Mobilising IOSCO to take action on the TCFD recommendations

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The document highlights a regulatory divergence in climate risk disclosure, noting that TCFD implementation is largely an EU phenomenon. It proposes that IOSCO, which represents regulators for over 95% of world securities markets, can reduce systemic financial risk by issuing formal acknowledgments of TCFD, updating its Principles, and developing reporting standards. It suggests investors engage either their national regulators or IOSCO directly to push for these actions, specifically targeting the Committee on Issuer Accounting, Audit and Disclosure (Committee 1).

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  • There is a significant disparity in the adoption of TCFD recommendations, with implementation being primarily an "EU phenomenon" while other economies are slower, leading to "regulatory divergence on climate risk disclosure" and increased systemic risks.
  • IOSCO is uniquely positioned to harmonise climate risk reporting because its 217 members regulate more than 95% of the world's securities markets, although the organisation itself lacks direct regulatory or enforcement powers.
  • To promote TCFD implementation, IOSCO could take several specific actions: issuing a formal acknowledgement of the recommendations, updating the IOSCO Methodology and Principles to refer to climate risk, developing TCFD-based reporting standards (specifically regarding 'materiality'), and producing reports on scenario analysis and regulatory integration.
  • Climate risk disclosure aligns with two specific IOSCO Principles: Principle 6, which requires regulators to identify and manage systemic risk, and Principle 16, which requires full and timely disclosure of material information to investors.

Cite the original document

APA
ClientEarth (2018). Mobilising IOSCO to take action on the TCFD recommendations. https://www.clientearth.org/media/xj5gfrmy/investor-briefing-the-opportunity-for-iosco-action-on-the-tcfd-recommendations-ce-en.pdf
Chicago
ClientEarth. Mobilising IOSCO to take action on the TCFD recommendations. 2018. https://www.clientearth.org/media/xj5gfrmy/investor-briefing-the-opportunity-for-iosco-action-on-the-tcfd-recommendations-ce-en.pdf.
Wikipedia
{{cite report |author=ClientEarth |title=Mobilising IOSCO to take action on the TCFD recommendations |date=August 2018 |url=https://www.clientearth.org/media/xj5gfrmy/investor-briefing-the-opportunity-for-iosco-action-on-the-tcfd-recommendations-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{clientearth2018mobilising, author = {{ClientEarth}}, title = {{Mobilising IOSCO to take action on the TCFD recommendations}}, institution = {ClientEarth}, year = {2018}, month = aug, url = {https://www.clientearth.org/media/xj5gfrmy/investor-briefing-the-opportunity-for-iosco-action-on-the-tcfd-recommendations-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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