FCA Consultation CP20/3: Proposals to enhance climate-related disclosures

ClientEarth argues that the FCA's proposals in CP20/3 are inadequate to protect consumers and ensure market integrity. The organization recommends making TCFD-aligned disclosures mandatory for all listed issuers by 2022, requiring a 'Paris-aligned' strategy for net zero by 2050, and clarifying materiality tests to align with investor expectations. It also calls for consistency with EU disclosure laws and stronger enforcement to close existing accountability gaps.

• Listed issuers in the UK are consistently failing to disclose material climate-related information, which ClientEarth suggests may constitute a breach of the law.
• ClientEarth recommends that the FCA replace the proposed 'comply or explain' approach with a mandatory 'climate rule' to avoid slow implementation and 'greenwash'.
• The briefing argues that the 'climate rule' should apply to all issuers by 2022, including those with a 'standard' listing on the Main Market of the London Stock Exchange and those on the Alternative Investment Market (AIM), rather than just premium listed issuers.
• ClientEarth proposes a 'TCFD+' standard, requiring issuers to disclose a 'Paris-aligned' strategy with a credible plan to reach net zero greenhouse gas emissions by 2050.
• The FCA is urged to define 'materiality' in a way that aligns with IFRS accounting standards and the Financial Reporting Council, focusing on information that could reasonably influence investor decisions.
• There is a need for the FCA to ensure consistency with emerging EU disclosure laws, specifically those under the Non-Financial Reporting Directive (NFRD), to maintain UK issuers' access to European capital.
• ClientEarth claims that the FCA and FRC have failed to take public enforcement action despite complaints about high-risk sector issuers omitting climate-related risks in annual reports.

APA

ClientEarth (2020). FCA Consultation CP20/3: Proposals to enhance climate-related disclosures. https://www.clientearth.org/media/d0xjwnrl/fca-climate-risk-disclosure-consultation-briefing-ce-en.pdf

Chicago

ClientEarth. FCA Consultation CP20/3: Proposals to enhance climate-related disclosures. 2020. https://www.clientearth.org/media/d0xjwnrl/fca-climate-risk-disclosure-consultation-briefing-ce-en.pdf.

Wikipedia

{{cite report |author=ClientEarth |title=FCA Consultation CP20/3: Proposals to enhance climate-related disclosures |date=August 2020 |url=https://www.clientearth.org/media/d0xjwnrl/fca-climate-risk-disclosure-consultation-briefing-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{clientearth2020fca, author = {{ClientEarth}}, title = {{FCA Consultation CP20/3: Proposals to enhance climate-related disclosures}}, institution = {ClientEarth}, year = {2020}, month = aug, url = {https://www.clientearth.org/media/d0xjwnrl/fca-climate-risk-disclosure-consultation-briefing-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }