Speakers: Michael Zimonyi, Policy & External Affairs Director and Nontokozo Khumalo, Corporate Engagement Manager at CDSB.
The EU Non-Financial Reporting Directive (NFRD) came into effect in 2018 and requires listed companies and other public interest entities to disclose information on the way they operate and how they manage social and environmental challenges. In June 2019 the European Commission published guidelines on reporting climate-related information which included the integration of the Taskforce on Climate-related Financial Disclosures (TCFD) recommendations. These guidelines supplement the existing Non-Financial Reporting Guidelines released in 2017.
The EU is now set to publish a fitness check of corporate reporting to assess the appropriateness of existing legislation, with a special focus on NFRD, giving way to a possibility of a reopening of the current regulation. In advance of these updates, there is a tremendous opportunity for companies to get ahead of the curve to ensure that they are complying with the EU reporting guidelines and prepared for potential new regulations.
During this webinar briefing, you’ll gain insight into:
Current requirements of the NFR Directive and Guidelines;
The state of corporate climate change reporting;
Potential impacts of a reopened NFR Directive and CDSB’s expectations going forward.
What You Need to Know: The EU Non-Financial Reporting Directive and what its reopening could mean
1. December 19 | Tweet @CDSBGlobal
What You Need to Know:
December 10,2019.
The EU Non-Financial Reporting Directive and what its
reopening could mean
2. December 19 | Tweet @CDSBGlobal
Nontokozo Khumalo,
Corporate Engagement Manager, CDSB
Michael Zimonyi,
Policy and External Affairs Director, CDSB
Moderated by:
Julia Kislitsyna, Communications Manager, CDSB
What You Need to Know:
The EU Non-Financial Reporting Directive and what its
reopening could mean
3. December 19 | Tweet @CDSBGlobal
Does your company currently report climate
change and environmental information in the
annual report?
Yes
No
No, but intends to in the next 3 years
The EU Non-Financial Reporting Directive and what its reopening could mean
4. December 19 | Tweet @CDSBGlobal
Board
Technical Working Group (examples)
To provide decision-useful environmental
information to markets via the mainstream
corporate report
5. December 19 | Tweet @CDSBGlobal
CDSB Framework
• 7 guiding principles
• 12 reporting requirements
• Fully aligned with the TCFD recommendations
• Complementary to existing reporting provisions
(CDP, GRI, SASB) and existing regulations
• Referenced in the EU NFRD guidance and stock
exchange guidance globally
For reporting environmental information, natural
capital and associated business impacts
cdsb.net/Framework
The EU Non-Financial Reporting Directive and what its reopening could mean
6. December 19 | Tweet @CDSBGlobal
The EU Non-Financial Reporting Directive and what its reopening could mean
7. December 19 | Tweet @CDSBGlobal
Governance Strategy Risk Management 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.
a) Describe the board’s oversight of
climate-related risks and
opportunities.
a) Describe the climate-related risks
and opportunities the organization
has identified over the short,
medium, and long term.
a) Describe the organization’s
processes for identifying and
assessing climate-related risks.
a) Disclose the metrics used by the
organization to assess climate-
related risks and opportunities in
line with its strategy and risk
management process.
b) Describe management’s role in
assessing and managing risks and
opportunities.
b) Describe the impact of climate-
related risks and opportunities on
the organization’s businesses,
strategy, and financial planning.
b) Describe the organization’s
processes for managing climate-
related risks.
b) Disclose Scope 1, Scope 2, and,
if appropriate, Scope 3 greenhouse
gas (GHG) emissions, and the
related risks.
c) Describe the resilience of the
organisation’s strategy, taking into
consideration different climate-
related scenarios, including a 2°C or
lower scenario.
c) Describe how processes for
identifying, assessing, and
managing climate-related risks are
integrated into the organization’s
overall risk management.
c) Describe the targets used by the
organization to manage climate-
related risks and opportunities and
performance against targets.
8. December 19 | Tweet @CDSBGlobal
TCFD recommendations
8
Overview
1. Voluntary
2. Report climate-related financial disclosures in
the annual financial filings (mainstream report)
3. Financial sector & high risk non-financial sectors
4. Transition risks & physical risks (and opportunities)
5. Scenario analysis & forward-looking information
6. Short-term, medium-term & long-term
7. Qualitative & quantitative disclosures
Governance
Strategy
Risk
Management
Metrics
and Targets
The EU Non-Financial Reporting Directive and what its reopening could mean
9. December 19 | Tweet @CDSBGlobal
France
The EU Non-Financial Reporting Directive and what its reopening could mean 9
Article 173 of Energy Transition and Green Growth Law
requires financial stakeholders to publish information on
how ESG criteria, particularly concerning climate risks, are
considered.
UK
The UK government has set out its expectation for all
listed companies and large asset owners to disclose in
line with the TCFD recommendations by 2022, in its
recently released UK Green Finance Strategy.
10. December 19 | Tweet @CDSBGlobal
Canada
• CSA Staff Notice 51-358: Reporting of Climate Change
Related Risks
• Final Report of the Expert Panel on Sustainable Finance
– 5.1. Endorse a phased ‘comply-or-explain’ approach to adoption of the
TCFD framework in Canada.
10The EU Non-Financial Reporting Directive and what its reopening could mean
11. December 19 | Tweet @CDSBGlobal
Australia
ASIC – climate change is ’systemic risk’
• Regulatory Guide 228 Prospectuses: Effective disclosure for retail investors;
• Regulatory Guide 247 Effective disclosure in an operating and financial review
AASB Practice Statement on Climate-related and other emerging risks
disclosures
• Asset impairment;
• Changes in the useful life of assets;
• Changes in fair valuation of assets due to climate-related and emerging risks;
• Change in costs and/or demand for products & services affecting impairment
• Provisions and contingent liabilities arising from fines and penalties; and
• Changes in expected credit losses for loans and other financial assets.
11The EU Non-Financial Reporting Directive and what its reopening could mean
12. December 19 | Tweet @CDSBGlobal
TCFD recommendations
12
Overview
1. Voluntary
2. Report climate-related financial disclosures in
the annual financial filings (mainstream report)
3. Financial sector & high risk non-financial sectors
4. Transition risks & physical risks (and opportunities)
5. Scenario analysis & forward-looking information
6. Short-term, medium-term & long-term
7. Qualitative & quantitative disclosures
Governance
Strategy
Risk
Management
Metrics
and Targets
The EU Non-Financial Reporting Directive and what its reopening could mean
13. December 19 | Tweet @CDSBGlobal
TCFD implementation
Creating consistent, comparable and decision-useful
climate-related financial disclosures
CDP helps companies
generate, report and
structure their data.
SASB helps companies
understand what is
material to their
organisation.
CDSB helps companies
integrate the financially
material information into
their mainstream reports.
The EU Non-Financial Reporting Directive and what its reopening could mean
14. December 19 | Tweet @CDSBGlobal
EU NFR Directive
Where should it be disclosed?
.
What
should be
disclosed?
Annual Report
Flexibility to include information
in separate report under certain
circumstances.
How?
Guidelines
• Guidelines on Non-financial
Reporting
• Guidelines on Reporting
Climate-related Information
Who?
Public Interest
Entities
employing >
500 people
Comply or Explain
• Business Model
• Policies
• Policy Outcomes
• Principal Risks
• Non-financial KPIs
The EU Non-Financial Reporting Directive and what its reopening could mean
15. December 19 | Tweet @CDSBGlobal
Materiality
Double Materiality TCFD Materiality
“description of the specific
climate-related issues for each
time horizon (short, medium, and
long term) that could have a
material financial impact on the
organization,”
filings.”
The EU Non-Financial Reporting Directive and what its reopening could mean
16. December 19 | Tweet @CDSBGlobal
Sustainable Finance Action Plan
Action 9: Strengthening
corporate disclosure on
sustainability
9.1 Fitness Check
9.2 Revision of NFR
Directive Guidelines – TCFD
The EU Non-Financial Reporting Directive and what its reopening could mean
17. December 19 | Tweet @CDSBGlobal
A
Introduction
B
Climate-Related Risks,
Opportunities,and
Financial Impacts
C
Recommendationsand
Guidance
D
Scenario Analysisand
Climate-Related Issues
E
KeyIssuesConsidered and
Areasfor Further Work
F
Conclusion
Appendices
Figure 12
Implementation Path (Illustrative)
More complete, consistent, and
comparable information for market
participants, increased transparency,
and appropriate pricing of climate-
related risks and opportunities
Final TCFD
Report Released
Companies already reporting under other frameworks implement the Task
Force’s recommendations. Others consider climate-related issues within
their businesses
Organizations begin to
disclose in financial filings
Greater adoption, further development of
information provided (e.g., metrics and
scenario analysis), and greater maturity in
using information
Five Year Time Frame
AdoptionVolume
Climate-related issues viewed as
mainstream business and investment
considerations by both users and
preparers
Broad understanding of the concentration of
carbon-related assets in the financial system and
the financial system’s exposure to climate-related
risks
18. December 19 | Tweet @CDSBGlobal
2019 Status Report
898
supporters globally,
with market capitalisation
of more than $9 trillion.
The EU Non-Financial Reporting Directive and what its reopening could mean
19. December 19 | Tweet @CDSBGlobal
Main Findings
Disclosure of climate-related
financial information has
increased since 2016, but is still
insufficient for investors.
More clarity is needed on the
potential financial impact of
climate-related issues on
companies.
Of companies using scenarios,
the majority do not disclose
information on the resilience of
their strategies.
Mainstreaming climate-
related issues requires the
involvement of multiple
functions.
The EU Non-Financial Reporting Directive and what its reopening could mean
20. December 19 | Tweet @CDSBGlobal
Non-Financial Reporting Directive updates
Materiality
• Double materiality
• Interpretation by Member States
Immaterial disclosures
• Presenting concise information
• Other supporting documentation?
Information requirements
The EU Non-Financial Reporting Directive and what its reopening could mean
21. December 19 | Tweet @CDSBGlobal
Non-Financial Reporting Directive updates
Reliability of information & assurance
“Statutory auditors and audit firms should only check that the non-financial statement or the
separate report has been provided. In addition, it should be possible for Member States to
require that the information included in the non-financial statement or in the separate report
be verified by an independent assurance services provider.”
– (6) of preamble to Non-Financial Reporting Directive
Comparability of information
• Metrics used
• Sector-specific alignment
Quality considerations
The EU Non-Financial Reporting Directive and what its reopening could mean
22. December 19 | Tweet @CDSBGlobal
Non-Financial Reporting Directive updates
• Scope of companies that should be covered
– Size of company
– Proportionality of requirements
• Location of disclosures
– Annual report vs separate report
– Length of reports
– What is most useful to the reader?
• Coherence with other policy
– Taxonomy, investor disclosure, etc
Other considerations
Source: Accountancy Europe, Core & More
The EU Non-Financial Reporting Directive and what its reopening could mean
23. December 19 | Tweet @CDSBGlobal
Non-Financial Reporting Directive updates
TCFD incorporation
• De-facto standard for climate-related financial reporting
• Non-binding guidelines are a good start, but more alignment is needed
• Significant alignment behind TCFD within standard setters
• Financial market focus
TCFD for natural capital
• Climate change is only one pillar of environmental risks
• IPBES: nature is in sharp decline
• Off track on SDGs, Aichi Biodiversity Targets
Other considerations contd.
The EU Non-Financial Reporting Directive and what its reopening could mean
25. December 19 | Tweet @CDSBGlobal
Q&A
Nontokozo Khumalo
Corporate Engagement Manager
nontokozo.khumalo@cdsb.net
Michael Zimonyi
Policy and External Affairs Director
michael.zimonyi@cdsb.net
26. December 19 | Tweet @CDSBGlobal
Questions?
With the contribution of the LIFE Programme of the European Union.
Hosted by CDP Europe.
@CDSBGlobal on Twitter
Climate Disclosure Standards Board on LinkedIn:
www.linkedin.com/company/cdsb/
info@cdsb.net
27. December 19 | Tweet @CDSBGlobal
Thank you!
The full-length video recording of the webinar is
available on our YouTube Channel:
https://youtu.be/tpkDHay-ZkE
Notas del editor
Mike: The Climate Disclosure Standards Board is a consortium of 9 environmental and business NGOs.
We were set up in Davos in 2007 with a mission to create the enabling conditions for material climate change and natural capital information to be integrated into the mainstream report.
We achieve our mission by offering a framework for reporting environmental and climate information.
Nonto
The TCFD was set up in 2015 to develop voluntary, consistent climate-related financial risk disclosures for use by companies in providing information to investors, lenders, insurers, and other stakeholders. They specifically considered the physical, liability and transition risks associated with climate change and what constitutes effective financial disclosures across industries.
In 2017 the Task Force released their final report which set out principles and 11 recommendations for effective disclosure.
Nonto
Just to remind you of the 4 core elements and the 11 recommended disclosures.
What makes the TCFD different?
Previous environmental reporting Staff Notice unsuccessful
Final Report of the Expert Panel on Sustainable Finance
5.1. Endorse a phased ‘comply-or-explain’ approach to adoption of the TCFD framework in Canada.
5.2. Provide clarity to issuers on the recommended scope and pace of TCFD implementation.
5.3. Work with federal, provincial and industry partners to clarify the materiality of climate-related financial disclosures.
Canadian Business Corporation Act, Part XIV Financial Disclosure is updated with requirements for financial statements to include environmental disclosures; and/or
Updates to National Instrument 51-102 Continuous Disclosure Obligationsii and National Instrument 58-101 Disclosure of Corporate Governance Practices.
Updates to CSA Staff Notice 51-333 Environmental Reporting Guidanceiv to incorporate TCFD recommendations
AASB Practice Statement on Climate-related and other emerging risks disclosures
asset impairment;
changes in the useful life of assets;
changes in the fair valuation of assets due to climate-related and emerging risks;
increased costs and/or reduced demand for products and services affecting impairment calculations and/or requiring recognition of provisions for onerous contracts;
potential provisions and contingent liabilities arising from fines and penalties; and
changes in expected credit losses for loans and other financial assets.
What makes the TCFD different?
Nonto
What the outcome of the TCFD is – improve decision-making (by investors, lenders and insurers in allocating capital and underwriting risk), enhance market resilience and more sustainable economic growth.
Also to ensure more stable, resilient markets over the medium and long term by facilitating a smoother transition—with less abrupt price adjustments—to a lower-carbon and climate-resilient economy.
Companies can use their CDP responses to help generate and structure the data and information they collect. CDSB’s Framework helps integrate the information in the annual report, and this leads to better TCFD reporting.
Nonto
What the outcome of the TCFD is – improve decision-making (by investors, lenders and insurers in allocating capital and underwriting risk), enhance market resilience and more sustainable economic growth.
Also to ensure more stable, resilient markets over the medium and long term by facilitating a smoother transition—with less abrupt price adjustments—to a lower-carbon and climate-resilient economy.
Companies can use their CDP responses to help generate and structure the data and information they collect. CDSB’s Framework helps integrate the information in the annual report, and this leads to better TCFD reporting.
Nonto
What the outcome of the TCFD is – improve decision-making (by investors, lenders and insurers in allocating capital and underwriting risk), enhance market resilience and more sustainable economic growth.
Also to ensure more stable, resilient markets over the medium and long term by facilitating a smoother transition—with less abrupt price adjustments—to a lower-carbon and climate-resilient economy.
Companies can use their CDP responses to help generate and structure the data and information they collect. CDSB’s Framework helps integrate the information in the annual report, and this leads to better TCFD reporting.
Nonto
What the outcome of the TCFD is – improve decision-making (by investors, lenders and insurers in allocating capital and underwriting risk), enhance market resilience and more sustainable economic growth.
Also to ensure more stable, resilient markets over the medium and long term by facilitating a smoother transition—with less abrupt price adjustments—to a lower-carbon and climate-resilient economy.
Companies can use their CDP responses to help generate and structure the data and information they collect. CDSB’s Framework helps integrate the information in the annual report, and this leads to better TCFD reporting.
With the release of the second status report, the TCFD had over 800 supporters globally with a market capitalisation of over $9.3 trillion. In the list of supporters, the financial sector leads the way with 392 supporters, followed by the “non-financial” sector at 297 and finally “other”, such as governments and business associations, at 114.
The map shows the geographic distribution of survey respondents with Europe leading the way at 45%. Despite this, it is interesting to note that the United States ranks number 1 in terms of country respondents following by the UK and then Japan.
Now before we dive into the details, let’s take a look at the four key themes and findings that emerged from the report.
The 2019 Status report tells us that, despite support for the TCFD rising by more than half since last September, companies are still finding it a challenge to implement the recommendations resulting in insufficient disclosure for investors. More clarity is needed on the potential financial impact of climate-related issues, the majority of companies do not disclose information on resilience and, finally, mainstreaming climate-related issues requires the involvement of multiple functions.
Given the urgency of the situation and the scale of the challenge, these findings are concerning. The financial risks that climate change presents to the global economy are enormous. In fact, the United Nations states that delays in tackling this issue could cost companies nearly $1.2 trillion over the next 15 years. In the upcoming slides, we’ll explore these key themes in more detail, discuss some of the most significant statistics from the report and action needed moving forward.
Materiality (taking into account double materiality and especially Germany’s interpretation of this)
Replicability of information & assurance
Comparability of information
Immaterial disclosures
Scope of companies that should be covered (and which requirements should apply to which size of companies)
Location of disclosure
Coherence with other policy (e.g.: taxonomy, investor disclosure)
By providing environmental information in mainstream reports, organisations are expected to apply the same rigour and management responsibility as is appropriate to all statements and disclosures presented in the mainstream report, whether audited or not. Generally, the financial statements auditor is required to read the information presented in addition to the audited financial statements and to identify any significant inconsistencies between it and the
audited financial statements and to consider any observed significant misstatements of fact in those disclosures and that it conforms with local regulations.
Materiality (taking into account double materiality and especially Germany’s interpretation of this)
Replicability of information & assurance
Comparability of information
Immaterial disclosures
Scope of companies that should be covered (and which requirements should apply to which size of companies)
Location of disclosure
Coherence with other policy (e.g.: taxonomy, investor disclosure)
Q Mike: Since materiality is only included in the guidelines, how important are they to complying with the requirements of the Directive?
Q Nonto: What is the key thing companies can do to prepare themselves?
Q Mike: Do we expect a change with regards to the flexibility allowed to companies in some jurisdictions?