Abstract

We conducted a type of “field experiment” in September 2017 to evaluate how difficult it will be for companies to implement the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). We examined the disclosures of 15 of the largest oil & gas companies by market cap that had filed a 10‑K or 20‑F in 2016, so before the TCFD’s recommendations were published. In general, we found reporting for that year uneven, with some TCFD categories fairly well covered and others not. We also found variation across companies, with most making fairly modest disclosures but some being fairly progressive in this regard. Significantly, we also found that most of the disclosures were in voluntary sustainability reports, not the financial filings required by statute and as recommended by the TCFD. Taken in the aggregate, at least one company was reporting on each of the 11 recommendations with one exception. This suggests that it is feasible for companies in this sector to follow the TCFD’s recommendations if they are interested in doing so.

Highlights

  • In June 2017, the Task Force on Climate-related Financial Disclosures (TCFD) published its final report of recommendations1 for how companies should report on climate issues

  • We conducted a type of “field experiment” in September 2017 to evaluate how difficult it will be for companies to implement the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD)

  • We found that most of the disclosures were in voluntary sustainability reports, not the financial filings required by statute and as recommended by the TCFD

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Summary

The Task Force on Climate-related Financial Disclosures

The TCFD final report, “Recommendations of the Task Force on Climate-related Financial Disclosures” (TCFD Recommendations) includes four broad themes—governance, strategy, risk management, and metrics and targets. Disclose the organization’s governance around climate-related risks and opportunities. 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. Disclose how the organization identifies, assesses, and manages climate-related risks. Disclose the metrics and targets used to assess and manage relevant climate-related risks and opportunities where such information is material

Governance and Materiality
Legal Risk
What needs to be done to facilitate adoption of the TCFD recommendations?
A Three-Step Process for Addressing the TCFD’s Recommendations

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