This review concludes that the UK’s existing regulation on disclosure is comprehensive and that (unlike many other developed nations) it integrates, to some extent, sustainability risks into the broader financial risk analysis and disclosure framework.
However, the adoption of a number of the TCFD’s recommendations would assist materially in ensuring better climate risk mitigation in the UK, facilitating better investment decisions and assisting with the maintenance of financial stability, as the UK and its global trading partners seek to transition to a lower carbon economy.
A wide range of companies and investors globally are aligned with the TCFD in relation to the material financial risks posed by climate change, and the role best practice climate risk analysis and disclosure can play in understanding these risks and their implications for existing assets and potential investments. Company law in the UK already requires most large organisations to disclose material financial risks to their businesses, and in some cases this extends to the disclosure of climate-related and other ESG risks.
Improvement of existing disclosure requirements would involve:
- more specific guidance in the existing regulation regarding best practice climate risk analysis and disclosure, and clear signals on the need to incorporate this analysis into general financial reporting;
- companies being required to undertake a more forward-looking consideration of climate change risks and their potential impacts on investments and company liabilities, in line with the TCFD’s detailed recommendations; and an increase in the scope and detail of existing disclosure requirements, to promote better risk management and improve investor confidence in climate disclosure as part of wider financial reporting.
Practical actions for better climate disclosure in the UK
- The UK government and regulators should endorse the TCFD’s final recommendations, including the FRC, PRA and The Pensions Regulator.
- UK Companies should adopt the TCFD’s recommendations as a useful voluntary framework for consistent climate-related disclosures to investors. Sharing of company good practice will assist in overcoming implementation hurdles, with convergence in reporting frameworks needed in the longer term.
- Investors should engage with companies to encourage adoption of the TCFD’s recommendations. Investors should also evolve their disclosure to beneficiaries and clients, informed by the TCFD’s guidance for asset owners and managers.
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TCFD Recommendations: Country reviews - UK
Produced in collaboration with Baker McKenzie