Global Climate Risk Barometer
September 2022

When will Climate
Disclosures
start to impact
decarbonization?

Contents
Foreword

3

Executive summary4

Chapter 1: Coverage and quality

6

Chapter 2: Market focus

9

Chapter 3: Sector focus

14

Chapter 4: Risks and opportunities

18

Chapter 5: Financial impact of disclosures

22

Chapter 6: Future forecast

26

Chapter 7: Action for decarbonization

29

About this research

32Foreword
Corporate reporting could be crucial to the decarbonization process. Within this context, a particularly
important role is played by climate-related disclosures, which are increasingly based on the recommendationsof the Task Force on Climate-related Financial Disclosures (TCFD). Yet, climate disclosures are still nottranslating into practical strategies to accelerate decarbonization.
A notable development in corporate reporting over the past 12 months was the launch of the International
Sustainability Standards Board (ISSB) at the COP26 climate change conference in November 2021. The ISSB
is developing a comprehensive global baseline of sustainability disclosures for the capital markets and has
already released its first two proposed standards.
Furthermore, in the US, the Securities and Exchange Commission (SEC) has proposed new rules tomandate climate risk disclosures, while Japan, New Zealand and the UK have all introduced rules
requiring large companies to disclose climate-related financial information on a mandatory basis. In the EU,
the European Financial Reporting Advisory Group (EFRAG) has published a draft of the proposed climate
standard that companies will be required to use when reporting under the Corporate Sustainability Reporting
Directive (CSRD).
In concert with political and regulatory activity in the space, companies are making ambitious announcements
to be net zero by a specified date in the future, often by 2050. However, they are providing little detail about
how they intend to meet these targets, leading many investors to intensify the pressure on companies topublish their transition plans.
How an organization responds to climate risks and opportunities can be a major strategic consideration
with long-standing implications for its own future prospects, as well as those of our planet. In fact, 86% of
the corporate executives and managers, who responded to the latest EY Long-Term Value and Corporate
Governance Survey, say that a focus on environmental, social and governance (ESG) issues, and sustainable,
inclusive growth has been critical to building trust with stakeholders in today’s uncertain times.
It can; therefore, be vital that organizations embed the findings from their scenario analysis into their financial
management, risk management and strategy-setting practices. In particular, boards and senior management
teams should be using their disclosures to inform stakeholders, particularly investors. They can show how
they are understanding and managing their risks in practice, rather than simply treating scenario analysis as atheoretical analysis of the potential impacts of climate change on the current business model. In addition, suchanalysis can sometimes be a siloed exercise that is not integrated into broader enterprise risk
management systems.
This is the fourth EY Global Climate Risk Disclosure Barometer, a comprehensive analysis of disclosures madeby more than 1,500 companies across 47 countries. It aims to help your own board and management teamreflect on your organization’s approach to climate disclosures and the practical actions you can take to alignyour organization’s strategy with the decarbonization of the global economy.
Global temperatures continue to rise and yet we are still far from where we need to be, in terms of allocating
capital to the transition process. While disclosure facilitates decarbonization, words alone cannot address thehuge challenge we face. It is time to move from disclosure to action.

Dr. Matthew BellEY Global Leader of Climate Change
and Sustainability Services

1Long-Term Value and Corporate Governance Survey, EY, 2022.

Global Climate Risk Disclosure Barometer 3

Executive
summary
4

Global Climate Risk Disclosure Barometer

Executive summary

The research highlights that companies are notsufficiently referencing the financial impact ofclimate change in their financial statements.

The EY Global Climate Risk Disclosure
Barometer shows that, while companies
continue to improve the coverage andquality of their climate disclosures, they
may not be considering a holistic view of
their physical and transition risks, as wellas the opportunities that can arise fromthese risks. The research also highlightsthat companies are not sufficiently
revealing the financial impact of climatechange in their financial statements.
The methodology of this year’s study
was updated to provide a more definitiveand robust scoring around disclosure
quality. The revised scoring matrix scoredcompanies on a scale of zero to five,compared with the previous matrix, which
provided scores of zero, one, three andfive. For more on the methodology, see
About this research on page 34.

most likely reflects greater regulation
around climate disclosure andcompanies responding to investor
pressure to publish transition plans.
••South Korea, southern Europe, central
and eastern Europe, and Ireland leadthe Barometer, in terms of the qualityof their climate disclosures.

•

From an industry sector perspective,the energy sector has the highest
coverage and quality score, followed
closely by insurance. Insurance
achieved a 34% increase in quality
year-on-year. Another financial
services sector — financial asset
owners and managers — improved
quality by 40%.

These are some of the key
findings from the research:•

The score for coverage of TCFD
recommendations is 84%, up from
70% in 2021 for the corporate reports
analyzed, while the average score
for quality is 44%. The gap between
coverage and quality suggests that,while more companies are reportingon climate risk, they are struggling toprovide meaningful disclosures aroundthe challenges they face.

•

Strategy is the element that has seen
the most improvement, with theaverage strategy score increasing
to 42%, up from 38% in 2021. This

Companies that disclose throughthe Carbon Disclosure Project (CDP)
global disclosure system achieved
both higher coverage and higher
quality scores.

•

Nearly half (49%) of companies
featured in this year’s Barometer had
conducted scenario analysis. The mostcommonly referenced scenarios were
RCP 8.5 and RCP 2.6, suggestingthat the analysis of physical risks is
top of mind for businesses. The mostcommon time horizons referenced
were 2040-50, while 2027 also
featured prominently for carbon
pricing scenarios.

•

Up to 75% of companies performed
risk analysis. They focused more orless equally on both physical andtransition risk. Furthermore, 62% ofcompanies undertook opportunity
analysis, with products and services
being the most commonly listed
opportunities.
•

Almost 61% of companies havedisclosed decarbonization strategies.
The energy sector ranks highest
among nonfinancial sectors, with 81%
of the companies disclosing a specificnet-zero strategy or transition plan.
Meanwhile, the agriculture, food andforest products sector ranks lowest
among nonfinancial sectors. In thefinancial sector, financial asset owners
and managers rank lowest, in terms ofthe disclosure of their decarbonization
strategy.

•

29% of companies referenced thefinancial impact of climate change intheir statements, as both qualitativeand quantitative aspects. This resultshows that, while companies are
improving the coverage and qualityof disclosures, they are struggling tobring financially material information
together in a meaningful way.

Global Climate Risk Disclosure Barometer 5

1
6

Coverageand quality

Global Climate Risk Disclosure BarometerCoverage and quality

84%

More than five years havepassed since the TCFD
finalized its recommendations
for disclosing climate-related
financial information. Duringthat time, companies around theworld have increasingly embraced
those recommendations acrossthe four elements of governance,
strategy, risk management,
and metrics and targets.

Nevertheless, while much progress has
been made, companies’ climate disclosures
are not yet as comprehensive as investors,
regulators and other stakeholders would
like them to be. Furthermore, the disclosureof climate risk does not yet appear to be
having a significant real-world impact,
in terms of accelerating the decarbonization
process.

Overall, coverage of TCFD
recommendations stands at 84%,a steep increase from 70% in 2021.

CoverageThis increase in coverage can be
attributed to a number of factors. In somejurisdictions, such as France, Japan andthe UK, companies are responding to thedemands of their regulatory environment.
In other jurisdictions, companies arevoluntarily choosing to do this reporting,both as a way to identify, manage andmitigate their own risk, and to better
engage with investors, employees, andcustomers on climate-related issues.

Coverage is defined as a company
providing some level of informationthat complies with each of therecommendations, regardless of thequality of information provided.
It is clear from the findings of this year’s
Barometer that C-suites and boards aroundthe world continue to prioritize climate
risk reporting. Overall, coverage of TCFD
recommendations stands at 84%, a steep
increase from 70% in 2021. What is more,coverage has increased across all four
elements of the recommendations.

Figure 1. Coverage has increased across all four elementsof the recommendations
70%

84%

Overall

71%

85%

Governance

65%

81%

Strategy

Coverage 2021

68%

83%

Risk
Management

75%

87%

Metrics andTargets

Coverage 2022
Global Climate Risk Disclosure Barometer 7

Coverage and quality

Quality
Quality relates to the extent towhich a company’s disclosure meetsall 11 requirements of the TCFD’s
recommendations. It considers whether acompany has provided well-developed or
market-leading disclosure of a particular
aspect of climate risk or whether disclosure
is restricted to a limited discussion, or noteven published at all.
The 2022 Barometer found that, despite
the changes to the scoring matrix, there
have only been small changes to thequality of climate risk disclosures madeby companies over the past year. Overall,
the average quality score was just 44% of
the maximum possible score across the 11
recommendations, up from 42% in 2021.

Furthermore, there was very limited yearon-year improvement across three of theelements: governance, risk management,
and metrics and targets, and in some sectors,
overall quality was lower than in the prior year.
Companies’ lower scores on disclosure
quality, compared with disclosure coverage,
potentially suggest that, while more

Figure 2. Small changes to the quality of climate risk disclosures
42% 44%

45% 46%Overall

Governance38%

The one element of the TCFD frameworkthat showed a marked improvement inrelation to quality of disclosures this year
was strategy. In previous versions of theBarometer, strategy lagged behind theother three elements, due to the toughquestions it posed around how companies
were integrating climate-related risks andopportunities into their business strategies,
and, possibly, building resilience throughdiversification, allowing for different
climate futures that may unfold.
This year, however, performance acrossall four pillars was broadly similar, with theaverage quality score for strategy being
42%, up from 38% in 2021. Similarly,
strategy showed the greatest improvementin terms of coverage, reaching 81% in
2022, up from 65% in 2021.

42%

Strategy

Quality 2021

Strategy

companies are reporting on climate risk,
they are struggling to provide meaningfuldisclosure around the challenges they
face. Nevertheless, it was notable from theresearch that jurisdictions that either have,or are moving toward, mandatory reporting
tend to have better quality reporting as well
as better coverage.

This enhanced focus on strategy reflects
the changing political and regulatory
landscape around climate risk disclosures,
as well as companies’ growing awarenessthat the future will likely require deep
decarbonization. The newly formed ISSB
is working on two proposed standards forsustainability disclosures, with strategy
being an important component of both,alongside the other three pillars ofgovernance, risk management and targets.2
Furthermore, investors are putting
companies under pressure to draw up andpublish transition plans that outline how
their organization could adapt as the worldtransitions toward a low-carbon economy. For
instance, investor-led initiative Climate Action
100+ is engaging with 167 of the world’s
largest corporate emitters of greenhousegases to drive faster action on climatechange in line with the global goal of reachingnet-zero emissions by 2050 or sooner.3

41% 43%

45% 45%

Risk
Management

Metrics andTargets

Quality 2022

Pressure to publish transition plans
is set to further intensify in the nearterm and some jurisdictions are looking
to develop specific frameworks forclimate transition plans. For example,
the UK Government has established theTransition Plan Taskforce (TPT) to develop
a “gold standard” for transition plans.4
Meanwhile, in March, the United Nations
launched a High-Level Expert Group on
the Net-Zero Emissions Commitmentsof Non-State Entities, with the aim ofdeveloping stronger and clearer standards
for net-zero emissions by businesses (aswell as investors, cities and regions) andaccelerating their implementation.5 Certain
sectors are also paying particular attention
to transition plans, with financial services
being a notable example.

“ISSB delivers proposals that create comprehensive global baseline of sustainability disclosures,” IFRS Foundation website, https://www.ifrs.org/news-and-events/news/2022/03/issb-delivers-proposals-thatcreate-comprehensive-global-baseline-of-sustainability-disclosures, accessed 20 July 2022.
32021 Year in Review: A Progress Update,” Climate Action 100+ website, https://www.climateaction100.org/wp-content/uploads/2022/03/Climate-Action-100-2021-Progress-Update-Final.pdf, accessed 20 July 2022
4
“Government launches consultation on ‘gold standard’ framework for climate transition plan,” Edie website, www.edie.net/government-launches-consultation-on-gold-standard-framework-for-climate-transitionplans, accessed 20 July 2022.
5“UN’s High-Level Expert Group on the Net-Zero Emissions Commitments of Non-State Entities,” UN website, https://www.un.org/sg/en/content/sg/personnel-appointments/2022-03-31/expert-group-thenet-zero-emissions-commitments-of-non-state-entities%C2%A0
28

Global Climate Risk Disclosure BarometerCoverage and quality

The greatest improvement in disclosure
quality around strategy is related tocompanies disclosing the impact of climaterelated risks and opportunities on theirbusiness, strategy and financial planning.
There was also some improvement incompanies identifying climate-relatedrisks and opportunities over the short-,
medium- and long-term, and companies
making assessments of their resilience,taking into consideration different climaterelated scenarios, including a 2°C or lower
temperature rise scenario.
It is encouraging to see companies paying
greater attention to strategy disclosures,
including different scenarios. This suggests
they are factoring climate risks andopportunities into their long-term decisionmaking. Furthermore, when companies
provide climate-related disclosure aroundstrategy, they provide valuable insightsthat help investors and other stakeholders
to better understand the potential impactsof climate change on their organization.

Impact of CDP
It is no coincidence that companies
using the CDP global disclosure systemwere more likely to achieve both higher
coverage and higher quality scores in thisyear’s Barometer. In 2018, CDP redesigned
its annual climate change questionnaire
to align with the TCFD recommendations.
This resulted in disclosing companies
having “ready-to-go material climate andnatural capital disclosures” that they could
use for their annual reports.6

While there has been an improvement in
the coverage and quality of disclosures,
strategy still has the lowest overall scoreof the four TCFD elements. This may wellbe due to the fact that companies are

struggling to translate targets into actual
business strategy and to embed climate
risk and opportunities into their businessand financial plans.

Figure 3. Improvements seen across all three strategy recommendations

41%

45%

41%

45%
32% 35%

S3

S4

S5

Climate-related risks
and the opportunities
identified over the
short, medium andlong term.

Impact of climate
related risks andopportunities on
the organization’s
businesses, strategy
and financial planning.

Resilience taking
into considerationdifferent climaterelated scenarios,
including a 2°C or
lower scenario.

Strategy 2021

Overall, the average quality score forcompanies disclosing through CDP was
44%, compared with 33% for companies
that did not disclose through CDP.
Similarly, the average coverage score forcompanies disclosing through CDP was
84%, compared with 80% for those that
did not. The process of completing the
CDP questionnaire involves discipline anddetailed analysis that helps to improve
both the coverage and quality of reporting.

Strategy 2022

Nevertheless, it is important to note that,while CDP questionnaires are valuable,
they are not subject to the same levelof governance and scrutiny as annual
reports. So, companies that are committed
to high-quality climate disclosures should
provide confidence that they report thesame information in their annual reports
as in their CDP questionnaires.

“On the 5-year anniversary of the TCFD, a critical reminder to companies,” CDP website, https://www.cdp.net/en/articles/climate/on-the-5-year-anniversary-of-the-tcfd-a-critical-reminder-to-companies,
accessed 20 July 2022.
6

Global Climate Risk Disclosure Barometer 92
10Marketfocus

Global Climate Risk Disclosure Barometer

Market focus

High-performing markets from previous
years, such as the UK, Japan, South Korea
and Canada, continue to perform well.

Continuing the trend of previous
years, the markets that produced
the most advanced reporting, interms of both coverage and quality,
benefit from strong climate disclosure
regulations, proactive investors who
are lobbying for change, and clear
signals from policymakers about thedirection of travel. Hence, the highperforming markets from previous
versions of the Barometer, such as
the UK, Japan, South Korea andCanada, continue to perform well inthis year’s research.

Topping the table, in terms of bothcoverage (99%) and quality (62%), is
the UK. Japan comes a close second
with a coverage score of 96% and aquality score of 56%. The scores ofthese countries reflect their advanced
regulatory environments, when it comesto climate disclosures.
Some notable improvements indisclosure quality can be seen in many
European markets. Emerging markets
have also improved considerably sincelast year, in terms of both their coverageand quality.

In a number of markets, including
India, Greater China, the Middle Eastand Southeast Asia, there is scope forfurther improvement, despite theiroverall increase in performance. This
improvement is more likely to happen
if companies in these markets comeunder more scrutiny from investors and
if regulators signal an intention to movetoward mandatory climate disclosures.

Figure 4. Improvements in coverage across all markets
93%

99%

UK

90%96%

Japan

80%

96%

85%94% 84%91%

South
Korea

CanadaWestern/
Northern
Europe

88%

88%
62%

62%

Ireland70%

87% 88%87% 84%86%

81%
48%

Southern
EuropeOceania

Coverage 2021

AfricaUSA

Greater
China

62%

78%

Central/South
America

84%

69%

58%

56%

Central/EasternEuropeSoutheast
Asia

49%

65%

India

49%46%

MiddleEast

Coverage 2022

Figure 5. Some notable improvements in quality in many markets
67%

62% 59%56%

46%

54% 51%53%

43%

52%

59%

51%

49% 50%48%

60%

48% 49%

42%

25%

UK

Japan

South
Korea

CanadaWestern/
Northern
EuropeIreland

Southern
EuropeQuality 2021

Oceania

Africa

USA

43%

38%

29%

29%

Greater
China

Central/South
America

25%

34% 29%30%

Central/EasternEuropeSoutheast
Asia

19%

26% 21%

India

15%

MiddleEast

Quality 2022
Global Climate Risk Disclosure Barometer 11

Market focus

United Kingdom
Central andSouth America
Several countries in Central andSouth America are targeting Net
Zero greenhouse gas emissions’by 2050, including Argentina,
Colombia and Costa Rica.7 Brazil
is also committed to achieving Net
Zero greenhouse gas emissions
by this date, and its central bankhas published new rules on social,environmental and climate-related
disclosures, which will be effectivefrom December 2022.8 Mexico
has created a sustainable financecommittee within its Financial
System Stability Council. The
committee has several working
groups, including one focused on
improving the amount and qualityof disclosures and reportingby nonfinancial and financial
institutions.9“Which countries have a net-zero carbon goal?” Climate
Home News website, https://www.climatechangenews.
com/2019/06/14/countries-net-zero-climate-goal, accessed 20
July 2022.
7“New regulation on social, environmental and climate-related
disclosures,” Banco Central do Brasil website, www.bcb.gov.br/
content/about/legilation_norms/BCB_Disclosure-GRSAC-Report.
pdf, accessed 20 July 2022
8

“Banco de México declaration towards UN Climate Change
Conference of the Parties (COP26),” Banco de México website,
https://www.banxico.org.mx/financial-system/d/%7B80FDF3B4F5C1-E88F-442E-EF77C6A7BE59%7D.pdf, accessed 20 July
2022.
9

“UK to enshrine mandatory climate disclosures for largest
companies in law,” UK government website, https://www.gov.uk/
government/news/uk-to-enshrine-mandatory-climate-disclosuresfor-largest-companies-in-law, accessed 20 July 2022.
10“HM Treasury launches UK Transition Plan Taskforce,” HM
Treasury website, https://www.e3g.org/news/hm-treasurylaunches-uk-transition-plan-taskforce, accessed 22 July 2022.
11

12

Global Climate Risk Disclosure Barometer

Since April 2022, more than
1,300 of the largest companies
and financial institutions in the UK
have had to disclose climate-related
financial information on a mandatory
basis, in line with the TCFD
recommendations.10 Companies had
to prepare for this deadline, which
explains why the UK’s coverage ofclimate disclosures is near-universal,
according to the Barometer. Fullmandatory climate-related financial
disclosure requirements are set
to come into force across the UK
economy by 2025, going beyond
the existing “comply or explain”
approach. The UK has also formed
the TPT to develop a gold standard
for climate transition plans. The TPT
aims to help drive decarbonization
by ensuring that financial institutions
and listed companies develop
and publish rigorous and robusttransition plans that detail how
they could adapt and decarbonize
as the UK moves toward a net-zero
economy by 2050.11

Market focus

Middle East
As the lowest performer on the
Barometer, in terms of bothcoverage and quality, the Middle
East has plenty of scope to improveits climate disclosures. The region isless advanced than other markets,in terms of its regulatory frameworkfor ESG reporting. This may belinked to its carbon-intensive
economy and strong links to thefossil fuel industry. Ultimately,
it may be down to investors andfinancial institutions to drivechange in the region by demanding
disclosures from companies that arelooking to raise capital.

Africa (includingSouth Africa)
Africa experienced similar results
to last year’s Barometer, in termsof both coverage and quality of
disclosures. Led by its mining
industry, South Africa is alreadya comparative leader in climate
reporting, and the Johannesburg
Stock Exchange is in the processof developing both sustainability
and climate change disclosure
guidance.12“JSE’s Sustainability and Climate Disclosure Guidance,” JSE website,
https://www.jse.co.za/our-business/sustainability/jses-sustainabilityand-climate-disclosure-guidance, accessed 20 July 2022.
12“Report: China emissions exceed all developed nations combined,”
BBC website, https://www.bbc.co.uk/news/world-asia-57018837
13“How should China improve climate disclosure in the financesector?” China Dialogue website, https://chinadialogue.net/en/
business/how-should-china-improve-climate-disclosure-in-thefinance-sector, accessed 20 July 2022.
14“Japan to require 4,000 companies to disclose climate
risks,” Nikkei Asia website, https://asia.nikkei.com/Spotlight/
Environment/Climate-Change/Japan-to-require-4-000-companiesto-disclose-climate-risks, accessed 20 July 2022.
15“SEBI issues Circular on ‘Business Responsibility and Sustainability
Reporting by listed entities’,” Securities and Exchange Board of India
website, https://www.sebi.gov.in/media/press-releases/may-2021/
sebi-issues-circular-on-business-responsibility-and-sustainabilityreporting-by-listed-entities-_50097.html, accessed 21 July 2022.
16“FSC Plans to Improve Corporate Disclosure Rules,”Financial Services Commission website, www.fsc.go.kr/eng/
pr010101/75177, accessed 20 July 2022.

Greater China

Japan

China, the world’s biggest emitterof greenhouse gases,13 has set
a target of reaching Net Zerogreenhouse gas emissions by 2060.
Nevertheless, the country currently
has no mandatory requirement
for companies to disclose climaterelated financial and nonfinancial
information in their annual reports.
There has been some progresswith improving climate disclosure
policies in the last year or so, with
the China Securities Regulatory
Commission encouraging voluntary
reporting to reduce carbon
emissions and the People’s Bankof China publishing guidelines
for environmental disclosures byfinancial institutions, covering
at least one disclosure per year.
Deeper regulation is probably
required, however, to improve thecoverage and quality of climate
disclosures in China.14

New mandatory rules for climaterelated disclosures took effect inJapan in April 2022. Under therules, developed by the country’s
Financial Services Agency, around
4,000 large companies, including
those listed on the Tokyo Stock
Exchange, are required to reporttheir greenhouse gas emissions
and make other climate-related
disclosures in accordance with the
TCFD framework. The rules are due
to be extended to all companies that
submit annual securities reports forthe 2023 financial year.15

India
India continues to lag behindmost other markets, in terms ofboth the coverage and the qualityof its disclosures. That said, theBarometer did record a significant
year-on-year improvement incoverage, which was up to 65%
from 49% last year. This increase isalmost certainly linked to new rules
published by the Securities andExchange Board of India. These rules
require the country’s 1,000 largest
companies to produce a business
responsibility and sustainability
report from the 2022–2023
financial year onward. Companies
were encouraged to produce thereports on a voluntary basis for the
2021–2022 financial year.16

South Korea
The quality of disclosures madeby companies in South Korea has
increased considerably over the
past year. This could be linked toSouth Korea’s Financial Services
Commission announcing plans toimprove the country’s corporate
disclosure rules, including guidance
to promote voluntary disclosureof sustainable management
reports by listed companies.
Mandatory disclosure of sustainable
management reports are likely to be
gradually expanded to all companies
listed in the Korea Composite Stock
Price Index (KOSPI) from 2030.17

Southeast Asia
Southeast Asia is highly vulnerable
to the effects of climate change.
While the region lags behind mostothers in terms of the coverageand quality of its climate-risk
disclosures, it has made some
progress over the past year,
particularly with respect tocoverage. This is probably due toSouth Asia following global trends
around climate disclosures andregulators paying greater attention
to the TCFD recommendations.

17

Global Climate Risk Disclosure Barometer 13

Market focus

Some notable improvements indisclosure quality can be seen in many
European markets.

Spotlight on the EU
Alexis Gazzo, Climate Change Leader,
EY & Associés
As part of the European Green Deal, the EU
has set itself a binding target of achieving
Net Zero greenhouse gas emissions by
2050, including an intermediate step toward
Net Zero greenhouse gas emissions; it has
raised its 2030 climate ambition, committing
to cutting emissions by at least 55% by2030. The EU is working on the revision of
its climate-, energy- and transport-related
legislation under the so-called “Fit for 55”
package, in order to align current laws withthe 2030 and 2050 ambitions.
In addition, the European Commission has
proposed CSRD to improve the existing
reporting requirements of the EU’s NonFinancial Reporting Directive (NFRD).
This will more than triple the number ofcompanies in the EU that are required toreport on sustainability data, including
climate-related information.18
Approximately 49,000 large and listedcompanies in the EU will likely need toreport in compliance with European
Sustainability Reporting Standards (ESRSs)
developed by the EFRAG. Companies
already subject to NFRSD will have to reportfor financial years beginning on 1 January2024 (report to be published in 2025)
and large companies for financial years
beginning on 1 January 2025 (report to be
published in 2026).
Under the proposed standard on climatechange, ESRS E1, companies are expected

to be required to disclose information on
their emissions reduction targets and how
their targets are aligned with the 2015
United Nations Paris Climate Change
Conference (Paris Agreement) goals andlimiting global warming to 1.5°C. Also,
companies are also likely to be required
to report on the potential financial effects
of material physical risks and materialtransition risks, as well as climate-related
opportunities. Another new mandatory
disclosure under the standard could requirecompanies to report on their Scope 3
emissions, including emissions related to(i) upstream purchasing, (ii) downstream
sold products, (iii) goods transportation, (iv)
travel, and (v) financial investments.19
Another important development is thelaunch of the EU Taxonomy for sustainable
activities, which went live at the start of2022. The taxonomy has been designed
to help protect against greenwashing andhelps to channel capital toward genuinely
green activities by offering a classification
system that provides companies, investors
and policymakers with appropriate
definitions for which activities can beconsidered environmentally sustainable.20
The EU has also developed its Sustainable
Finance Disclosure Regulation, which setsout sustainability disclosure obligations for
asset managers and other financial market
participants, with the aim of improving
transparency for investors. The regulation isscheduled to apply from 1 January 2023.21
This policy landscape helps to explain
why this year’s Barometer recorded somenotable improvements, in terms of bothcoverage and quality of disclosures inmany European markets. Southern Europe
achieved a quality score of 52%, up from
43% last year, and its coverage score
jumped from 62% to 88%. Ireland recorded
exactly the same increase in coverage, while
its quality score leapt from 25% to 49%.
Meanwhile, in central and eastern Europe,
coverage increased from 58% to 84%, while
quality scored 43%, up from 29% last year.

Spotlight on Oceania
Pip Best, Climate Change and Sustainability
Services Partner, Ernst & Young, New
Zealand, and Fiona Hancock, Climate
Change and Sustainability Services Director,
Ernst & Young, Australia
Oceania is particularly vulnerable to thepotential impact of global warming. Yet,despite the risks it faces, the region trails
much of the world, in terms of both thecoverage and the quality of its climate
disclosures, according to this year’s
Barometer. A major reason for this is thehistoric lack of regulatory support forclimate-related disclosures. Change is underway, however, which should lead to boththe coverage and the quality of climate
disclosures improving in future.
New Zealand has already passed
legislation that makes climate-related
disclosures mandatory with effect fromthe 2023 financial year for around 200
entities. These entities include large listedcompanies, insurers, banks, nonbank
deposit takers and investment managers.22

18“Three ways businesses can help meet global climate goals,” EY website, https://www.ey.com/en_gl/sustainability/three-ways-business-can-help-meet-global-climate-goals, accessed 15 July 2022.

19

Exposure Draft: ESRS E1 – Climate change, European Financial Reporting Advisory Group, April 2022.

EU taxonomy for sustainable activities, European Commission website, https://ec.europa.eu/info/business-economy-euro/banking-and-finance/sustainable-finance/eu-taxonomy-sustainable-activities_en,
accessed 15 July 2022.
20

Regulation on sustainability-related disclosure in the financial services sector, European Commission website, https://ec.europa.eu/info/business-economy-euro/banking-and-finance/sustainable-finance/sustainabilityrelated-disclosure-financial-services-sector_en, accessed 21 July 2022.
21“Mandatory climate-related disclosures,” New Zealand Ministry for the Environment website, https://environment.govt.nz/what-government-is-doing/areas-of-work/climate-change/mandatory-climate-related-financialdisclosures, accessed 20 July 2022.
22

14

Global Climate Risk Disclosure Barometer

Market focus

The Barometer shows that US companies
have some work to do as they move towarddetailed, mandatory climate disclosures.

Meanwhile, earlier this year, the Australian
Prudential Regulation Authority issued
guidance for banks, insurers and pension
funds on managing and disclosing climaterelated risks, including physical, transitionand liability exposures. While the guidance
did not create new obligations, it suggeststhat Australia is moving toward a
mandatory regime.23
In addition, the Australian Federal
Government passed legislation enshrining
a pledge to cut carbon emissions by 43% by
2030 and to net zero by 2050.24 Investors
are demanding that companies make better
disclosures about their climate-relatedrisks and the country has seen a rise in civil
lawsuits alleging greenwashing.
Concerned that greenwashing may prevent
investors from making informed investment
decisions and undermine confidence,
the Australian Securities & Investments
Commission has warned companies
against making misleading and deceptive
statements in relation to sustainabilityrelated products. To improve the quality of
disclosure, it has also encouraged voluntary
disclosure in accordance with the TCFD.25
In Oceania, disclosure coverage increased
significantly on this year’s Barometer —up to 87% from 70%. In contrast, there wasa smaller improvement in quality — up to
49% from 42%.

Spotlight on North America
Stephanie Hamilton, Climate Change
and Sustainability Services Director,
Ernst & Young, Canada
The US SEC is planning to mandate
climate-risk disclosures by public companies
with a view to providing investors withconsistent, comparable and decisionuseful information. The proposed rules areprescriptive in their disclosure requirements(more so than the TCFD), and companies
would be required to disclose bothforward-looking information and “certain
disaggregated climate-related financial
statement metrics that are mainly derived
from existing financial statement line items”
in notes to their financial statements. This
would include the impact of the climaterelated events and transition activities
on company’s consolidated financial
statements.26
Additionally, under the proposed rules,
some SEC registrants would be required todisclose Scope 3 emissions (emissions fromthe upstream and downstream activities intheir value chain), if those emissions arematerial to investors or if the company has
committed to including a target around
Scope 3 emissions.
The Barometer shows that US companies
have some work to do as they move towarddetailed, mandatory climate disclosures.

While the coverage score for the US is 86%,
a slight increase on last year, its quality
score stands at 48%. This could be reflectiveof many US companies now reporting
to CDP for the first time, which is highlyaligned to the TCFD framework.
Canada has consistently performed strongly
on the Barometer over time, in termsof both disclosure coverage and quality.
Securities regulators have long emphasizedthat public company disclosures should
cover material information, including
material environmental matters, such as
climate change.27 After a public consultationlate last year, they are expected to go ahead
with more structured climate disclosure
requirements using the TCFD framework
in 2022.
Meanwhile, the Canadian government has
also endorsed the TCFD framework andalready made TCFD-aligned disclosuresmandatory for 2023 for Crown corporations(government-owned entities that holdmore than CA$1b in assets).28 Crown
corporations with fewer than CA$1b inassets will be expected to start reportingby 2024. Next, they are requiring federally
regulated banks and insurance companies
to provide disclosures on their climaterelated risks and exposures, startingfrom 2024.29“Australian regulator issues long-awaited climate risk guidance,” Reuters website, https://www.reuters.com/business/environment/australian-regulator-issues-long-awaited-climate-risk-guidance-2021-04-22,
accessed 20 July 2022.
23

24“Australia passes a law for net zero emissions by 2050,” Reuters website, https://www.reuters.com/world/asia-pacific/australia-passes-law-net-zero-emissions-by-2050-2022-09-08, accessed 8 September 2022.”“How to avoid greenwashing when offering or promoting sustainability-related products,” the Australian Securities & Investment Commission website, https://asic.gov.au/regulatory-resources/financial-services/howto-avoid-greenwashing-when-offering-or-promoting-sustainability-related-products, accessed 12 July 2022.
25

26“Statement on Proposed Mandatory Climate Risk Disclosures,” Securities & Exchange Commission website, https://www.sec.gov/news/statement/gensler-climate-disclosure-20220321, accessed 21 July 2022.

“Task force on climate-related financial disclosures (TCFD): Overview”, Chartered Professional Accountants Canada website, https://www.cpacanada.ca/en/business-and-accounting-resources/financial-and-nonfinancial-reporting/mdanda-and-other-financial-reporting/publications/tcfd-overview, accessed 21 July 2022.
27

28“Canada moves towards TCFD-aligned reporting”, https://environment-analyst.com/global/107647/canada-moves-towards-tcfd-aligned-reporting, accessed 12 August 2022.

“Climate Disclosures for Banks, Insurance Companies Beginning 2024,” Report Adviser website, https://reportadviser.info/news/canada-introduces-mandatory-climate-disclosures-for-banks-insurance-companiesbeginning-2024, accessed 21 July 2022.
29

Global Climate Risk Disclosure Barometer 15

316

Sectorfocus

Global Climate Risk Disclosure Barometer

Sector focus

All sectors that could be compared yearon-year recorded an increase in disclosure
coverage in 2022 and the vast majority
recorded improved quality.

Continuing the trend of previous
Barometers, the sectors with the mostsignificant exposure to transition
risk generally scored higher for theirdisclosures in 2022, in terms of both
quality and coverage.
Energy leads the way, with a coveragescore of 93% and a quality score of 51%.
It is followed closely by insurance, which
has the same quality score and a coveragescore of 90%. In fact, insurance recorded
a 34% increase in quality year-on-year. An
even higher percentage improvement inquality — 40% — was achieved by anotherfinancial services sector, financial asset
owners and managers.
For this year’s Barometer, the materials
and buildings industry featured as aseparate category from real estate (in the2021 Barometer, both categories werecombined). This separation has helped
to highlight materials and buildings asa strong performer for both disclosure
coverage and disclosure quality, withthe sector scoring particularly highly
in relation to targets and metrics. Thissuggests the sector is further intensifying
its efforts to reduce emissions, helped byinitiatives such as the Global Alliance for
Buildings and Construction.30
Significantly, given its high vulnerability
to the effects of climate change, theagriculture, food and forest products
sector continues to lag behind most othersectors, in terms of both coverage andquality. It performs particularly poorly
on the strategy and risk management
elements of the TCFD framework fordisclosure quality.

30

Limiting global warming to 1.5°C is amajor challenge for agriculture, foodand forest products, since it is likely torequire the sector to make far-reachingchanges to how it operates. The resultsof the Barometer suggest that companies
in the sector are still wrestling with thesensitive issues of transition plans and thepotential impact of climate-related risks
and opportunities on their business.

Overall, all sectors that could be compared
year-on-year recorded an increasein disclosure coverage in 2022 andthe vast majority recorded improved
quality. This trend probably reflects how
decarbonization is becoming more widely
integrated into organizational strategy,
rather than being treated as a separate
initiative.

Table 1. Sectors with the most significant exposure to transition risk continue to score higher
SectorQuality
2021

Quality2022

Coverage2021

Coverage
2022

Banks

46%

39%

77%

77%

Financial asset owners and managers

25%

35%

48%

72%

Insurance

38%

51%

57%

90%

Other financial institutions*

NA

46%

NA

86%

Agriculture, food and forest products

35%

37%

65%

76%

Energy

48%

51%

78%

93%

Materials and building**

NA

46%

NA

87%

Mining

38%

42%

68%

85%

Real estate**

36%

40%

67%

83%

Transportation

50%

46%

77%

84%

Retail, health and consumer goods

42%

44%

67%

86%

Telecommunications and technology

50%

46%

79%

87%

*Other Financial institutions - new category included this year to include exchanges, other financial service providers, rating agencies
and credit bureaus.
**Materials and buildings separated in 2022 from Real estate, buildings and construction in 2021.

“Global Alliance for Buildings and Construction,” United Nations Climate Change website, https://unfccc.int/news/global-alliance-for-buildings-and-construction, accessed 26 July 2022.

Global Climate Risk Disclosure Barometer 17

Sector focus

By the nature of its business, the financial services sector
is heavily exposed to climate risk ... (which) could lead toa sharp fall in asset prices and increased uncertainty ...
potentially destabilizing the entire finance system.
Spotlight on financial services
Alexis Gazzo, Climate Change Leader,
EY & Associés, and Emma Herd, Climate
Change and Sustainability Partner,
Ernst & Young, Australia
By the nature of its business, the financial
services sector is heavily exposed to climate
risk. Any acceleration in global warming,
together with the accompanying economic
consequences of that, could lead to a
sharp fall in asset prices and increased
uncertainty, impacting the balance sheets ofbanks and asset managers, and potentiallydestabilizing the entire financial system.
Given this context, and the fact that climate
reporting is at a relatively mature stage
within the banking sector, it is surprising thatbanks have appeared to have not performed
as well as some other sectors in this year’s
Barometer, in terms of both the quality andthe coverage of their disclosures. While
this may reflect the change to the sample
size, it could also reflect the steps that thebanking industry is taking to revise and reset
frameworks for climate reporting.
For example, The Glasgow Financial Alliancefor Net Zero (GFANZ) has developed adraft Net-zero Transition Plan framework
for the financial sector. This frameworkaims to support financial institutions todemonstrate and stakeholders to judge, thecredibility of their plans to accelerate andscale clean energy and transition-related
finance to levels consistent with limiting
global warming this century to 1.5°C.31

The insurance industry has performed
strongly in terms of both coverageand quality on this year’s Barometer,outperforming most other financial andnonfinancial sectors. This performance is
probably linked to the growing momentum
within the industry toward a transition to a
net-zero emissions economy. The insurance
industry is exposed to the risks of economic
losses caused by extreme weather events.
In 2021, insured losses from natural
catastrophes — including flooding in Europe
and a tornado in the US — reached around
US$120b globally.32
Last year, eight insurers and reinsurers
established the United Nations-convened
Net-Zero Insurance Alliance (NZIA),
now part of GFANZ, with the goalof transitioning their insurance andreinsurance underwriting portfolios tonet-zero greenhouse gas emissions by
2050.33 The NZIA, in collaboration with
the Partnership for Carbon Accounting
Financials, subsequently launched aworking group to develop the first global
standard to measure and disclose insured
greenhouse gas emissions.34
Asset management is another financial
sector that has improved considerably
year-on-year, in terms of both the quality
and the coverage of its disclosures. As they
sit at the top of the investment chain, large
asset owners and asset managers have long
been pushing companies to produce more
reporting on climate risk. Now, they

appear to have recognized that they can set
a positive example to the organizations they
invest in. Providing better climate-related
financial disclosures is an opportunity forthem to “walk the talk,” when it comes todriving up the quality of climate reporting.

Financing the transition
to a sustainable future
In 2018, Citi became the first
US bank to publicly report on its
efforts to implement the TCFD
recommendations. It has also madeclimate risk a central pillar of its
2025 Sustainable Progress Strategy.
As part of this strategy, Citi is
working to further integrate
climate risk into its risk policies
and governance frameworks, andanalyze and measure the impacts
of its portfolios. Furthermore, thebank is engaging clients in theirown climate risk management andlow-carbon transition strategies.34
In 2021, Citi announced that it
would be committing US$1t to
sustainable finance by 2030. It
plans to finance a wide array ofclimate solutions, from renewableenergy and clean technology
through to water conservationand sustainable transportation.36“GFANZ Releases Guidance on Credible Net-zero Transition Plans and Seeks Public Input to Accelerate Action,” Glasgow Financial Alliance for Net Zero website, www.gfanzero.com/press/gfanz-releases-guidance-oncredible-net-zero-transition-plans-and-seeks-public-input-to-accelerate-action, accessed 20 July 2022.
31“Natural disasters cost insurers $120 billion in 2021, Munich Re says,” Reuters website, www.reuters.com/markets/commodities/natural-disasters-cost-insurers-120-billion-2021-munich-re-says-2022-01-10, accessed
23 July 2022.
32“Global insurance and reinsurance leaders establish alliance to accelerate transition to net-zero emissions economy,” United Nations Environment programme website, www.unep.org/news-and-stories/press-release/global-insurance-and-reinsurance-leaders-establish-alliance, accessed 23 July 2022.
33“Partnership for Carbon Accounting Financials Collaborates with UN-convened net-zero insurance alliance to develop standard to measure insured emissions,” United Nations Environment programme website, www.
unepfi.org/news/industries/insurance/partnership-for-carbon-accounting-financials-collaborates-with-un-convened-net-zero-insurance-alliance-to-develop-standard-to-measure-insured-emissions/, accessed 23 July 2022.
34

35

Finance for a Climate-Resilient Future II, Citi, 2020.

36“Citi Commits $1 Trillion to Sustainable Finance by 2030,” Citigroup website, https://blog.citigroup.com/2021/04/citi-commits-1-trillion-to-sustainable-finance-by-2030, accessed 24 July 2022.

18

Global Climate Risk Disclosure Barometer

Sector focus

Spotlight on energy
Matt Handford, Climate Change andSustainability Principal, Ernst & Young LLP,
United States
Energy production accounts for almost
three quarters of all anthropogenic
emissions. The energy sector should,
therefore, be viewed as an important lowcarbon transition platform, aligning to the
expectations of investors and regulators, aswell as those of the markets more broadly.
It is not surprising, then, that energy isahead of other sectors on the Barometer,when it comes to disclosure quality andcoverage, as well as decarbonization
strategy. EU-based oil and gas companies
have increasingly focused on portfolio
diversification while more broadly, oiland gas producers are disclosing more
ambitious emissions reduction targets,typically focused on their own operations.
Their investors are demanding that they
do even more, however. For example, they
are calling on management teams to better
articulate short-, medium- and long-term
reduction targets and expand coverage
metrics to include Scope 3 emissions.
The industry is activating across the value
chain. For example, the Oil and Gas Climate
Initiative (OGCI) is a CEO-led initiative that
accounts for almost 30% of global operated
oil and gas production. It aims to accelerate
the oil and gas sector’s response to climatechange and explicitly supports the Paris
Agreement. Drawing on its collective
strength, it hopes to achieve net-zeroemissions as early as possible.37

Recognizing the fundamental shifts inenergy production that are required in a
below 1.5°C future, scenario analysis isvital to help energy companies plan forthe significant structural changes that arelikely to accompany the transition to a lowcarbon economy. For the global economy
to support the Paris Agreement goal,
emissions related to the consumption offossil fuels should decrease rapidly throughtechnological advances (such as carbon
capture and sequestration and greenhydrogen production), and increased uptake
and deployment of low-carbon alternatives(such as renewable energy production). This
shift will likely require energy systems todecarbonize, transport systems to electrify
and public transport to be powered by lowor zero-carbon sources.
Geopolitical circumstances can impact
short-term supply and demand of fossil
fuels that may be at odds with longer-termtransition scenarios. There is likely to bea continuing tension for the industry, as
it navigates these near-term cycles at thesame time as demonstrating an enabling
effect for the energy transition.

Business transformation
toward a net-zero target
UK energy company Shell set
a target to become a net-zeroemissions energy business by
2050. To help set the pace ofchange, Shell has also announced
a target of halving its Scope 1
and Scope 2 absolute emissions
by 2030, compared with2016. Shell is transforming its
business to meet its objectives,
providing more low-carbon
energy, such as charging forelectric vehicles, hydrogen, andelectricity generated by solar
and wind power.38 It has also
published the “Sky scenario,”
which outlines what it believes
is a technologically, industriallyand economically possible routeforward, which they believe
would be consistent with limiting
the global average temperaturerise to well below 2°C from preindustrial levels.39

Oil and gas producers are disclosing more
ambitious emissions reduction targets,typically focused on their own operations.
Their investors are demanding that they
do even more, however.

37“A catalyst for change,” Oil and Gas Climate Initiative website, https://www.ogci.com/about-us, accessed 24 July 2022.

38

Our climate target,” Shell website, www.shell.com/energy-and-innovation/the-energy-future/our-climate-target.html, accessed 24 July 2022.

39“Sky scenario,” Shell website, www.shell.com/energy-and-innovation/the-energy-future/scenarios/shell-scenario-sky.html, accessed 28 July 2022.

Global Climate Risk Disclosure Barometer 19420

Risks andopportunities

Global Climate Risk Disclosure BarometerRisks and opportunities

Nearly half (49%) of companies featured
on this year’s Barometer had conductedscenario analysis, compared with 41% in
the previous year.

The TCFD believes that companies
should use scenario analysis toassess the strategic and financial
implications of potential climate-relatedrisks and opportunities, disclosing
these in financial statements whereappropriate.40 It highlights two principal
forms of risk:•

In general, companies’ approach toscenario analysis is becoming moremature, partly because they are able toaccess reference scenarios to use as astarting point, such as those developedby the Network for Greening the
Financial System.41

2100) and RCP 2.6 (a lower risk future,
where the global temperature rise isbelow 2°C by 2100). The results reflectcompanies planning for what they see as
the effective worst-case and best-casescenarios in practice.

•

Physical risks: The practical andoperational risks posed to companies
and their value chains by climate eventsand acute climate change. For example,
these risks may pertain to fixed assets,
operations in climate-sensitive locations
and water availability.

The most common time horizonsreferenced were 2040-50, while 2027
also featured prominently for carbon
pricing scenarios.

Figure 6. Did the company mention they conducted scenario analysis?
If yes, what was the type of scenario analysis?

Nearly half (49%) of companies featured
on this year’s Barometer had conductedscenario analysis, compared with 41%
in the previous year. Representative
concentration pathway (RCP)
scenarios represent different measuresof atmospheric greenhouse gas
concentration trajectories for the longterm future, with the lowest scenario,
RCP 1.9, being the pathway that would
limit global warming to below 1.5°C, theaspirational goal of the Paris Agreement.

63%
No

37%

51%
49%
Yes

Comprehensive analysis
includes quantitative
analysis over and above
general qualitative analysis.

Qualitative only

Comprehensive

Type of scenario analysis
20%

The most commonly referenced
scenarios in the Barometer were RCP
8.5 (a high-emissions future, delivering atemperature increase of about 4.3°C by

Transition risks: The risks faced bycompanies, particularly resourceintensive organizations, from policy
action, technology or market changes
aimed to accelerate the transition to a
net-zero economy. A key transition risk
scenario is the so-called 2°C scenario,
which sets out an emissions trajectory
consistent with holding the increase in
the global average temperature to 2°C
above pre-industrial levels.

18%
14%

15%

11%

10%

9%

9%
6%

5%

4%

4%

IEA
B2DS

RCP 6

2%

2%

2%

IEA
NPS

IEA
450

IEA
CPS

1%

1%

1%

0%
RCP
8.5

RCP
2.6

RCP
4.5

2DS

IEA
SDS

NDCs

40

Recommendations of the Task Force on Climate-related Financial Disclosures, Task Force on Climate-Related Financial Disclosures, June 2017.

41“The future is uncertain,” NGFS website, www.ngfs.net/ngfs-scenarios-portal, accessed 23 July 2022.

REMIND IRENA GLOBIOM

Global Climate Risk Disclosure Barometer 21

Risks and opportunities

The most commonly referenced risks inthis year’s Barometer were acute physical,
chronic physical, market, emerging andregulatory risks.
Three-quarters (75%) of the companies
featured in this year’s Barometer said thatthey performed risk analysis. Nevertheless,a quarter did not, perhaps because they did
not see the usefulness of it or they struggled
to make sense of the climate-related data
made available to them. Alternatively, it may
be the case that they did the modeling but
chose not to disclose the outcomes.
Last year’s Barometer found that thosecompanies that performed risk analysis weremore heavily focused on physical risk (55%),
compared with transition risk (25%). In
contrast, this year’s research found that bothrisk types attracted nearly equal focus.

This shift is probably a reflection ofcompanies undertaking more in-depth
scenario analysis to understand both theoperational risks of climate change, as well
as a reflection of the TCFD recommendationthat companies complete scenarios to atleast a 2 degree future. The most commonlyreferenced risks in this year’s Barometer
were acute physical, chronic physical,
market, emerging and regulatory risks.
Nearly two-thirds (62%) of companies thatfeatured in this year’s Barometer performed
opportunity analysis. “Products and services”
was the most commonly listed opportunity,in line with last year’s Barometer.

Whilst for many companies their directemissions may be a proxy for the degree ofrisk they face from the climate transition,in many other cases there is a disconnect
between scope 1 and 2 GHG emissions
and their exposure. For example, manyorganisations in the fossil fuel value chain
themselves have relatively low emissions.
Also, the future prospects of companies
could inevitably hinge on how different
components of their overall value chain areaffected by the transition. Hence, companies
should consider the risks and opportunities
posed by their entire value chain as part oftheir scenario analysis.

Figure 7. Both physical and transition risks attracted nearly equal focus

No

25%
75%
Yes

49%

51%

Physical risk

Transition risk

66%

61%

60%

59%

57%

57%

57%

52%

Acute
physical

Chronic
physicalMarketEmerging
regulation

Reputation

Current
regulation

Technology

Legal

Risk analysis

Risk typeFigure 8. “Products and services” was the most common listed opportunity
52%
No

38%
62%
Yes

33%

Products andservices

Opportunity analysis
22

Global Climate Risk Disclosure Barometer

Resource
efficiency

31%

EnergysourceOpportunity type22%

Markets

16%

ResilienceRisks and opportunities

Decarbonization strategy
Unsurprisingly, the energy sector — which
is set to play a pivotal role in the transition
to a low-carbon economy — leads the
Barometer, when it comes to disclosing
decarbonization strategy. More than fourfifths of energy companies (81%) disclosed
either a specific net-zero strategy,transition plan or decarbonization strategy.
This compares with an average acrosssectors of 61%.

Figure 9. Does theorganization disclosea specific net-zerostrategy, transition plan or
decarbonization strategy?

No

39%
61%
Yes

1

Notably, the agriculture, food and forest
products sector had a very poor rate ofdisclosure of decarbonization strategy
compared with other sectors, reflecting
the complexity of the issues it is likely
dealing with as part of the decarbonization
process. Overall, however, nonfinancial
sectors performed significantly better
than financial sectors, when it came
to disclosing their decarbonization
strategies.

While nonfinancial sectors can primarily
focus on their own sector alone, financial
sectors should understand the shifts taking
place across all the sectors and assets
they are providing financial capital for, as
well as the financial implications of thoseshifts, to be able to disclose a credible
decarbonization strategy.

Nonfinancial sectors
Energy81%

Mining66%

34%

Real estate

63%

37%

Materials and building

61%

39%

48%

52%

Financial sectors
Insurance
Banks

Financial asset owners and managers
Other financial institutions (e.g. exchanges)

3

32%Transportation

Agriculture, food and forest products

2

19%

68%

75%
53%
46%

25%
47%
52%

52%

48%

High risk sectors

Telecommunications and technology
Retail, health and consumer goods

61%
53%

39%
47%

Portfolio rebalancing in the mining sector
Australia-based mining company BHP has set a target of 2030 for reducing its operational emissions by at least 30% from thelevel they were at in 2020.42 Over a period of years, it has been gradually shifting its business portfolio away from carbonintensive industries, such as thermal coal mines, toward “future-facing commodities,” such as copper and nickel. These
commodities are crucial to the technologies that can support decarbonization.

“We have set targets* and a goal for reducing operational greenhouse gas (CHG emissions) Scope 1 and Scope 2 from our operated assets,” BHP website, www.bhp.com/sustainability/climate-change,
accessed 23 July 2022.
42

Global Climate Risk Disclosure Barometer 23

524

Financial impact
of disclosures

Global Climate Risk Disclosure Barometer

Financial impact of disclosures

The Barometer shows that companies
are only making limited progress withintegrating their climate reporting with
their financial statements. This is despite
the fact that financial disclosures area clear priority for the TCFD and arereferenced in its name. Overall, fewer thana third (29%) of companies are referencing
climate-related matters in their financial
statements, as both qualitative andquantitative aspects. What is more, themajority (54%) of references are qualitative
rather than quantitative in nature. Thesefindings suggest that, while companies
are improving the coverage and quality of
disclosures, they are struggling to bringthe information together in a financiallymaterial and meaningful way.
A reason for this could be that the financeteams of companies do not have theknowledge to understand where climate
risks sit in the context of the financial
statements and how material thoseclimate risks are. A further challenge
is that financial statements refer to acomparatively short time horizon, whereas
climate risk is relevant to a much longer

timeframe. This mismatch makes it difficult
for companies to properly assess theimpact of climate risk in their statements.
Furthermore, the uncertainty involved
with climate scenarios, and the range ofpossible outcomes, present challenges,
when it comes to including these scenarios
in financial models.

When a company cites a climate-related
matter in a financial statement, it makesa provision that it will account for possible
future impacts. Climate or environmental
risk was the most commonly referenced
term in the financial statements, cited by
29% of companies. Asset impairment was
the second most commonly referenced
term, cited by 16%, while property, plantand equipment came third, cited by 12%.

29%

46%

Qualitative

16%

Quantitative

12%

Climate/Asset
Property,
environmental impairment plant andrisk
equipment

76%
54%

46%

42%

Banks

Financial asset
owners andmanagers

60%

58%

24%

Insurance

In contrast, banks scored poorly forquantitative disclosure — despite their
exposure to the risk of sudden falls in
asset prices due to climate change. Thisis because of the challenges banks facewith calculating their exposure to carbonintensive assets, both now and going
forward. The quantitative disclosure of theretail, health and consumer goods sector
also lagged behind other sectors.

Common referenced terms

54%

71%
29%
Yes

The Barometer highlighted some strong
sectoral differences in relation to thereferencing of climate-related matter inthe financial statements. The strongestperforming sectors were materials andbuildings, financial institutions (including
exchanges and rating agencies) andinsurance. These sectors performed
comparatively highly for quantitative
disclosure.

To overcome these problems, there isa need to address methodology gaps
and provide additional education andtraining for company finance teams, aswell as auditors. It is also important topromote deeper intra-company integration
among finance, sustainability and risk
management functions.

Figure 10. Are climate related mattersreferenced in financial statements?

No

Future versions of the Barometer should
show a steady increase in the percentage
of companies referencing financial impact
in their statements.

40%

54%

46%

Other
Agriculture,
financial
food and forest
institutions (e.g.
products
exchanges)

50% 50%

EnergyQualitative

62%
38%

Materials
and building

8%

7%

7%

7%

5%

5%

4%

Cash flows

Liabilities
assured

Green
bonds

Goodwill

Intangible
assetsRenewableenergyEmission
impact50% 50%50% 50%MiningRealestate

56%

60%
44%

Transportation

40%

53%

47%

Retail,Telecommunications
health andand technology
consumer goods

Quantitative
Global Climate Risk Disclosure Barometer 25

Financial impact of disclosures

US$125t
in investment required by 2050
to achieve net zero.43

The investor perspective
Investors around the world are playing
a crucial role in driving up the quality ofreporting on climate-related risks. Thisis due to their strong requirement forrobust information that will allow them toaccurately price risk. Not only have they
been challenging management teams on
climate issues at annual meetings, but they
have also been engaging with policymakers
and regulators, advocating for better
disclosure regimes.
Investors are conscious that the transition
to a lower-carbon economy may undermine
the business models of companies thatengage in certain activities, or even resultin them ceasing to be viable altogether.
This, in turn, would impact on investment
returns. Furthermore, the risk profile ofcompanies may change significantly as
they are exposed to more extreme weather
events, such as flooding and heat waves,as well as policy developments relating
to regulation and tax.

Climate risk disclosures support investors
to identify those companies that are
most at risk from climate change, toassess what actions they are taking, andto compare and contrast companies’
strategies for mitigating climaterelated risk. When allocating capital,
investors are increasingly relying on
climate risk disclosures, as well as othersustainability-related disclosures, toinform their decision-making. In fact,
nearly three-quarters (72%) of investors
surveyed for the 2020 EY Climate Change
and Sustainability Services (CCaSS)
Institutional Investor survey said thatthey conduct a structured, methodical
evaluation of nonfinancial disclosures that
relate to the environmental and social
aspects of a company’s performance.43

investors are hungry for informationfrom companies that provides them withauthentic insights into where the realopportunities lie.
While they seek information to inform
capital allocation, investors are also asking
some challenging questions about theextent to which they can rely on the ESG
information currently being provided andhow that information can be more closely
connected with financial materiality.
Research by EY teams, “The emerging
sustainability information ecosystem,” hashighlighted, for example, that investors
focused on financial risk can find that alack of transparency around the calculationof ESG ratings reduces the decisionusefulness of those ratings.45

While presenting risks, the transition toa lower-carbon economy also presents
considerable opportunities to investors —with US$125t in investment required by
2050 to achieve net zero.44 Hence,

43

How will ESG performance shape your future?, EY, 2020.

44“What’s the cost of net zero?” Climate Champions website, https://climatechampions.unfccc.int/whats-the-cost-of-net-zero-2, accessed 23 July 2022.

45

The emerging sustainability information ecosystem, EY, 2022.

26

Global Climate Risk Disclosure Barometer

Financial impact of disclosures

Climate risk disclosures enable investors
to identify those companies that are mostat risk from climate change, to assess what
actions they are taking, and to compare andcontrast companies’ strategies for mitigatingclimate-related risk.

Global Climate Risk Disclosure Barometer 27

628

Futureforecast

Global Climate Risk Disclosure BarometerFuture forecast

The climate reporting landscape is evolving
at pace — as the events of the past year
have shown — and it looks set to evolve
even faster in future. The direction of
travel has been made clear, thanks to the
combination of high-level policy decisions,
regulatory action, the launch of the ISSB,
and a number of key jurisdictions aroundthe world moving decisively towardmandatory disclosures on climate-relatedrisks and opportunities for companies.
As a result of these developments, weare beginning to see the emergence ofa shared view on climate reporting anddisclosures. We are also moving toward
a common approach to climate-related
disclosures, which is likely to have atransformational impact on the global
coverage and quality of reporting overthe coming years.
In response to the evolving landscape,companies are looking more closely at
how they can integrate reporting on
climate issues into their mainstream
financial reporting. They are also investingin systems and resource capabilities toimprove the quality of their reporting.
These investments have the potential toprovide returns in the form of improved
disclosure quality that should be evident
in future Barometers.
As well as assessing their approach
to climate reporting, companies arealso reassessing their decarbonization
strategies. It is becoming increasingly
obvious that many companies will likely
struggle to meet the ambitious targets
they have set themselves unless they starttaking radical action soon. Companies arebeing pressed by investors and regulators
to demonstrate that they have a short- or
medium-term target that puts them on
track to meet 2050 net-zero goals.
According to the International Energy
Agency, around US$90b of public money
needs to be mobilized globally to complete a
portfolio of demonstration projects (projects
that promote innovation and disseminate
leading practice in relation to carbonization)by 2030. Currently, however, only US$25b
is budgeted for that period.46

As a result, banks, investors and thedebt markets are likely to come underincreasing pressure from governments
to fund the energy transition. Thispotentially creates a conflict with their
existing strategies to decarbonize theirportfolios from a debt perspective. So,
the challenge for banks and investors is tofind ways to balance their portfolio froma risk perspective, while increasing theirinvestment in those sectors that shouldurgently decarbonize.
Finally, as policy developments in the EU
highlight, the focus of investors, regulatorsand other stakeholders going forward
will likely not just be on the financiallymaterial impacts of climate on business.
Increasingly, they also want to know what
impact a business is having on the climate.
As a result, the issue of double materiality
will likely continue to rise in prominence.
There can be a huge difference in termsof the level of emissions generated by anorganization and how that organization
itself is impacted by climate change.
For example, a high emissions-intensive
business may be less exposed to transition
risk than a low emissions-intensive
business, if it produces goods that aresought after in a low-carbon world.
Growing interest in double materiality
could therefore pose challenging questions
for businesses to answer — challenges thatthey can expect to have to answer intheir disclosures.

Taskforce on Nature-related
Financial Disclosures
The Taskforce on Nature-related
Financial Disclosures (TNFD) is a
global, market-led initiative thataims to develop a risk managementand disclosure framework fororganizations to report and act
on evolving nature-related risks.
Its aim is to support a global
shift in capital flows “away fromnature-negative outcomes andtoward nature-positive outcomes.”

46

Net Zero by 2050, International Energy Agency, 2021.

47

About the Taskforce on Nature-related Financial Disclosures,” TNFD website, https://tnfd.global/about, accessed 23 July 2022.

Launched in June 2021, the TNFD
represents financial institutions
and market service providers with
US$19.4t in assets.47 It is due torelease its final recommendations
for its framework in September
2023.
The TNFD framework is intended
to be a foundational framework
for reporting on nature, just as the
TCFD framework is a foundationalframework for reporting on climate.
Given that the TCFD framework
underpins climate disclosure inmarkets around the world, it isreasonable to expect that the
TNFD framework will do the samefor nature.
Companies can draw on the lessons
they have learned from TCFD
reporting, as they prepare forreporting under the TNFD. Elements,
such as governance and strategy,
have the potential to be fairly
straightforward to integrate into
nature reporting, but targets andmetrics are likely to be much harder
due to the complexity involved withbiodiversity-related issues. WhileCO2e is a commonly used metricin climate reporting, there is noequivalent for biodiversity.
Nevertheless, the principle behind
TNFD reporting is fundamentallythe same as the principle behind
TCFD reporting. The framework asks
companies to consider the risks they
face and how these impact on theirfinancial performance over the longterm. Also, how are these risks likely
to impact their portfolio of business?
To perform TNFD reporting,companies will likely need to collectlarge amounts of data —from bothinternal and external sources. They
should also be able to manage andmake sense of the data, in order todisclose the right information.

Global Climate Risk Disclosure Barometer 29

7

Action for
decarbonization

Action for decarbonization

6%

The transition to a lower-carbon economy
is the largest economic transition that we
could see globally within our lifetimes. It
will likely require the complete decouplingof economic growth from greenhousegas emissions, as well as far-reaching
corporate transformation.
The world will only be able to achieve
the Paris Agreement target of a 1.5°C
rise in temperature above pre-industrial
levels through a rapid reduction in
global emissions and the comprehensive
decarbonization of the global economy.
Yet, in practice, there is no sign that thisis actually taking place.
Global energy-related carbon dioxide
emissions rose by 6% in 2021 to 36.3
billion tonnes, their highest-ever level,

Global energy-related carbon dioxide
emissions rose by 6% in 2021 to 36.3 billion
tonnes, their highest-ever level, according to
the International Energy Agency.

according to the International Energy
Agency.48 Meanwhile, a new study led by
the UK Met Office has predicted that global
temperatures will continue to rise, withthere being a 50:50 chance that one of theyears between 2022 and 2026 will exceed
1.5°C above pre-industrial levels, moving
us closer to a scenario, where 1.5°C is
exceeded for extended periods.49
Left unchecked, rising temperatures
could inevitably have negative impacts oncompanies, in terms of both physical andtransition risks. Meanwhile, it is clear that
there is a major disconnect between thedisclosures that companies are making
under the TCFD framework and theirreal-life decarbonization journeys, as they
pertain to their operations and supply

chains. If companies — and countries — areto stand any chance of meeting their 2050
targets, let alone their 2030 targets, major
progress should be made over the next
12 months.
So, what can your own organization do toaccelerate both its own decarbonization
journey and the decarbonization of the
global economy, drawing on climate risk
disclosure as a robust basis for corporatetransformation?

48“Global CO2 emissions rebounded to their highest level in history in 2021,” IEA website, www.iea.org/news/global-co2-emissions-rebounded-to-their-highest-level-in-history-in-2021, accessed 24 July 2022.

49“Temporary breaching of 1.5C in the next five years?” Met Office website, www.metoffice.gov.uk/about-us/press-office/news/weather-and-climate/2022/decadal-forecast-2022, accessed 24 July 2022.

Global Climate Risk Disclosure Barometer 31

Action for decarbonization

If we are to accelerate progress, we needcompanies to be more transparent about
the process they’re following to achieve theiremissions targets, the investments they’remaking, and what they’re doing in the event
they miss those targets.

1. Treat disclosure as a means toan end, rather than an end itself:
Ultimately, decarbonization is the resultof the real-world actions that companies
take, not the information they disclose in
their reports. Nevertheless, companies canuse their disclosures as a means of holding
themselves to account for how they reduce
their carbon footprint, while creating value
for their stakeholders over the long term.

2. Set meaningful targets:
Many companies with complex value
chains generate the majority of theiremissions indirectly, through thesevalue chains. What is more, they may set
ambitious reductions targets without fully
understanding their current baseline. Does
your own organization have a genuine
appreciation of its own capability todecarbonize not only its own operations,but its supply chain as well? If not, how
can it develop this appreciation? Also,
how is your organization allocating capital
investment to bring about the transition
to a low-carbon economy? Is it making useof marginal abatement cost curves andoptimizing strategy to increase its chancesof reaching a net zero target?
If we are to accelerate progress, companies
should be more transparent about theprocess they’re following to achieve
their emissions targets, the investments
they’re making, and what they’re doingin the event they miss those targets.

32

Global Climate Risk Disclosure Barometer

Targets should be looked at on a holistic
basis, taking into consideration entire
value chains, as well as different climaterelated scenarios, including a 2°C or
lower scenario. Science-Based Targets
are available to all sectors apart from oil
and gas. While they have their limitations,
Science-Based Targets can offer a usefulpathway to companies looking to reduce
their greenhouse gas emissions.

3. Assess strategy:
Not only should climate strategy
be disclosed, but it should also becomprehensively assessed on an ongoingbasis. Does your company continually
ask itself whether its strategy iscomprehensive and credible, whether
it covers the most important issues andwhether it is aligned with the targets of theParis Agreement? Does it perform scenario
analysis to understand all the risks andopportunities associated with a change
in strategy? And does it have a capital
allocation plan to provide confidence thatinvestment is channeled toward the rightprojects? Finally, of course, it is crucial to
implement the strategy using a detailed
execution plan.

4. Perform scenario analysis:
Assessing the impact of different futurescenarios should be fundamental to yourorganization’s future strategy. Use scenario
planning to stress-test your current
strategy in light of different potential
eventualities and understand which

scenarios could lead to your businessbecoming unprofitable. The scenario
analysis should highlight opportunities
to adjust business strategy and boost
resilience. When assessing the likelihoodof different scenarios, it’s important tostay close to the science and the policy
environment to understand the latest
climate-related trends.

5. Explore the opportunity:
Companies can often be concerned about
discussing opportunities in their disclosures
for fear it looks like they are exploiting thethreat of climate change. The reality isthat transformation creates opportunities,
however. As your organization channels
greater investment into climate solutions,
it has a chance to make some big strategic
decisions, which may include transforming
its whole portfolio of business, while
reducing its emissions footprint. As
discussed, performing scenario analysis
may help your organization to fully
understand the available opportunities andlook at the targets that have been disclosed
by its banks as a means of identifying
suitable finance options.

6. Collaborate to succeed:
Collaboration — including both publicprivate and company-to-company
collaboration — is vital to achieving on theambitious decarbonization targets set
by both governments and organizations.
Is your organization working withother organizations, as well as national

Action for decarbonization

authorities, to innovate, ensuring that
finance is directed to the projects most
likely to drive change? Are you helping toprovide confidence that your reporting
capabilities inform policy and decisionmaking, at both an organizational anda national level? Progress depends on
businesses managing climate risk thatis outside of their own organizationaland operational control. As such, yourorganization should be collaborating withthe other members of its value chain todevelop new and innovative solutions
that reduce emissions and accelerate
decarbonization.

The role of reportingin decarbonization
Here are three ways inwhich your organization can use
corporate reporting to support its
decarbonization strategy:
1.

7. Track performance in real time:
Investors and banks will be paying
increasing attention to how companies
perform against their environmental
targets, as those targets draw nearer. As
a result, companies that miss the targets
they have set themselves can expect tosee an impact on their valuations. Your
organization can prepare for greater
scrutiny from investors by embedding
real-time tracking of climate performance
into its organizational risk management
practices and operations.

and risks presented by climatechange in terms of the products
and solutions they develop?
By studying the disclosures ofothers, your organization canfind ways to enhance its own
strategy, better understandthe financial impact of climatechange, and more effectively
communicate its performance.

2.

Prioritize materiality:
Decarbonization is a big,complex and challenging
process. With so many elements
to consider, companies canget so caught up in the detailthat they can lose sight of the
big picture. Reporting can bea useful way to focus on whatmatters. Rather than trying toreport on every standard andmetric, is your organization
concentrating on materiality?
It should be telling a sharp,
focused and integrated story
about the financial risks andopportunities that climatechange presents to its business.
Benchmark disclosuresagainst peers: Companies
may consider looking at what
their customers, competitorsand suppliers are disclosing
as their greatest challenges.
What is the carbon intensity of
their emissions? How are they
responding to the opportunities

3.

Prepare for the
implementation of the ISSB’s
new standards: The processof reporting on climate andother sustainability-related
matters is set to be transformedby the ISSB’s global baselineof sustainability disclosures.
The new standards will help
to bring greater comparability
and transparency to thereporting process, helping tohighlight companies that may
be engaged in greenwashingor making insufficient progressagainst their targets. Therefore,
companies should provide
confidence they have theappropriate processes andgovernance in place to respondto the higher levels of scrutinythat will accompany global
adoption of the standards.

Global Climate Risk Disclosure Barometer 33

About thisresearch

34

Global Climate Risk Disclosure BarometerAbout this research

The 2022 Barometer analyses the extent towhich companies have applied the TCFD
framework to more effectively disclose
climate-related risks and opportunities
through their reporting processes.

The EY Global Climate Risk Disclosure
Barometer provides an annual overview
of the alignment of organizations’climate-related risk disclosures with therecommendations across sectors likely
to be highly impacted worldwide.
This assessment provides not only
companies, but also external stakeholdersof all types, such as national regulators,
financial institutions and investors, with anunderstanding of the current state of global
climate risk reporting. The first edition of theBarometer was issued in December 2018.

4th edition
Examines disclosures from overThe 2022 Barometer analyses the extent
to which companies have applied the TCFD
framework to more effectively disclose
climate-related risks and opportunities
through their reporting processes. It draws
on public disclosures produced during the2021 calendar year by companies in boththe financial and nonfinancial sectors,
including companies that are at high riskof climate-related impact. These disclosures
were typically made in annual sustainability
reports and CDP reports.

Proportion of sample

Mandatory TCFD disclosure

1,504 companies

Western/Northern Europe

14% 14%(majority of listed companies)

13 exposed sectors in 47 countries*
Selected
sectors

Number ofcompanies reviewed

Financial

370

Nonfinancial

1,135

Total

1,504

The disclosures of more than 1,500
companies (the largest by market
capitalization) across 47 jurisdictions were
included in the assessment, broadening
the size and geographical scope from2021, when the research was based on
more than 1,100 companies across 42
jurisdictions. In addition, the scoring matrix
for the Barometer has been evolved andrefined since last year to become evenmore detailed and robust. Because of thesechanges, it was not possible to include ameaningful in-depth year-on-year analysis.

CanadaCanada5% 5%

UK

20% 10%

4% 4%

5% 4%
Ireland

USA

Central/Eastern Europe

UK

EU

Southern Europe

Greater China

8% 7%

7% 11%

2% 3%

India

6% 4%

3% 3%

Disclosures made in annual, sustainability,
CDP reports and other reports publishingwithin the 2021 calendar year.
Companies were scored through a multitiered system including both the coverageand quality of the TCFD recommendations.
*Russia is excluded from CRB 2022

Singapore

9% 11%
Australia

8% 5%

3% 3%

2022

Southeast Asia

Oceania

Africa

Japan

3% 6%

2% 2%

3% 3%

Central/South America

Japan

South Korea

Middle East

2021

Increase/decrease in the companies pertains to language constraints/country POC’s inputs and selectionof companies by Market Cap, revenue and no of employees

Global Climate Risk Disclosure Barometer 35

About this research

Scoring
In addition to the annual snapshotof organizations’ uptake of therecommendations, this year’s
Barometer explores:•••

The quality of climate-related
disclosures across markets
and sectors
Comparisons of disclosures
between companies that doand do not disclose throughCDP
The extent to which companies
use scenario analysis andwhether that analysis isqualitative or quantitative•

Whether companies use risk
and opportunity analysis•

Decarbonization strategy
analysis•

Referencing of climate-related
matters in the financial
statements

Companies were scored on two different
metrics: the coverage and quality of
disclosures.

CoverageCompanies were assigned a score (inpercentage) on the basis of the numberof TCFD recommendations addressedby them. A score of 100% indicated thatthe company had disclosed some levelof information compliant to each of therecommendations, regardless of thequality of information provided.

QualityCompanies were given a rating (out of five)
based on the quality of the disclosure,
expressed as a percentage of the maximum
score, should the company implement all
11 recommendations. A score of 100%
indicates that the company had adopted

all the recommendations and the qualityof the disclosure met all the requirements of
the TCFD (i.e., gaining a maximum score of
5 for each of the 11 recommendations).50
The quality of the disclosures was scoredusing the following scoring system:51
0 – Not publicly disclosed
1 – Limited discussion of the aspect (or only
partially discussed)
2 – General discussion or disclosure of the
aspect3 – Detailed discussion or disclosure of the
aspect4 – Well-developed disclosure of the aspect
5 – Market-leading disclosure of aspect;addressed all features of aspect in disclosure

Note: The scoring matrix for this analysis was updated to reflect the 2021 revised guidance from the TCFD for metrics, targets andtransition plans. These changes are likely to have caused a decline in quality scores due to the stricter guidance.
50

Note: This scoring matrix was updated to include more granular scores of 0,1,2,3,4 and 5, compared with possible scores of 0, 1, 3
and 5 in previous research. This could have impacted the likelihood of scores achieving a rating of 4 rather than 5.
51

36

Global Climate Risk Disclosure Barometer

Financial impact
Aboutofthisdisclosuresresearch

EY contacts
Matthew Bell
Global CCaSS Leader
matthew.bell@uk.ey com
Velislava Ivanova
Americas CCaSS Leaderveli.ivanova@ey.com
Jan Niewold
Europe, Middle East, India
and Africa CCaSS Leader
jan.niewold@nl.ey.com
Terence Jeyaretnam
Asia Pacific CCaSS Leader
terence.jeyaretnam@au.ey.com

Global Climate Risk Disclosure Barometer 37

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