TCFD-based reporting to become mandatory for PRI signatories in 2020
The following climate change indicators will be mandatory for signatories to report on from 2020: SG 01 CC, SG 07 CC, SG 13 CC. These will be voluntary to disclose and will not be assessed. Read more about it in our press release.
PRI reporting is the largest global reporting project on responsible investment. It was developed with investors, for investors. Signatories are required to report on their responsible investment activities annually. This ensures:
- accountability of the PRI and its signatories;
- a standardised transparency tool for signatories’ reporting;
- that signatories receive feedback from which to learn and develop.
Ninety-three percent of signatories reporting in 2018 said that the Reporting Framework captures signatories’ implementation of the Principles to a moderate or large extent.
Who has to report?
Reporting is compulsory for all PRI signatories. It is one of the explicit commitments that signatories make when signing the Principles. Signatories that fail to report are delisted.
When signatories first sign up, they will have a one-year grace period whereby the first reporting cycle is voluntary. The PRI encourages new signatories to report in their voluntary year and use this process as a learning experience. Voluntary reporters can choose to keep their report confidential.
When do signatories report?
The reporting tool is open annually from the first week of January to the end of March and can be accessed here. The 2020 reporting cycle runs from 6 January to 31 March.
Where do signatories report?
Signatories report in the reporting tool. This tool is open from January to the end of March each year. Find out more about how to use the reporting tool below.
What are the benefits of reporting for signatories?
Through the reporting process, signatories can:
- evaluate their RI progress against an industry-standard framework;
- receive ongoing feedback and tools for improvement;
- benchmark their performance against peers;
- see the big picture by understanding the state of the market;
- strengthen internal processes and build ESG capacity;
- summarise activities for staff, clients, shareholders and regulators.
The 2020 Reporting Framework
Click the modules below to find out more about the 2020 Reporting Framework:
|Strategy and governance|
|Climate change reporting|
|Asset class-specific modules|
Listed equity (incorporation)
Listed equity (active ownership)
Manager selection, appointment and monitoring
|1. Organisational overview|
|2. Strategy and governance|
|3. Relevant modules only:|
|Investment consultancy||Reporting||Research and data provision||Active ownership services|
|4. Closing module|
What to report on
The Reporting Framework is split into 12 modules. Each module has a separate theme and includes a number of indicators to respond to. All signatories complete the organisational overview, strategy & governance and closing module. The remaining modules are asset class specific. The organisational overview module contains gateway indicators that will inform which of the asset class specific modules to report on. The main indicator for this is OO 05, where signatories will describe the mix of assets they hold.
If ESG factors are considered in an asset class where the signatory invests less than 10% of their AUM, indicator OO 12 will allow the signatory to opt out from reporting on the specific module. Not all information within each module is mandatory to complete or disclose. Further information on this can be found here. Signatories are free to choose the period they report on but should report on the same period each year.
The Reporting Framework is split into seven modules. Each module has a separate theme and includes a number of indicators to respond to. All signatories complete the organisational overview, strategy & governance and closing module. The remaining modules are business specific. The organisational overview module contains gateway indicators that will inform which of the business specific modules that will be relevant to report on.
Not all information within each module is mandatory to complete, or disclose. Further information can be found here. Signatories are free to choose the period they report on but should report on the same period each year.
What do I receive after reporting?
If you submit your report before the reporting cycle ends, in July of each year you will receive:
Public Transparency Report
Includes all public and mandatory indicators. Transparency Reports will also be publicly available on our website. Signatories that report during their grace year can decide whether to publish their Transparency Report on the PRI website.
Private Transparency Report
Includes all indicators, public and private. Private Transparency Reports are confidential. Signatories may request access to others’ private Transparency Report, something which can be approved or denied.
Assessment Reports are confidential. Signatories may request access to others’ private Transparency Reports, something which can be approved or denied.
Public Transparency Report
Includes all public indicators. Your Transparency Report will also be publicly available on the signatory directory.
Private Transparency Report
Includes all indicators, public and private. Your private Transparency Report is confidential. Other signatories may request access to your private Transparency Report, which you can approve or deny.
Where can I find reporting resources on the website?
For information on where to find reporting resources, watch our video.
When can we start reporting?
Reporting opens at the beginning of January each year. Signatories have a three-month window to submit their report and can start preparing for reporting in November, when the PRI releases its reporting frameworks in PDF versions.
Will our report be assessed/scored by the PRI?
The PRI currently assesses investors’ reports, but not service providers’. In 2018, the PRI will explore the possibility of introducing service provider assessment. This will include a rigorous research and consultation process to ensure that we capture the possibilities and challenges of service provider assessment.
I am new to reporting. How do I access the reporting tool?
Register here and click the ‘Request access to reporting tool’ box. You will receive an activation link within one hour.
I forgot my password to the reporting tool. How do I get a new one?
You can set a new password here.
How long does it take to report?
Signatories estimate that for an organisation managing more than US$1 billion, it takes one full-time staff member approximately one week to collect, aggregate and submit information. This will vary based not only on the organisation’s size, but also its structure and asset mix (which will determine how many modules must be completed) and what information flow and data tracking systems are in place. After the first year, the Reporting Framework is pre-filled with the previous year’s answers, saving signatories time where information has not changed.
How can I contact the PRI for reporting-based queries?
Send an email to firstname.lastname@example.org or call +44 (0)20 3714 3187.
Can I report in another language?
The official reporting language for the PRI is English. If you enter text in other languages, an English translation should also be provided.
How does the PRI develop Reporting Framework modules?
The PRI regularly updates the Reporting Framework to ensure that it reflects best practice and allows signatories to report on their various activities. Occasionally, modules in the Reporting Framework need to be changed more extensively to reflect updates in the investment industry. In these cases, the PRI seeks greater feedback from signatories through public consultations. Changes to the PRI Reporting Framework will be made for the following reasons:
- to clarify points of confusion or provide improved guidance to signatories;
- to support a more robust assessment methodology;
- to facilitate better analysis of the data;
- to strengthen accountability;
- to respond to input from the PRI Board;
What processes are involved when making changes to the Reporting Framework?
When making changes to the Reporting Framework, the PRI:
- Reviews signatory input. This includes feedback from calls, meetings, FAQs and free text answers in the Reporting Framework.
- Consults with the Reporting and Assessment Advisory Committee, working groups, other advisory committees and groups of engaged signatories who provide direct feedback.
- Reviews internal information, including data analysis and a review of current practices.
- Launches signatory consultations. Changes to mandatory frameworks, modules or sections of a module require signatory consultation. Where new content is voluntary, the PRI uses the first voluntary year to collect feedback and consult with signatories. However, minor changes to wording and explanatory notes, or moving indicators from one place to another will not require signatory input.
A new module or a module that has undergone substantial change will have no major modifications for at least two years. Smaller changes will be made in case the reported data shows inconsistencies or points to a need or clarification of wording. The PRI will conduct a wider Reporting Framework review every three to five years to identify if it’s fit for purpose, how it aligns with the PRI’s strategy, and whether it reflects advances in responsible investment practices and changing technology.
How was the PRI Reporting Framework developed?
Signatories initially reported via a self-evaluation process. However, following the most extensive consultation in the PRI’s history, the reporting and assessment process was redeveloped to ensure signatory responses were more robust. Signatories were involved in its design from the outset and in the governance bodies and committees that oversaw its development.
A pilot version of the Reporting Framework was launched for signatory testing in June 2012. Multiple international consultations and module-specific workshops held around the world resulted in thousands of points of signatory feedback, which fed into the Reporting Framework that launched in October 2013.
For the first two reporting cycles, the fixed income module was in a pilot phase. It was redeveloped for the 2015/16 cycle following another round of extensive consultation with signatories, to better capture how responsible investment is practiced in this asset class. The infrastructure module is still in a pilot phase and is voluntary to report on.
More than 800 signatories reported under the new Reporting Framework in its first year. Now well over 1,000 do, with more joining every year.
Can we decide not to disclose on mandatory indicators?
Mandatory indicators will be published on the PRI website. The disclosure requirements have been developed in close consultation with signatories via several asset class and region-specific technical committees and working groups. However, in rare cases, some signatories may find themselves unable to comply. In these cases, they may appeal against the mandatory disclosure of an indicator.
Why do we have to dislose our AUM?
The PRI requires that signatories provide us with an AUM figure upon joining and every year that they complete the Reporting Framework. We use this information in a number of ways:
- to assign the correct fee band to signatories;
- to calculate the overall PRI signatory AUM;
- to create peer groups for assessment of signatories;
- in signatory segmentation activities, including calculating the size of asset class allocations;
- for a future plan to mandate greater transparency on asset class allocations of AUM over a certain monetary threshold but that are less than 10% of a signatory’s AUM (as currently very large signatories can circumvent reporting).
If signatories find themselves unable to comply with the disclosure requirements of an indicator, they may lodge an appeal with the PRI. Given the signatory involvement in developing Reporting Framework content, appeals are not expected to be needed except in rare situations.
Further discussion of the topic has emerged as an obstacle for some potential signatories during the sign-up process. A small number of potential signatories is uncomfortable disclosing their AUM figure to the PRI at all. Those in this category include sovereign wealth funds and, increasingly, entities in the Asian market.
The PRI has effectively decided that an exception to the AUM rule can be considered where signatories present high strategic value. This status would need to be agreed at the sign up process and would not be backdated to any existing signatory.
When can we appeal?
As a guideline, signatories may appeal where disclosing their organisation’s response to a particular indicator would:
- Conflict with local legislation or regulation.
- Conflict with a pre-existing company policy (for example, a non-disclosure policy that is not specific to ESG issues). Appeals of this type will be considered, but are less likely to succeed where the policy jeopardises a signatory’s ability to fulfil Principle 6, We will each report on our activities and progress towards implementing the Principles.
- In the cases of some signatories who are not able to be transparent in regards to their AUM figure for confidentiality reasons.
Signatories may not appeal on the following grounds:
- General non-disclosure policies relating to ESG information. Reporting and disclosing responsible investment activities is a requirement of being a PRI signatory.
- Disagreement about the form or structure of a particular indicator. In these cases, signatories should use the free text field within each indicator to contextualise their responses, and should provide feedback to PRI directly via the Online Reporting Tool.
Signatories may lodge an appeal by sending a letter on their company letterhead to email@example.com, detailing the indicator(s) affected and the reasons for the appeal. Signatories wishing to appeal should continue to complete the framework but should not submit their responses.
When reviewing appeals, the PRI will be advised by the Reporting and Assessment Advisory Committee, made up of signatory representatives approved by the PRI. The RAAC has particular expertise in the field of responsible investment reporting and assessment.
The PRI will contact signatories directly to inform them of the decision about their appeal. If granted, the Transparency Report will not contain the information that has been appealed.
Signatories can request that a previously granted appeal applies to their following year’s response. To do so, they should contact firstname.lastname@example.org during the reporting period (between 3 January and 31 March). The PRI will confirm the appeal status.
What happens if we are delisted?
Signatories that have to report on a mandatory basis that do not submit reported data by the deadline will be entered into the delisting process in April, with a delisting date of 31 May. Their names will be included in the PRI’s Annual Report and failure to report will be indicated as the reason for delisting. A signatory can only relist after they have completed their last reporting requirement, and the grace year will not apply again.
If a signatory chooses to delist during the reporting cycle (including because they do not wish to complete the Reporting Framework), their account will be suspended when they have delisted. Previously submitted reports that have been published will remain on the Data Portal (under category “delisted”) but the organisation will cease to have access to this platform.
All submitted data will be retained in the PRI’s public and private databases. This is covered by the terms and conditions of the reporting tool. The PRI databases, including data from delisted signatories that submitted reported data, will be used to produce the aggregate statistics used in PRI data outputs such as snapshot reports and assessment reports. Assessment reports will be sent only to active signatories.
Where can I find information on the Reporting Framework modules?
You can find FAQs about the Reporting Framework modules here.
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