The TCFD was created by the G20 in the aftermath of the 2015 Paris Agreement, aiming to “improve and increase reporting of climate-related financial information”.
In 2017, the TCFD released climate-related financial disclosure recommendations designed to help companies provide better information to support market transparency and more informed capital allocation. These recommendations are split up into four ‘pillars’ (governance, strategy, risk management, and metrics and targets), and eleven recommended disclosures.
The UK has incorporated these recommendations into its regulatory landscape through changes to the Financial Conduct Authority (“FCA”) Listing Rules, for major listed companies, through the Prudential Regulation Authority’s Supervisory Statement for banks, insurers, building societies, credit unions, and major investment firms, as well as through changes to the Companies Act for smaller listed companies and large privately owned businesses.
These changes have been, or will be, implemented in three phases:
- Phase 1: This was implemented for the fiscal year 2023-2024 and covers:
- the general principles of the TCFD, including scoping;
- disclosure of general governance principles in relation to climate risks and opportunities, including the board’s oversight of the same, and senior management’s role in assessing these risks and opportunities;
- the disclosure of Scope 1, Scope 2, and if appropriate, Scope 3 greenhouse gas emissions; and
- the TCFD compliance statement requirements.
- Phase 2 was implemented for the 2024-2025 fiscal year, and covers:
- disclosure of further metrics and targets; and
- description of risk management processes (how the organisation plans to assess and manage relevant climate related risks and opportunities).
- Phase 3 is due to be implemented for the 2025-2026 financial year, and will cover:
- the strategy recommendation requirement, i.e. disclosing climate risks, impacts, and opportunities; and
- disclosure of the organisation’s plans and strategy to address the risks and opportunities that the organisation has identified over the short, medium, and long terms.
Whilst the TCFD recommendations were designed as voluntary global standards, they are increasingly being made mandatory through national level legislation and regulation. In scope entities are required to comply with the requirements described above, or explain why they have not been able to do so (the comply or explain principle).
It is also increasingly thought of as best practice for out of scope entities to attempt to comply with the recommendations.
There is extensive guidance on the UK government website, which links to other useful resources here.
See this article for further detail.