Task Force on Climate-related
Financial Disclosures
Public Consultation Summary
April 18, 2017

BACKGROUND
The Financial Stability Board (FSB)
established the Task Force on Climaterelated Financial Disclosures (TCFD) in2015 to develop recommendations formore effective climate-related disclosures
that:Industry Led and GeographicallyDiverse Task ForceThe Task Force’s 32 international members, led byMichael Bloomberg, include providers of capital,
insurers, large non-financial companies, accounting
and consulting firms, and credit rating agencies.

‒ could “promote more informed
investment, credit, and insurance
underwriting decisions” and,‒ in turn, “would enable stakeholders
to understand better theconcentrations of carbon-related
assets in the financial sector andthe financial system’s exposures toclimate-related risks.”

2

PUBLIC CONSULTATION APPROACH
The Task Force on Climate-related Financial
Disclosures released its report for a 60-day publicconsultation on December 14, 2016. The
consultation period closed on February 12, 2017.
•The public consultation was conducted through an
online questionnaire designed to gather feedbackon the report, guidance, and key issues identified bythe Task Force.

•The Task Force received 306 responses to theonline consultation questionnaire and 59
comment letters on the report and guidancefrom a variety of organizations.

•14 of the 59 respondents that submitted commentletters did not also complete the online
questionnaire, resulting in a total of 320 unique
responses.

Please note that due to rounding the numbers in certain charts throughout the presentation may not add to 100%

3

GEOGRAPHICAL DISTRIBUTION
The Task Force received online responses and comment letters from respondents in 30
countries, including 15 of the G20 jurisdictions.
Organizations that provided both online submissions and comment letters are counted in the“Online Consultation Responses Received” totals.
COMMENT LETTERS FROM UNIQUE RESPONDENTS

ONLINE CONSULTATION RESPONSES RECEIVEDCountry

Responses

Country

Responses

Country

Responses

United Kingdom

4France1

Canada2Germany

1

Switzerland

2

India

1United States

2

Saudi
Arabia1

Australia

15

Italy

5

Austria

2

Japan

25

Belgium

10

Luxembourg

1

Belize1

Mauritius

1

Brazil8

Mexico1

Canada19

Netherlands

11

Colombia

1

Norway5Denmark

1Peru

1Finland

1

Singapore

4France27

Sweden6Germany

16

Switzerland

8

Greece1Turkey2Hong Kong

6

United Kingdom

78

India

7

United States

42

Indonesia

1CountryResponses

ONLINE RESPONSES BY REGION
0.3% 3.6%
EuropeNorth America

19.0%

Asia Pacific
20.3%

56.9%

Middle East/Africa
South America

4

TYPES OF RESPONDENTS
Respondents were asked to provide information on their industry and their perspective on
the recommendations as a user, preparer, or user and preparer of disclosures, or other. In
addition, respondents noted their area of responsibility.
PERCENTAGE OF RESPONDENTS BY SECTOR
Financial39%

43%

PERCENTAGE OF RESPONDENT TYPE

Non-Financial
NGOs andOthers18%

132 respondents work in the financial sector, 54 in nonfinancial sectors, and 120 in “Academia,” “NGO”, or “Other”
categories (“NGOs and Others”).

192 respondents identified
themselves as users of disclosure,
191 as preparers of disclosure, and49 as “other.”*

11%
45%
44%

PERCENTAGE OF RESPONDENTS BY ROLE

4% 3%
7%

21%

9%
14%

12%
8%

22%

Sustainability
Other
Investment/Asset Management
Academic/Industry Expert
Government/Regulatory Affairs
Finance/Corporate Reporting/Strategy
Admin/General Management
Legal/Risk/Compliance
Board Member

User

Preparer

Other

Respondents represented a variety ofroles, most commonly sustainability andinvestment/asset management.

5RESPONSES AT A GLANCEThe Task Force asked respondents whether certain aspects of its recommendations andguidance were useful. The table below lists the questions asked and summarizes theresponses.
USEFULNOTUSEFULNEITHER

DON’T
KNOW

Preparers

75%

12%

11%

2%

Preparers

66%

14%

18%

2%

77%

3%

10%

10%

Financial

74%

7%

9%

10%

Non-Financial

17%

50%

26%

7%

NGOs and Others

86%

7%

6%

2%

Financial

74%

4%

5%

17%

Non-Financial

33%

33%

30%

4%

NGOs and Others

72%

3%

15%

11%

Financial

68%

11%

14%

8%

NGOs and Others

74%

7%

13%

7%

QUESTIONRESPONDENTS

How useful are the recommendations and guidance for all
sectors in preparing disclosures?
How useful is the supplemental guidance in preparing
disclosures?

If organizations disclose the recommended information, howUsers and Others
useful would it be for decision making?
How useful is a description of potential performance acrossa range of scenarios to understanding climate-related
impacts on an organization’s businesses, strategy, andfinancial planning?
How useful are the illustrative examples of metrics andtargets?

How useful would the disclosure of GHG emissions
associated with investments be for economic decisionmaking purposes (e.g., investing decisions)?

6

KEY THEMES
Overall, commenters were generally supportive of the Task Force’s recommendations;however, several provided specific and constructive feedback on the report.
The key themes from this feedback are included below. The Task Force will address these themesin the final version of the report.
Materiality and Location of Disclosures

Scenario Analysis

Clarifying which recommended disclosuresdepend on materiality assessment andproviding flexibility for organizations toprovide some or all disclosures in reports
other than financial filings.

Improving ease of implementation, andcomparability of scenario analysis byspecifying standard scenario(s) and providing
additional guidance and tools.

Metrics for Non-Financial Sectors
Improving comparability and consistency of
the illustrative metrics for non-financial
sectors, clarifying the links to financial impact
and climate-related risks and opportunities.

Metrics for the Financial Sector
Encouraging further development andstandardization of metrics for thefinancial sector.
Implementation
Providing disclosure examples to support
preparers in developing relevant climaterelated disclosures.

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USEFULNESS OF RECOMMENDATIONS AND GUIDANCE
Preparers were asked how useful Task Force's recommendations and guidance for all sectors
are in preparing disclosures.
75% responded that the recommendations and guidance for all sectors would be quite useful orvery useful.
RESPONDENTS

USEFULNOT USEFULNEITHER

DON’T KNOW

75%

12%

11%2%Preparers

PERCENTAGE OF RESPONDENT TYPE
Very Useful37%

Quite Useful

13%
52%

Neither/Nor

2%

30%

Not Very Useful

4%

23%

Not Useful at All
1%

31%
25%

58%

9%
2%

8%

Don't Know

2%
3%

Financial

Non-Financial

NGOs and Others

Base size (asked of Preparers): 191

8USEFULNESS OF RECOMMENDATIONS AND GUIDANCE (CONTINUED)
Preparers were asked how useful Task Force's
supplemental guidance is or would be for preparing
disclosures.
66% responded that the supplemental guidance would bequite useful or very useful.
RESPONDENTS
Preparers

USEFUL66%

NOT
USEFUL
14%

NEITHER
18%

DON’T
KNOW
2%

Base size (asked of Preparers): 191

Users and Others

Very Useful

USEFULNOTUSEFULNEITHER

DON’T
KNOW

77%

3%

10%

10%

Base size (asked of Users and Others): 241

8% 16%

26%

Quite Useful

53%

Neither/Nor 12%

34%

64%

25%
11%

Not Very Useful 4%21% 9%
Not Useful at All
Don't Know

1%

11%

2%
3%

Financial

Users and others were asked if organizations disclose
the recommended information, how useful would it
be for decision making purposes (e.g., investment,underwriting, and lending).
77% responded that the disclosures would be quite
useful or very useful.
RESPONDENTSPERCENTAGE OF RESPONDENT TYPE

Non-Financial

NGOs and Others

PERCENTAGE OF RESPONDENT TYPE
Very Useful33%

Quite Useful
Neither/Nor

47%

31%
44%

10% 9%

Not Very Useful 2% 3%
Not Useful at All
Don't Know1%
8% 14%

Financial

NGOs and Others

9USEFULNESS OF SCENARIO ANALYSIS
All respondents were asked about the usefulness ofa description of potential performance across a
range of scenarios to understanding climate-related
impacts on an organization’s businesses, strategy, andfinancial planning.
RESPONDENTSAll

USEFULNOTUSEFULNEITHER

DON’T
KNOW

69%

14%

11%

6%

PERCENTAGE OF RESPONDENT TYPE
Very Useful36%

Quite Useful

39%

Neither/Nor

9%

26%

Not Very Useful 5%

39%

Not Useful at All
Don't Know

Financial

7%

47%

9%

39%

6%
6%

11% 1%
2%
10% 7% 2%

Non-Financial

Base size (asked of All): 306

All respondents were asked about the most effectivemeasures to address potential challenges around
conducting scenario analysis and disclosing therecommended information.
PERCENTAGE OF RESPONSES
Better practice standards around conducting
and disclosing scenario analyses

29%

Development of additional methodologies
and tools

26%

Further work by industry trade groups anddisclosure users on critical elements to be…

22%

Reduce the cost of conducting and disclosing
scenario analysis

8%

Allow a year or two to phase-in scenario
analysis and related disclosures

7%

Other

7%

NGOs and Others

Base size (asked of All): 306

10METRICS AND TARGETSAll respondents were asked about the usefulness of theillustrative examples of metrics and targets provided
for non-financial groups.
RESPONDENTS

USEFULNOTUSEFULNEITHER

DON’T
KNOW

RESPONDENTS

66%

9%

13%

12%Users

All

PERCENTAGE OF RESPONDENT TYPE
Very Useful30%

Quite Useful
Neither/Nor

4%

27%

44%
5%

20%
3…

Not Useful at All

13%

45%

15%
3%

Financial

NEITHER

DON’T
KNOW

70%

10%

13%

7%

22%

35%

Quite Useful

45%

Neither/Nor

14%

Not Very Useful

9% 4%

Don't Know

11%

Non-Financial

Base size (asked of All): 306

NOTUSEFUL

39%

13%

Not Useful at All 3%3%

1%
17% 4%USEFULPERCENTAGE OF RESPONDENT TYPE
Very Useful

30%30%

Not Very UsefulDon't Know

Users were asked how useful disclosure of GHG
emissions associated with investments would be for
economic decision-making (e.g., investing decisions).

NGOs and Others

8% 7%

Financial

NGOs and Others

Base size (asked of Users): 192

11IMPLEMENTATION TIMEFRAME
Preparers were asked about the timeframe in which they would be willing to implement therecommendations in financial filings.
Over 40% of financial and non-financial preparers indicated that they do not know whether orwhen they would implement the recommendations. The most often cited reasons include:• the organization has not yet decided whether to implement the recommendations• the organization will report outside of financial filings• the organization will likely implement the recommendations, but could not commit at this time
PERCENTAGE OF RESPONSES

In the next one to two years

21%

In three to five years
47%
16%

We do not intend to implement the recommendations
We already report these disclosures in financial filings

6%10%

Do not know

Base size (asked of Preparers): 191

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DRIVERS FOR IMPLEMENTATION - PREPARERS
Preparers were asked what drivers, if any, would encourage them to adopt therecommendations.
“Request from investors” was the most cited driver in focus groups and by the non-financial
respondents. Financial respondents said that “adoption by peers” would be their primary driver.
NUMBER OF RESPONSES
Adoption by industry peers

66

Requests from investors to disclose

54

Requests from clients or beneficiaries
42

Reputational benefits and goodwill from adoption

2153

Other
None of the above

2664

Inquiries or requests from debt or equity analysts

30
6Financial

1222

1132
34

21

28
27

2320

16 1

Non-Financial

Other

Base size (asked of Preparers): 191

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NEXT STEPSThe Task Force is in the process of evaluating feedback and potential changes to thereport, which is scheduled to be finalized and released in June 2017.
The FSB has extended the Task Force through mid-2018 to support and monitor adoption.
TIMELINE
Second Quarter2017

Apr 20-21: Meeting of G20
Finance Ministers andGovernors

Third Quarter
2017

Fourth Quarter
2017

First Quarter2018

Jul 7-8: FSB reportpresentation at G20Summit

Q2: Update report perconsultation feedback

Second Quarter2018

Q2 2018: Submission of implementation
monitoring report

Q4 2017-Q2 2018: Implementation monitoringQ2 2017-Q2 2018: Outreach and engagement

Jun: Issuance of final report
to FSB14