 10,000 companies to disclose through CDP, which has aligned its climate change disclosures with the TCFD recommendations.

In Australia, TCFD influences the Australian Accounting Standards Board. 

TCFD supporters

The TCFD framework has become the global benchmark for disclosing the potential financial impacts of climate change on an organisation.  

The 2022 TCFD Status Report highlighted its rising influence with a five-fold increase in TCFD adoption since the framework’s inception in 2017, and a steady increase in the amount of information disclosed.

As at late 2022, the number of TCFD supporters surpassed 4,000 organisations from 100+ jurisdictions with a combined market capitalisation of $27 trillion. 

Many jurisdictions around the world publicly support TCFD recommendations, suggesting they may set their own rules based on the recommendations.

Some jurisdictions have progressed beyond endorsement and indicated that they’re considering setting their own rules based on TCFD recommendations. 

In Australia, regulatory bodies including the Australian Securities and Investments Commission and the Australian Prudential Regulation Authority have been supportive and encouraging of aligning with TCFD. 

Learn more about TCFD

To learn more, explore the TCFD website and education resources including: 

The Pathzero solution

TCFD reporting in private markets is on the rise. However, broad uptake is hindered by the lack of standardised climate data from portfolio companies, and the lack of in-house expertise.  

Pathzero is helping to overcome these barriers by uniting private market participants on a common platform. 

This enables asset owners, asset managers and portfolio companies to disclose and use consistent, comparable carbon data.

The platform is built to align with the TCFD framework and leading standards including the Greenhouse Gas Protocol, and the Partnership for Carbon Accounting Financials Standard.