FCA Consultations CP21/17 and CP21/18 on enhancing climate-related disclosures

ClientEarth argues that the FCA's proposed disclosure requirements in CP21/17 and CP21/18 are insufficient to provide the granularity needed for informed investment decisions. The briefing recommends mandatory disclosures, the inclusion of Scope 3 emissions, and the alignment of financial accounts with the Paris Agreement and the UK's net-zero target. It specifically calls for expanding the scope of regulated firms and listed entities subject to these rules and introducing robust enforcement to prevent greenwashing.

• ClientEarth asserts that current corporate reporting on climate change is often unclear, incomplete, and potentially misleading, which may lead to 'greenwash' and prevent capital from being directed toward net-zero transitions.
• The briefing recommends that transition plans must be aligned with the best available science and the UK Government's targets, specifically reducing emissions by 68% by 2030 and 78% by 2035 compared to 1990 levels.
• ClientEarth argues that the FCA should mandate the disclosure of all categories of Scope 3 emissions for all in-scope firms across all sectors, noting that these are often the largest source of a company's emissions.
• The briefing calls for the FCA to ensure financial accounts are Paris-aligned and reflect the transition plans disclosed by firms to reduce the risk of inaccurate cost and return information.
• Regarding CP21/17, ClientEarth recommends expanding the scope of disclosure requirements to all FCA regulated firms regardless of size, removing the £5 billion assets under management threshold for core metrics.
• For CP21/18, the briefing argues that rules should be mandatory rather than following a 'comply or explain' model, and that auditors should provide a 'limited assurance' opinion on climate-related disclosures in annual reports.
• ClientEarth suggests that the scope of CP21/18 should be extended to include issuers of standard listed debt, global depositary receipts, and non-equity shares.
• The briefing emphasizes the need for the FCA to be adequately resourced to enforce reporting obligations and hold 'laggards' accountable to fulfill its remit regarding the UK's 2050 net-zero target.

APA

ClientEarth (2021). FCA Consultations CP21/17 and CP21/18 on enhancing climate-related disclosures. https://www.clientearth.org/media/vsqp2e45/24-08-2021-clientearth-briefing-2021-fca-consulations-cp2117-and-cp2118-on-enhancing-climate-related-disclosures.pdf

Chicago

ClientEarth. FCA Consultations CP21/17 and CP21/18 on enhancing climate-related disclosures. 2021. https://www.clientearth.org/media/vsqp2e45/24-08-2021-clientearth-briefing-2021-fca-consulations-cp2117-and-cp2118-on-enhancing-climate-related-disclosures.pdf.

Wikipedia

{{cite report |author=ClientEarth |title=FCA Consultations CP21/17 and CP21/18 on enhancing climate-related disclosures |date=August 2021 |url=https://www.clientearth.org/media/vsqp2e45/24-08-2021-clientearth-briefing-2021-fca-consulations-cp2117-and-cp2118-on-enhancing-climate-related-disclosures.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{clientearth2021fca, author = {{ClientEarth}}, title = {{FCA Consultations CP21/17 and CP21/18 on enhancing climate-related disclosures}}, institution = {ClientEarth}, year = {2021}, month = aug, url = {https://www.clientearth.org/media/vsqp2e45/24-08-2021-clientearth-briefing-2021-fca-consulations-cp2117-and-cp2118-on-enhancing-climate-related-disclosures.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }