ClientEarth response to consultation Recommendations of the Task Force on Climate-related Financial Disclosures

ClientEarth broadly supports the TCFD's industry-led guidance but identifies three critical deficiencies: the potential to confuse voluntary recommendations with existing mandatory legal duties in G20 jurisdictions, the misstatement of the Paris Agreement's objectives by suggesting a 2°C scenario is sufficient for alignment, and a lack of prescriptive requirements for organisations to publish the assumptions underpinning their scenario analyses.

• The TCFD Report may mislead organisations by emphasizing the voluntary nature of its recommendations, whereas the disclosure of material climate-related risks is already a mandatory legal obligation in many G20 jurisdictions.
• In the UK, the Companies Act 2006 requires quoted companies to provide a fair review of their business, a description of principal risks and uncertainties, and information on environmental matters, all of which can necessitate the reporting of climate-related risks.
• EU regulations, including the Transparency Directive (2004/109/EC) and the Accounting Directive (2013/34/EU) as amended by the Non-Financial Reporting Directive (2014/95/EU), require public companies to disclose environmental matters, including climate-related risk, if necessary to understand the company's position, performance, or development.
• The TCFD Report incorrectly suggests that using a 2°C scenario is aligned with the Paris Agreement; ClientEarth argues that true alignment requires a pathway consistent with holding temperature increases to 'well below 2°C' and pursuing efforts to limit the increase to 1.5°C.
• ClientEarth contends that the TCFD Report should be more prescriptive in requiring organisations to publish the assumptions underpinning their scenario analyses to ensure consistency, comparability, and reliability across the market.

APA

ClientEarth (2017). ClientEarth response to consultation Recommendations of the Task Force on Climate-related Financial Disclosures. https://www.clientearth.org/media/tfgly3qe/clientearth-response-to-task-force-on-climate-related-financial-disclosures-consultation-ce-en.pdf

Chicago

ClientEarth. ClientEarth response to consultation Recommendations of the Task Force on Climate-related Financial Disclosures. 2017. https://www.clientearth.org/media/tfgly3qe/clientearth-response-to-task-force-on-climate-related-financial-disclosures-consultation-ce-en.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=ClientEarth response to consultation Recommendations of the Task Force on Climate-related Financial Disclosures |date=9 February 2017 |url=https://www.clientearth.org/media/tfgly3qe/clientearth-response-to-task-force-on-climate-related-financial-disclosures-consultation-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2017clientearth, author = {{ClientEarth}}, title = {{ClientEarth response to consultation Recommendations of the Task Force on Climate-related Financial Disclosures}}, publisher = {ClientEarth}, year = {2017}, month = feb, url = {https://www.clientearth.org/media/tfgly3qe/clientearth-response-to-task-force-on-climate-related-financial-disclosures-consultation-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }