TCFD Consultation: Proposed Guidance on Climate-related Metrics, Targets, and Transition Plans

ClientEarth argues against the use of materiality assessments for climate metrics, advocates for mandatory Scope 3 emissions disclosure, and calls for transition plans to include science-based targets aligned with national commitments and a 1.5°C pathway.

• ClientEarth argues that the disclosure of climate-related metrics and financial impacts should not be subject to materiality assessments, as doing so reduces disclosure quality, deprives investors of relevant data, and allows organisations to delay compliance.
• The document proposes that the TCFD remove the materiality threshold for Scope 3 emissions, requiring organisations to disclose all relevant categories as defined by the GHG Protocol to prevent misleading net-zero commitments.
• ClientEarth recommends that short-term interim targets be set for a duration of two to five years, rather than the proposed five to ten years, to ensure immediate climate action and mitigate unpredictable transition risks.
• The response asserts that transition plans must include science-based emissions reduction targets that at least match the national emissions reduction commitments of any jurisdiction where the organisation operates.
• ClientEarth suggests that organisations should reflect their transition plans and climate-related assumptions within their financial accounts to avoid inaccurate cost and return information, such as failing to reflect asset impairments.
• The document calls for minimum disclosure standards for carbon offsets to prevent 'greenwash', proposing that organisations specify the volume of offsets by project type, vintage, location, and standard, while distinguishing between reduction/avoidance and removal projects.

APA

ClientEarth (2021). TCFD Consultation: Proposed Guidance on Climate-related Metrics, Targets, and Transition Plans. https://www.clientearth.org/media/urppuqdr/clientearth-response-to-tcfd-consultation-on-metrics-targets-and-transi.pdf

Chicago

ClientEarth. TCFD Consultation: Proposed Guidance on Climate-related Metrics, Targets, and Transition Plans. 2021. https://www.clientearth.org/media/urppuqdr/clientearth-response-to-tcfd-consultation-on-metrics-targets-and-transi.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=TCFD Consultation: Proposed Guidance on Climate-related Metrics, Targets, and Transition Plans |date=July 2021 |url=https://www.clientearth.org/media/urppuqdr/clientearth-response-to-tcfd-consultation-on-metrics-targets-and-transi.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2021tcfd, author = {{ClientEarth}}, title = {{TCFD Consultation: Proposed Guidance on Climate-related Metrics, Targets, and Transition Plans}}, publisher = {ClientEarth}, year = {2021}, month = jul, url = {https://www.clientearth.org/media/urppuqdr/clientearth-response-to-tcfd-consultation-on-metrics-targets-and-transi.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }