Progress on Corporate Climate-related

Disclosures—2024 Report
 November 2024

Mr Klaas Knot
Chair
Financial Stability Board
Bank for International Settlements
Centralbahnplatz 2
CH-4002 Basel
Switzerland

Dear Chair Knot,

On behalf of the IFRS Foundation, it is my pleasure to present the 2024 report on progress on corporate
climate-related disclosures. This report reflects progress made since the publication of the sixth and
last status report by the Financial Stability Board’s (FSB) Task Force on Climate‑related Financial
Disclosures (TCFD).
In July 2023 the FSB announced that the work of the TCFD had been completed, with the two inaugural
Standards issued in June 2023 by the International Sustainability Standards Board (ISSB) marking the
‘culmination of the work of the TCFD’. Having fulfilled its remit, the TCFD disbanded in October 2023,
concurrent with the release of its 2023 status report.
The FSB has asked the IFRS Foundation to record companies’ progress in making climate-related
disclosures by monitoring:
• companies’ early take-up of ISSB Standards; and
• the ISSB’s progress in achieving interoperability between ISSB Standards and other standards
and frameworks.
The IFRS Foundation is fulfilling the FSB’s request by publishing this report.
As this report describes, companies continue to make progress in their climate-related disclosures and
are preparing to make the transition from disclosures prepared using the TCFD recommendations to
disclosures prepared using ISSB Standards.
The International Organization of Securities Commissions (IOSCO) endorsed ISSB Standards in
July 2023. Since then, many jurisdictions have taken action to introduce sustainability-related disclosure
requirements—including through the adoption or other use of ISSB Standards—in their legal and
regulatory frameworks.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 2

This report informs the work of the FSB, in co-ordination with IOSCO and the IFRS Foundation:
• to assist jurisdictions—through a broad capacity-building programme—to consider how they might
adopt, apply or otherwise use ISSB Standards;
• to promote timely and widespread adoption of ISSB Standards, in line with jurisdictions’ individual
circumstances; and
• to continue to report annually to the G20 on jurisdictions’ and companies’ progress in implementing
climate-related disclosures and reporting in line with international standards.1
As set out in its Constitution, the IFRS Foundation remains committed to promoting and facilitating the
global adoption, use and rigorous application of ISSB Standards and to co-ordinating efforts with other
international organisations (including the Monitoring Board of the IFRS Foundation, IOSCO and the FSB)
for the provision of globally comparable information for capital markets.

Yours sincerely,

Erkki Liikanen
Chair of the Trustees of the IFRS Foundation

Terms defined in the Glossary are in italics the first time they appear in the Executive Summary and
in Sections 1–5.

1 Financial Stability Board (FSB), FSB Roadmap for Addressing Financial Risks from Climate Change Progress: 2023 Progress Report, FSB, 2023,
https://www.fsb.org/wp-content/uploads/P130723.pdf.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 3

EXECUTIVE SUMMARY As of September 2024 30 jurisdictions have
decided to use or are taking steps to introduce
Purpose of this report ISSB Standards in their legal or regulatory
frameworks. Together, these jurisdictions represent:
This report presents progress on corporate
climate-related disclosures. The report continues • approximately 57% of global gross domestic
the work of the Financial Stability Board’s product;
(FSB) Task Force on Climate‑related Financial • more than 40% of global market capitalisation;
Disclosures (TCFD) to record the progress of and
companies reporting on its 11 recommended
• more than half of global greenhouse gas (GHG)
disclosures. Based on a sample of 3,814 public
emissions.
companies, in fiscal year 2023 82% of companies
disclosed information in line with at least one
of the 11 TCFD recommended disclosures Takeaways in numbers
and 44% of companies with at least five of the
82% of companies disclosed information in
recommended disclosures. Approximately 2–3%
line with at least one of the 11 TCFD
of companies reported in line with all 11 TCFD
recommended disclosures
recommended disclosures.
The report shows that companies are making the 2–3% of companies reported in line with all
transition from disclosures prepared using the 11 TCFD recommended disclosures
TCFD recommendations to disclosures prepared
1,000+ companies referenced the ISSB in
using the two inaugural Standards issued by
their reports
the International Sustainability Standards Board
(ISSB) in June 2023. Between October 2023 30 jurisdictions are on the journey to
and March 2024, more than 1,000 companies introducing ISSB Standards in their
referenced the ISSB in their reports. legal or regulatory frameworks
This report also presents information
about jurisdictions’ progress in introducing
sustainability‑related disclosure requirements
in their legal and regulatory frameworks,
including through the adoption or other use of
ISSB Standards.

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Background information Integrating the TCFD recommendations in
ISSB Standards is an important evolution in
In June 2017 the TCFD released a framework
climate‑related financial reporting. ISSB Standards
to help companies develop more effective
are designed to meet the needs of investors,
climate‑related financial disclosures.2
although other parties, such as regulatory bodies,
To promote the use of the framework, the are expected to find information in the resulting
TCFD provided guidance, supported educational sustainability-related financial disclosures useful.
efforts, monitored companies’ climate-related By ensuring that companies using ISSB Standards
financial disclosure practices in terms of how they also provide the information covered by the
aligned with the TCFD recommendations, and TCFD recommendations, the ISSB has built on
prepared six annual status reports.3 pre-existing practice, facilitating the transition
In June 2023 the ISSB issued its first two from disclosures prepared using the TCFD
Standards—IFRS S1 General Requirements for recommendations to disclosures prepared using
Disclosure of Sustainability-related Financial ISSB Standards.
Information and IFRS S2 Climate-related Concurrent with the release of its 2023 status
Disclosures.4 report in October 2023, the TCFD fulfilled its
remit and disbanded as a consequence of the
issuance of IFRS S2, which integrates the TCFD
The requirements in IFRS S2 integrate
recommendations.
and are consistent with the TCFD’s four
core recommendations and 11 supporting The FSB has asked the IFRS Foundation to record
recommended disclosures. companies’ progress in making climate-related
disclosures since the TCFD 2023 status report,
The core content requirements in IFRS S1
including information useful to monitor companies’
also integrate the TCFD recommendations,
take-up of ISSB Standards.
requiring a company to provide information
about its governance, strategy, risk
management, and metrics and targets.
However, IFRS S1 requires a company
to disclose information about its
sustainability‑related risks and opportunities
beyond climate-related financial disclosures,
and therefore beyond the scope of the
TCFD recommendations’ climate focus.

2 The TCFD framework consists of four core recommendations (related to governance, strategy, risk management, and metrics and targets),
11 supporting recommended disclosures and all-sector and sector-specific guidance. The guidance informs implementation of the
recommendations but is not part of the formal recommendations.
3 The annual reports and other TCFD publications are available on the TCFD website: https://www.fsb-tcfd.org/publications. Although the TCFD’s
logo and resources are now retired, to reflect the TCFD’s intention for its work to be available as a public good, stakeholders may use the content
of the TCFD’s reports in resources, educational materials, reports and communications. These materials are required to include proper attribution
and should not be presented in a manner that could suggest any collaboration with the TCFD or any review or approval by the TCFD of the
materials or any related disclosures, products or services. The TCFD published its sixth and final report on 12 October 2023: TCFD, Task Force
on Climate-related Financial Disclosures: 2023 Status Report, TCFD, 2023, https://www.fsb.org/wp-content/uploads/P121023-2.pdf.
4 IFRS S1 and IFRS S2 are available on the IFRS Sustainability Standards Navigator.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 5

Key takeaways and findings
Many jurisdictions have taken action to
Between October 2023 and March 2024, more
introduce sustainability-related disclosure
than 1,000 companies referenced the ISSB in their
requirements—including through the
reports. In Africa and Asia-Oceania, approximately
adoption or other use of ISSB Standards—
half of the 554 companies that referenced the
in their legal and regulatory frameworks.
ISSB mentioned their current or future alignment in
reporting with the sustainability-related disclosure
requirements in ISSB Standards.
The TCFD recommendations served as
the foundation for several jurisdictional and
Companies continue to make progress international climate-related disclosure
in their climate-related disclosures and requirements and standards, such as:
are preparing to make the transition from • IFRS S1 and IFRS S2;
disclosures prepared using the TCFD
recommendations to disclosures prepared • the European Sustainability Reporting Standards
using ISSB Standards. (ESRS) adopted by the European Commission
in July 2023; and
• the final climate disclosure rule issued by the US
Jurisdictions that have made progress in the past Securities and Exchange Commission (US SEC)
12 months towards the adoption or other use of in March 2024.5
ISSB Standards include both:
The shared foundation of these requirements and
• jurisdictions that have issued or proposed standards helps to ensure that ISSB Standards
disclosure requirements aligned with the are interoperable with ESRS and the US SEC
TCFD recommendations in previous years climate rule.
(14 jurisdictions); and
Table 1 summarises the key takeaways and
• jurisdictions, mainly in Africa, Latin America and findings of this report.
the Caribbean, and Asia-Oceania, that have
not issued or proposed disclosure requirements
aligned with the TCFD recommendations
in previous years and are introducing
sustainability-related disclosure requirements for
the first time (an additional 16 jurisdictions).

5 On 4 April 2024 the US SEC issued an order to stay the rule, pending completion of an ongoing judicial review.

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Table 1—Summary of key takeaways and findings of this report

The requirements in IFRS S2 integrate and are consistent with the TCFD recommendations.
Companies using ISSB Standards provide the information covered by the
TCFD recommendations.6

The number of public companies disclosing TCFD-aligned information continues to grow,

but more progress is necessary. In fiscal year 2023 82% of companies disclosed
information in line with at least one of the 11 TCFD recommended disclosures and
44% of companies with at least five of the recommended disclosures. Approximately
2–3% of companies reported in line with all 11 TCFD recommended disclosures.

Between October 2023 and March 2024, more than 1,000 companies referenced
the ISSB in their reports. In Africa and Asia-Oceania, approximately half of the
554 companies that referenced the ISSB mentioned their current or future alignment in
reporting with the sustainability-related disclosure requirements in ISSB Standards.

Most asset managers and asset owners who responded to survey questions about
ISSB Standards want or expect portfolio companies to make the transition from
disclosures prepared using the TCFD recommendations to disclosures prepared using
ISSB Standards.

As companies take the necessary steps to make the transition from disclosures
prepared using the TCFD recommendations to disclosures prepared using
ISSB Standards, they also get ready to provide sustainability-related financial
information simultaneously with the financial statements as part of their general
purpose financial reports.

In May 2024 the IFRS Foundation published the Inaugural Jurisdictional Guide for
the adoption or other use of ISSB Standards to promote globally comparable climate
and other sustainability-related disclosures for capital markets. A growing number
of jurisdictions are using the guide to help them to move ahead with their plans to
adopt or otherwise use ISSB Standards.

In the past 12 months jurisdictions representing approximately 57% of global

gross domestic product have made progress towards the adoption or other
use of ISSB Standards. These jurisdictions include jurisdictions that have issued or
proposed disclosure requirements aligned with the TCFD recommendations previously
(14 jurisdictions) and other jurisdictions, mainly in Africa, Latin America and the
Caribbean, and Asia-Oceania, that are introducing sustainability-related disclosure
requirements for the first time (an additional 16 jurisdictions).

6 It is not necessary to apply the TCFD recommendations in addition to ISSB Standards to obtain information in line with the TCFD recommendations.
However, some companies may still be required to use the TCFD recommendations because of jurisdictional requirements.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 7

Conclusion and next steps As recognised by the TCFD, climate-related and
other sustainability issues are dynamic. As more
Companies’ progress in disclosing
jurisdictions progress in the introduction of
climate‑related financial information using the
sustainability-related financial disclosures and
TCFD recommendations or ISSB Standards
more companies start to implement regulatory
is encouraging.
requirements, it remains paramount that investors’,
The support shown by governments, regulators lenders’ and other creditors’ information needs
and other relevant authorities in using the are met.
TCFD recommendations or ISSB Standards as
Fragmentation in regulatory requirements caused
a basis to develop laws, rules and standards on
by jurisdictional modifications to ISSB Standards,
climate-related financial disclosures is also a
in particular modifications that result in removing
positive development towards greater consistency
or excluding requirements in ISSB Standards,
and quality of disclosures.
could conflict with the objective of delivering
Nevertheless, few companies are disclosing timely and comparable sustainability‑related
climate-related financial information that provides financial information to capital markets.
information about the company’s governance, This fragmentation adds complexity to those using
strategy, risk management, and metrics and the information and adds costs and complexities
targets—especially as it relates to the effect of to preparers of information subject to inconsistent
climate change on their businesses, strategies regulatory requirements.
and financial planning. This lack of information
The IFRS Foundation has published the Inaugural
could hinder investors’, lenders’ and other creditors’
Jurisdictional Guide for the adoption or other
ability to assess and price climate-related risks
use of ISSB Standards to support jurisdictions in
and opportunities. If the omitted information is
balancing jurisdictional considerations (including
material, the analysis summarised in this report
their approach to scaling and phasing in of
and previous TCFD status reports provide evidence
requirements) and to promote less variation in how
that this concern is valid.
ISSB Standards are adopted or otherwise used
The introduction of sustainability-related disclosure to reduce fragmentation in sustainability-related
requirements into regulatory frameworks through disclosure requirements.
the adoption or other use of ISSB Standards
The degree to which the jurisdictional disclosure
supports the provision of more comparable and
requirements are aligned with ISSB Standards
reliable information about sustainability-related
is an aspect to monitor to assess progress
risks and opportunities for global capital markets.
towards globally comparable information for
The progress towards use of ISSB Standards capital markets.
by companies and adoption of ISSB Standards
External high-quality assurance plays an important
by jurisdictions is expected to be beneficial to
role in enhancing trust and confidence in the
the increased specificity about the information
integrity and reliability of sustainability-related
to be provided, the links to information in the
financial information. Enhancing the quality of
financial statements and the trend towards
disclosures by introducing assurance requirements
disclosure being required to be provided rather
is also an area to monitor in the future.
than being recommended or subject to ‘comply or
explain’ approaches.

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Update on areas of continued focus and further work identified by the TCFD in
its 2023 status report
In its 2023 status report the TCFD considered areas that warranted continued focus or further work by
the ISSB or other appropriate bodies. Table 2 summarises progress in these areas since the TCFD 2023
status report.

Table 2—Update on areas of continued focus and further work identified by the TCFD

Interoperability

Ensuring interoperability of ISSB Standards with jurisdictional frameworks to

support consistent company reporting among jurisdictions and to avoid the need for
companies to report through more than one disclosure framework.

2024 update The IFRS Foundation and the ISSB are working to support the adoption of
ISSB Standards. The Jurisdictional Guide intends to bring transparency on the level
of compliance of the local standards with ISSB Standards. Consistency in company
and jurisdictional reporting and avoidance of duplicative reporting is best achieved
when companies use ISSB Standards and jurisdictions adopt ISSB Standards without
modifications, while potentially building from them for their own broader reporting
objectives. When this is not the case, the ISSB works to ensure ISSB Standards are
interoperable with the work of others. For example:
• in January 2024 the IFRS Foundation and the Global Reporting Initiative (GRI)
published Interoperability considerations for GHG emissions when applying GRI
Standards and ISSB Standards.
• in May 2024 the IFRS Foundation and EFRAG published the ESRS–ISSB
Standards—Interoperability Guidance, which explains the alignment and
interoperability between ESRS and ISSB Standards. The document describes
how a company can improve alignment in its disclosures and avoid duplication
in reporting.
In May 2024 the ISSB and GRI committed to jointly identify and align common
disclosures that provide needed information under the distinct scopes and purposes
of their respective standards, for both thematic and sector-based standard-setting.

continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 9

Guidance

Developing guidance on topics such as climate-related physical-risk assessment and

adaptation planning, climate-related scenario analysis at a sector or industry level and
Scope 3 GHG emissions measurement at a sector or industry level.

2024 update The ISSB continues to prioritise supporting the implementation of ISSB Standards,
including via the publication of educational material, to help ensure companies,
regulators and other stakeholders are well prepared to use ISSB Standards.
The IFRS Foundation and its supporting partners have developed educational
resources for preparers of sustainability-related financial disclosures, such as a
course for intermediate preparers that the IFRS Foundation has developed with the
United Nations Sustainable Stock Exchanges Initiative and the Fundamentals of
Sustainability Accounting (FSA) Credential® designed for all professionals who would
benefit from understanding the link between sustainability and financial performance.
The IFRS Sustainability knowledge hub hosts content developed by the
IFRS Foundation and more than 100 resources developed by third-party organisations.

Disclosing resilience of strategy under different climate-related scenarios

Continuing to focus on companies’ disclosure of the resilience of their strategies

under various climate-related scenarios, such as a climate-related scenario aligned
with the latest international agreement on climate change.

2024 update IFRS S2 requires a company to disclose information about the resilience of its
strategy to climate-related risks and that this disclosure be informed by scenario
analysis. The application guidance accompanying IFRS S2 helps companies in
determining an approach to climate-related scenario analysis that is commensurate
with their circumstances.
This report shows that companies continue to disclose the resilience of their
strategies under various climate-related scenarios, such as a scenario aligned
with the latest international agreement on climate change referred to in the
TCFD recommended disclosures.
IFRS S2 does not specify particular scenarios for a company to use in its
climate‑related scenario analysis. IFRS S2 requires a company to select scenarios
that are relevant to its circumstances in order to provide useful information to users of
general purpose financial reports.
Additional resources about scenario analysis are available in the IFRS Sustainability
knowledge hub.

continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 10

Decision-useful disclosure on other sustainability topics

Continuing to focus on decision-useful disclosure on other sustainability

topics—such as biodiversity, water and social issues—and considering the links
between climate-related and other sustainability issues (for example, in the context of
companies’ transition plans).

2024 update In December 2023 the IFRS Foundation published Educational material—Nature
and social aspects of climate-related risks and opportunities, as part of its efforts to
support application of IFRS S1 and IFRS S2.
The educational material illustrates how nature and social aspects can be relevant
climate-related risks and opportunities using three examples that illustrate disclosures
when applying IFRS S2.
IFRS S1 already requires a company to disclose material information about
the sustainability-related risks and opportunities reasonably expected to affect
its prospects and to provide information about connections between various
sustainability-related risks and opportunities.
In 2024 the ISSB agreed on its future work plan. That work plan includes work
to enhance the SASB Standards, which provide information on a range of
sustainability‑related risks and opportunities. The work plan also includes projects to
research disclosure about a company’s risks and opportunities associated with:
• biodiversity, ecosystems and ecosystem services; and
• human capital.
This research is considering additional specific disclosure requirements that would
complement the requirements in IFRS S1.

Climate-related disclosure by sovereigns

Developing a consistent climate-related financial disclosure framework for use

by countries and other sovereign entities to support companies in preparing
comprehensive TCFD-aligned disclosures and transition plans that appropriately
reflect their operating environment.

2024 update The International Public Sector Accounting Standards Board (IPSASB) is developing
a climate-related disclosure standard for the public sector, with the support of the
World Bank. In October 2024 the IPSASB published a draft standard for consultation,
building on IFRS S2.

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Contents from page

LETTER FROM ERKKI LIIKANEN 2

EXECUTIVE SUMMARY 4

Purpose of this report 4

Background information 5

Key takeaways and findings 6

Conclusion and next steps 8

Update on areas of continued focus and further work identified by the TCFD in its 2023 status report 9

SECTION 1—STATE OF CLIMATE-RELATED FINANCIAL DISCLOSURES 15

1.1—Introduction 15

1.1.1—Key takeaways 16

1.2—TCFD-aligned reporting by public companies 18

1.2.1—Scope and approach 18

1.2.2—Summary of AI review results 19

1.3—TCFD-aligned reporting by public companies by region 33

1.3.1—Africa 33

1.3.2—Latin America and the Caribbean 37

1.3.3—North America 41

1.3.4—Asia-Oceania 45

1.3.5—Europe 49

1.4—Companies referencing ISSB Standards 53

1.4.1—ISSB reference analysis by region 54

1.4.2—ISSB reference analysis by Sustainable Industry Classification System sectors 57

1.5—Reporting by asset managers and asset owners 61

1.5.1—Introduction 61

1.5.2—Scope and approach: survey of asset managers and asset owners 63

1.5.3—Summary of reporting of climate-related information 66

1.5.4—Reporting of climate-related information by asset managers 68

1.5.5—Reporting of climate-related information by asset owners 73

1.5.6—ISSB-specific questions 77

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SECTION 2—FROM TCFD RECOMMENDATIONS TO ISSB STANDARDS 78

2.1—Introduction 78

2.1.1—Key takeaways 79

2.2—Reconciliation between TCFD recommendations and requirements in ISSB Standards 80

2.3—Transition from TCFD recommendations to ISSB Standards 88

2.3.1—Understanding ISSB Standards 88

2.3.2—Gap analysis 88

2.3.3—Governance, risk management and strategy 89

2.3.4—Update reporting processes 89

2.3.5—Training and internal communication 89

2.3.6—External communication and engagement 89

2.3.7—Monitor regulatory developments 89

2.4—The role of digital taxonomies and digital reporting for climate-related data 90

2.4.1—What is the ISSB Taxonomy? 91

2.5—Examples of companies preparing to move from TCFD recommendations to ISSB Standards 94

SECTION 3—CLIMATE-RELATED INFORMATION AND FINANCIAL STATEMENTS 99

3.1—Introduction 99

3.1.1—Key takeaways 100

3.2—Climate-related financial information, IFRS Accounting Standards and financial statements 101

3.2.1—IFRS Foundation guidance on climate-related matters in financial statements 101

3.2.2—IASB’s project on climate-related and other uncertainties in the financial statements 102

3.3—ISSB’s progress in ensuring climate-related financial disclosures and financial statements

are connected 104

SECTION 4—INTRODUCTION OF CLIMATE-RELATED DISCLOSURE REQUIREMENTS IN REGULATORY

FRAMEWORKS AND OTHER INITIATIVES 105

4.1—Introduction 105

4.1.1—Key takeaways 106

4.2—Issued and proposed disclosure requirements aligned with the TCFD recommendations 107

4.3—Introduction of TCFD recommendations or ISSB Standards in regulatory frameworks by region 123

4.3.1—Africa 123

4.3.2—Latin America and the Caribbean 126

4.3.3—North America 129

4.3.4—Asia-Oceania 131

4.3.5—Europe 137

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 4.4—Interoperability of ISSB Standards with other standards and initiatives 140

4.4.1—Introduction 140

4.4.2—Interoperability between ISSB Standards and ESRS 142

4.4.3—Interoperability between ISSB Standards and GRI Standards 144

4.5—Collaboration between the ISSB and other organisations 145

SECTION 5—NEXT STEPS AND AREAS OF CONTINUED FOCUS OR FURTHER WORK 146

5.1—Update on areas of continued focus and further work identified by the TCFD 146

5.1.1—Interoperability 146

5.1.2—Guidance 146

5.1.3—Disclosing resilience of strategy under different climate-related scenarios 147

5.1.4—Decision-useful disclosure on other sustainability topics 148

5.1.5—Climate-related disclosure by sovereigns 149

5.2—Next steps 149

APPENDIX 1—COMPANY SELECTION AND AI REVIEW METHODOLOGY 151

A1.1—Companies included in the review 151

A1.2—Documents reviewed 153

A1.3—Methodology to review companies’ publicly available reports 153

A1.4—Review of company reports 154

A1.5—Performance validation 154

A1.6—Outcome 155

A1.7—Limitations of the analyses 155

APPENDIX 2—GLOSSARY AND LIST OF ACRONYMS 156

APPENDIX 3—REFERENCES 158

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SECTION 1—STATE OF CLIMATE- Given the growing number of jurisdictions around
the world using the TCFD recommendations
RELATED FINANCIAL DISCLOSURES
or planning to adopt or otherwise use
ISSB Standards in climate-related reporting
1.1—Introduction requirements, the IFRS Foundation analysed
Consistent with previous annual status reports reporting practices by industry for five regions—
prepared by the Task Force on Climate‑related Africa, Latin America and the Caribbean,
Financial Disclosures (TCFD), the IFRS Foundation North America, Asia-Oceania and Europe.
reviewed thousands of public companies’ reports The insights from the analysis are described in
for climate-related financial information. The review Section 1.3—TCFD-aligned reporting by public
was performed using the artificial intelligence (AI) companies by region.
technology developed by Bloomberg L.P. for the
Because many companies are preparing to
TCFD 2023 status report.7
make the transition from disclosures prepared
The AI technology was used to determine whether using the TCFD recommendations to disclosures
the reports include information that appears to prepared using ISSB Standards, the IFRS
align with the 11 TCFD recommended disclosures, Foundation reviewed the publicly available
organised into four disclosure pillars related to reports of listed and private companies to collect,
governance, strategy, risk management, and categorise and analyse references to the use
metrics and targets (see Table 1.2). Historically, the (or planned use) of ISSB Standards. Reference
information on climate-related financial disclosures categories include general reference, planned
resulting from the AI reviews has been helpful for alignment and stated alignment. The results are
companies and investors in understanding current discussed in Section 1.4—Companies referencing
reporting practices. Other stakeholders have also ISSB Standards.
expressed interest in understanding changes and
Consistent with prior TCFD status reports, the
trends in climate-related financial disclosures
IFRS Foundation also collected information on
over time.
asset managers’ and asset owners’ reporting to
To assess the current state and evolution their clients and beneficiaries and a broader range
of climate-related financial disclosures, the of stakeholders. These financial institutions were
IFRS Foundation used the AI technology to review excluded from the AI review because the types
the reports of 3,814 public companies over a of reports required for analysis were not always
two-year period—fiscal years 2022 and 2023—as publicly available. Instead, the IFRS Foundation
described in Section 1.2—TCFD-aligned reporting carried out a survey to gain insights into the asset
by public companies.8 managers’ and asset owners’ climate-related
reporting practices. The results are described in
Section 1.5—Reporting by asset managers and
asset owners.
Table 1.1 summarises the key takeaways of
Section 1.

7 The IFRS Foundation acknowledges the support of Bloomberg Philanthropies in connection with this report. Neither the IFRS Foundation,
Bloomberg Philanthropies nor their affiliates provide any guarantee or representation as to the correctness or completeness of any part of this
work; nor shall any such party be responsible for or have any liability to any person whatsoever with respect thereto.
8 In this report, references to years are to fiscal year reporting unless the context specifies otherwise.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 15

1.1.1—Key takeaways
Table 1.1—Key takeaways

The number of public companies disclosing TCFD-aligned information continues to

grow, but more progress is necessary. In fiscal year 2023 82% of companies disclosed
information in line with at least one of the 11 TCFD recommended disclosures and 44%
of companies with at least five of the recommended disclosures. Approximately 2–3% of
companies reported in line with all 11 TCFD recommended disclosures.

The percentage of companies disclosing in line with each of the 11 TCFD recommended
disclosures increased from 2022 to 2023. The largest increase in reporting was for
companies reporting on their greenhouse gas (GHG) emissions and climate-related
metrics, at 10 and eight percentage points respectively. In fiscal year 2023 the most
frequently disclosed recommended disclosure was about GHG emissions, made by 63% of
the companies reviewed.

The least disclosed recommended disclosure for both 2022 and 2023 was the resilience
of companies’ strategies under different climate-related scenarios, with 11% of companies
disclosing this information in 2023.

Companies were more likely to disclose climate-related financial information in their

climate or sustainability reports than in their financial filings. However, the number of
companies that included TCFD-aligned information in their financial filings increased
from 2022 to 2023. ISSB Standards require companies to provide sustainability-related
financial information simultaneously with the financial statements as part of their general
purpose financial reports. Accordingly, the location of reported information is expected to
change in the future as more companies start to use ISSB Standards.

Between October 2023 and March 2024, more than 1,000 companies referenced the
ISSB in their reports. In Africa and Asia-Oceania, approximately half of the 554 companies
that referenced the ISSB mentioned their current or future alignment in reporting with the
sustainability-related disclosure requirements in ISSB Standards.

Most asset managers and asset owners who responded to survey questions about
the ISSB Standards want or expect portfolio companies to make the transition from
disclosures prepared using the TCFD recommendations to disclosures prepared using
ISSB Standards. These respondents cited the integration of the TCFD recommendations
into ISSB Standards, the comparability of information provided in accordance with
ISSB Standards and increasing jurisdictional adoption of ISSB Standards as the primary
reasons in support of the transition.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 16

Table 1.2—Four core TCFD recommendations and 11 supporting recommended disclosures9

1—Governance 2—Strategy 3—Risk management 4—Metrics and targets

Disclose the Disclose the actual Disclose how Disclose the metrics
company’s and potential the company and targets used
governance around impacts of climate- identifies, assesses to assess and
climate-related risks related risks and and manages manage relevant
and opportunities. opportunities on climate‑related risks. climate‑related risks
the company’s and opportunities
businesses, strategy where such
and financial information is
planning where material.
such information is
material.

a) Describe the a) Describe the a) Describe the a) Disclose the

board’s oversight of climate-related risks company’s processes metrics used by the
climate‑related risks and opportunities the for identifying company to assess
and opportunities. company has identified and assessing climate‑related risks
over the short, medium climate‑related risks. and opportunities in line
and long term. with its strategy and risk
management process.
1 3 6 9

b) Describe b) Describe the impact b) Describe the b) Disclose Scope 1,

management’s of climate-related risks company’s processes Scope 2 and, if
role in assessing and opportunities for managing appropriate, Scope 3
and managing on the company’s climate‑related risks. GHG emissions, and
climate‑related risks businesses, strategy the related risks.
and opportunities. and financial planning.
2 4 7 10

c) Describe the c) Describe how c) Describe the targets

resilience of processes for used by the company to
the company’s identifying, assessing manage climate-related
strategy, taking into and managing risks and opportunities
consideration different climate‑related risks and performance
climate-related are integrated into the against targets.
scenarios, including a company’s overall risk
2°C or lower scenario. management.

5 8 11

9 Table 1.2 reflects the wording in the TCFD recommendations. The ISSB Standards integrate the TCFD recommendations, although some
changes have been made to the wording and detailed requirements. Refer to Section 2.2—Reconciliation between TCFD recommendations and
requirements in ISSB Standards for a comparison of IFRS S2 and TCFD recommendations.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 17

1.2—TCFD-aligned reporting by Six of the eight industries correspond to industry
public companies groups in the TCFD 2017 status report: banking,
insurance, energy, materials and buildings,
This section summarises the scope of the review transportation, and agriculture, food and forest
and the approach used to examine how public products.12 Of these industry groups, the
companies reporting for fiscal years 2022 and TCFD identified four non-financial industries as
2023 aligns with the 11 TCFD recommended those potentially most affected by climate change
disclosures. The section then presents the results and the transition to a low-carbon economy.
and key findings from the review. Beginning with the TCFD 2019 status report,
the TCFD added two additional industries to
1.2.1—Scope and approach
the review process to consider other companies
For this report, the IFRS Foundation sought to that might be exposed to climate-related risks
maintain as much methodological consistency and opportunities—technology and media
as possible with the TCFD 2023 status report.10 and consumer goods.13,14 Starting in 2023, in
Accordingly, the IFRS Foundation followed addition to analysing a smaller set of larger
the approach discussed in the TCFD 2023 and less geographically diverse companies,
status report to identify industries, regions and the TCFD status report included an expanded
companies’ relevant reports for the analysis. and more geographically diverse set of public
Consistent with the approach in the TCFD 2023 companies in the eight industries and five regions
status report, the IFRS Foundation reviewed (3,110 companies). For this year’s report, the
financial filings, annual reports, integrated IFRS Foundation focuses on the analysis of a
reports, sustainability reports and other relevant larger set of geographically diverse companies in
reports by public companies from five regions the eight industries and five regions.
(Africa, Latin America and the Caribbean, North
America, Asia-Oceania and Europe) and in
eight industries (banking, insurance, energy,
materials and buildings, transportation, agriculture,
food and forest, technology and media, and
consumer goods).11

10 TCFD, Task Force on Climate-related Financial Disclosures: 2023 Status Report, TCFD, 2023,
https://www.fsb.org/wp-content/uploads/P121023-2.pdf.
11 Note, in this year’s report, the IFRS Foundation used a definition of regions that differs from that in the TCFD 2023 status report in two main
aspects: first, the Middle East is part of Asia-Oceania and, second, Mexico is part of Latin America and the Caribbean. This definition aligns with
jurisdictional groupings used by the IFRS Foundation.
12 TCFD, Final Report—Recommendations of the Task Force on Climate-related Financial Disclosures, TCFD, 2017, https://assets.bbhub.io/
company/sites/60/2021/10/FINAL-2017-TCFD-Report.pdf.
13 TCFD, Task Force on Climate-related Financial Disclosures: 2019 Status Report, TCFD, 2019, https://assets.bbhub.io/company/
sites/60/2020/10/2019-TCFD-Status-Report-FINAL-0531191.pdf.
14 Note that in March 2023, changes were implemented to the Global Industry Classification Standard. These changes were considered in this
year’s report when grouping companies into industries. See S&P Dow Jones Indices, ‘S&P Dow Jones Indices and MSCI announce revisions to
the Global Industry Classification Standard (GICS®) structure in 2023’, S&P Global, 2022,
https://www.msci.com/documents/1296102/29559863/GICS_Press_Release_31_March_2022.pdf/f0ac4118-d6c3-4456-3c7b-
2b0174099e4e?t=1648760411652.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 18

The IFRS Foundation used the same AI technology Table 1.3—AI review population size
for this year’s review as the TCFD used for the
review in the 2023 status report. Using the same Industry Number of
AI technology facilitates comparability between this companies
year’s results and the previous year’s results. More
information on the review methodology is provided Banking 534
in Appendix 1—Company selection and AI review Insurance 150
methodology. Because the AI technology cannot
Energy 444
process reports in languages other than English,
the number of companies that could be included Materials and buildings 1,398
in the review was smaller for some jurisdictions
Transportation 242
located in Africa, Latin America and the Caribbean,
Asia-Oceania and Europe. Agriculture, food and forest products 288
Technology and media 364
Importantly, consistent with previous TCFD Consumer goods 394
status reports, the AI review was not
designed to assess the quality of companies’ Total 3,814
climate-related financial disclosures, but
instead to analyse whether companies 1.2.2—Summary of AI review results
include climate-related financial disclosures
Overall trends
that align with the 11 TCFD recommended
disclosures. This section summarises the results and findings
from the AI review of public companies’ reports for
fiscal years 2022 and 2023 in terms of alignment
Table 1.3 summarises the sample of companies with the 11 TCFD recommended disclosures.
analysed by industry. The final population for this
year’s AI review comprises 3,814 companies, Key takeaway
resulting in the analyses of 25,127 reports in
2022 and 26,637 reports in 2023, after excluding In the two years reviewed, 2022 and 2023,
companies without available reports in English and considering the findings in the TCFD 2023
for 2022 and 2023. As such, the reports analysed status report, disclosure of climate-related
correspond to available financial filings, annual information continues to increase but more
reports, integrated reports, sustainability reports progress is needed.
and other relevant reports for a given company,
all of which are in English. Notably, this year’s
sample is an approximate 23% increase from
the expanded population of 3,110 companies
analysed in the TCFD 2023 status report. The AI
technology was employed to determine whether
company reports included information that
appeared to align with one or more of the 11 TCFD
recommended disclosures.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 19

Overall, the percentage of companies disclosing Percentage of companies disclosing
information in line with the TCFD recommendations Number of recommended disclosures
increased in 2023 relative to 2022, as did
the amount of TCFD-aligned information that At least 1
82% Year
companies disclosed. The results of this report and
2022
of previous TCFD annual status reports are that the At least 1 2023
73%
percentage of companies disclosing climate‑related
information continues to increase, but more
progress is necessary.
At least 5
For example, as shown in Figure 1.1, the 44%
percentage of companies disclosing information in
line with at least one of the 11 TCFD recommended
disclosures is 82% in 2023—up from 73% At least 5 At least 7
38% 29%
in 2022. Similarly, 44% of companies disclosed
information in line with at least five of the 11 TCFD
At least 7
recommended disclosures in 2023—up from 25%
38% in 2022. Approximately 2–3% of companies
disclosed in line with all 11 recommended
All 11
disclosures. Furthermore, the average number of 2%
the recommended disclosures made per company At least 1 At least 5 At least 7 All 11
in 2022 was 5.1 and increased in 2023 to 5.2.
Base size: 3,814
Figure 1.1—AI review results for fiscal years
2022 and 2023

Percentage of companies reporting on at least one

TCFD recommended disclosure

82%
73%

2022 2023
Base size: 3,814

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 20

As shown in Figure 1.2, the percentage of
companies disclosing information in line with Key takeaway
each of the 11 TCFD recommended disclosures
Companies reported on climate-related metrics
increased from 2022 to 2023. The largest increase
and targets and board oversight more than
in reporting was for companies reporting on their
other recommended disclosures.
GHG emissions and climate-related metrics,
at 10 and eight percentage points respectively.
In contrast, 11% of the reviewed companies
Reporting on board oversight of climate-related
disclosed the resilience of their strategy
issues saw the third-largest increase, at seven
(Strategy c) for the fiscal year 2023, compared
percentage points.
with 9% in fiscal year 2022. A 2022 TCFD survey
of more than 200 companies found that almost
Key takeaway 90% of the surveyed companies rated this
recommended disclosure as somewhat difficult
From 2022 to 2023 the recommended
or very difficult to implement, which might help
disclosure that saw the largest increase
explain the lower frequency of reporting for
in reporting by companies was for
this recommendation.15 Similarly, 18% of the
GHG emissions and climate-related
companies reviewed in 2023 discussed how
metrics, followed by board oversight of
the processes for identifying, assessing and
climate‑related disclosures.
managing climate‑related risks are integrated into
the company’s overall risk management (Risk
In general, reporting on climate-related metrics management c), up from 16% in fiscal year 2022.
and targets was higher than for the other three
core TCFD recommendations. In 2023, more than Key takeaway
60% of the reviewed companies disclosed their
GHG emissions (Metrics and targets b). In addition, In the two years reviewed, the least-reported
more than 50% of the companies reported on recommended disclosures were the resilience
climate‑related metrics and targets. Notably, the of the company’s strategy under different
percentage of companies reporting on governance, climate-related scenarios and the integration
specifically, board oversight of climate-related of climate-related risks and opportunities into
disclosures, was also more than 50%. overall risk management.

15 See TCFD, Task Force on Climate-related Financial Disclosures: 2022 Status Report, TCFD, 2022,
https://assets.bbhub.io/company/sites/60/2022/10/2022-TCFD-Status-Report.pdf.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 21

Figure 1.2—TCFD-aligned disclosures by fiscal year for 2022 and 2023

Recommendations Recommended disclosure Fiscal year

Governance a) Board oversight 2022 48%

2023 55%

b) Management’s role 2022 31%

2023 34%

Strategy a) Risks and opportunities 2022 34%

2023 38%

b) Impact of risks and 2022 33%

opportunities on company
2023 37%

c) Resilience of strategy 2022 9%

2023 11%

Risk management a) Risk identification and 2022 25%

assessment processes
2023 28%

b) Risk management 2022 30%

processes
2023 34%

c) Integration into overall 2022 16%

risk management
2023 18%

Metrics and targets a) Climate-related metrics 2022 46%

2023 54%

b) GHG emissions 2022 53%

2023 63%

c) Climate-related targets 2022 48%

2023 53%

0% 10% 20% 30% 40% 50% 60% 70%

Base size: 3,814

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 22

Location of disclosure Trends by industry
This section summarises the results of alignment
Key takeaway with the 11 TCFD recommended disclosures by
industry for fiscal years 2022 and 2023.
Companies were more likely to disclose
TCFD-aligned information in their climate
or sustainability reports than in their Key takeaway
financial filings.
Companies in all reviewed industries continue
to increase disclosures that align with
Although companies disclosed information in the TCFD recommendations. The largest
various types of reports (for example, financial increase in reporting aligned with the TCFD
filings, annual reports, and climate and recommendations was for companies in the
sustainability reports), they were more likely to technology and media industry.
disclose TCFD-aligned information for fiscal year
2023 in their climate or sustainability reports
The comparison of reporting by industry for
than in financial filings. For example, for all TCFD
fiscal years 2022 and 2023 shows an increase in
recommended disclosures, companies were
disclosures for nearly all TCFD recommendations
approximately twice as likely to provide information
and by nearly all industries (see Figure 1.3).
in their climate or sustainability reports than in their
The largest increase in reporting aligned with
financial filings. However, the number of companies
the TCFD recommendations was for companies
that included TCFD-aligned information in their
in the technology and media industry, which
financial filings increased from 2022 to 2023.
historically had comparatively low reporting rates
For reviewed climate or sustainability reports, the
(see, for example, the TCFD 2023 status report).
most frequently reported TCFD recommended
Specifically, technology and media companies
disclosure was the disclosure of GHG emissions
reporting increased by 16 percentage points for the
information (Metrics and targets b). For reviewed
governance recommendation, by seven percentage
annual reports, the most frequently reported TCFD
points for the strategy recommendation, by
recommended disclosure was the disclosure
11 percentage points for the risk management
about the board’s oversight of climate-related risks
recommendation and by 17 percentage points
and opportunities (Governance a). For reviewed
for disclosure of climate-related metrics and
financial filings, the most frequently reported TCFD
targets. The banking and insurance industries and
recommended disclosure was the disclosure
agriculture, food and forest products companies
about the company’s climate-related risks and
had consistent levels of disclosure or showed
opportunities (Strategy a). In contrast, the least
moderate increases in reporting for some of the
disclosed recommendation in all three types of
TCFD recommendations.
reports was information about the resilience of
the company strategy in different climate-related
scenarios (Strategy c).

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 23

Figure 1.3—TCFD-aligned disclosures by industry for fiscal years 2022 and 2023

buildings (1,398)

Consumer goods
Agriculture, food
Insurance (150)

Technology and
products (288)
Transportation
Banking (534)

Materials and
Energy (444)

media (364)
2022

and forest
2023

(242)

(394)
Recommendations

Governance 61% 64%

55% 58%

44% 44%
40% 38%
41% 40% 42% 40%
37% 35% 37%
24%

Strategy

38% 38% 37% 39%

29% 29%
24% 25% 24% 26% 27% 24%
23% 22% 20%
15%

Risk management

48%
44%

30% 33% 33%

27% 25% 24% 24%
22% 21% 23% 23%
18% 20%
12%

69%
Metrics and targets 64%
61%
59%
54% 57% 56% 54% 57% 52% 52%
50%
46%
41% 43%
35%

The numbers in parentheses represent the size of the review population.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 24

 Companies in the energy and insurance industries
Key takeaway also had the highest rates of reporting on five of
the 11 recommended disclosures. Specifically,
Energy and insurance companies disclosed
energy companies were the industry with the
more information aligned with the TCFD
highest rate of reporting on the impact of risks
recommendations than companies in
and opportunities on the company, resilience
other industries.
of strategy, climate-related metrics, GHG
emissions and climate-related targets. Insurance
Energy and insurance companies, on companies had the highest rate of reporting on
average, reported on approximately 5.5 of the board oversight, management’s role, risks and
11 recommended disclosures in 2023, and opportunities, risk identification and assessment
materials and buildings companies reported on processes, risk management processes and
4.3; companies in the technology and media integration into overall risk management. Banks
and consumer goods industries, on average, had comparatively high rates of reporting on the
reported on the fewest recommended disclosures risk management recommendation, which might
(see Table 1.4). reflect financial regulators’ emphasis on risk
management processes (see Table 1.5).
Table 1.4—Average number of recommended
disclosures per company for fiscal year 2023, Companies in the consumer goods and
by industry technology and media industries made fewer of
the recommended disclosures than companies in
Industry Number of other industries. As noted previously, these two
disclosures industries were added to the review to examine
Insurance 5.5 other companies that might be exposed to
climate-related risks. The other four non-financial
Energy 5.4 industries—energy, materials and buildings,
Materials and buildings 4.3 transportation, and agriculture, food and forest
products—were included in previous TCFD status
Transportation 4.2
reports because they were considered most likely
Agriculture, food and forest products 4.1 to be affected by climate change. Consumer goods
Banking 3.8 and technology and media industries’ lower risk of
exposure to climate-related risks might explain why
Technology and media 3.7
companies in these two industries make relatively
Consumer goods 3.6 fewer recommended disclosures.

In general, reporting on climate-related metrics and

targets, including the disclosure of GHG emissions,
and board oversight is considerably higher than
reporting on other recommended disclosures in all
industries reviewed (see Table 1.5).

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 25

Table 1.5—Disclosure by industry for fiscal year 2023

Percentage of companies
Recommendation Recommended disclosure

forest products (288)

Agriculture, food and
buildings (1,398)

Consumer goods
Insurance (150)

Technology and
Transportation
Banking (534)

Materials and
Energy (444)

media (364)
(242)

(394)
Governance a) Board oversight 47% 71% 70% 54% 55% 51% 55% 48%
b) Management’s role 33% 57% 46% 33% 34% 33% 25% 27%
Strategy a) Risks and opportunities 41% 57% 50% 37% 31% 33% 25% 35%
b) Impact of risks and
26% 44% 49% 40% 40% 39% 34% 31%
opportunities on company
c) Resilience of strategy 7% 15% 18% 11% 7% 13% 7% 8%
Risk management a) Risk identification and
31% 48% 34% 27% 24% 26% 23% 22%
assessment processes
b) Risk management
33% 53% 42% 33% 29% 31% 33% 24%
processes
c) Integration into overall risk
27% 31% 24% 15% 17% 14% 13% 14%
management
Metrics and targets a) Climate-related metrics 45% 50% 68% 57% 61% 51% 48% 49%
b) GHG emissions 52% 61% 75% 66% 62% 62% 60% 58%
c) Climate-related targets 40% 59% 65% 54% 60% 59% 49% 48%
The numbers in parentheses represent the size of the review population.

Trends by region increase in disclosures aligned with the TCFD

recommendations was by companies operating
Key takeaway in Asia-Oceania, which historically had moderate
reporting rates (see, for example, the TCFD
The region with the largest increase 2023 status report). Specifically, the reporting of
in disclosures aligned with the TCFD reviewed companies in Asia-Oceania increased
recommendations was Asia-Oceania. by 10% for the governance recommendation,
Other regions had generally consistent levels by 8% for the strategy recommendation, by 7%
of disclosure. for the risk management recommendation and
by 15% for disclosure of climate-related metrics
The comparison of reporting by regions and targets. Companies in Africa, Latin America
for fiscal years 2022 and 2023 shows an and the Caribbean, North America and Europe
increase in or consistent levels of disclosures had relatively consistent levels of disclosure or
in nearly all regions for the four core TCFD moderate increases or decreases in reporting for
recommendations (see Figure 1.4). The largest some of the TCFD recommendations.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 26

Figure 1.4—TCFD-aligned disclosures by region for fiscal years 2022 and 2023

Latin America and

2022 Africa the Caribbean North America Asia-Oceania Europe
2023 (113) (119) (1,111) (1,754) (717)

Governance

60% 63%
49% 48%
38% 39% 35% 36%
29% 26%

Strategy

41% 42%
32% 31%
22% 24% 23%
18% 18% 15%

Risk management

43% 46%

24% 23% 24% 27% 25%

19% 21%
14%

Metrics and targets

80% 82%

51% 53%
48% 46% 46% 47% 48%
38%

The numbers in parentheses represent the size of the review population.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 27

 In all regions, the lowest reporting rates were on
Key takeaway the resilience of the company’s strategy under
different climate-related scenarios (Strategy c)
Companies in Europe had the highest reporting
and on the integration of climate-related risks into
rates for each of the 11 recommended
overall risk management (Risk management c).
disclosures.
Table 1.6—Average number of recommended
As in 2022, in 2023 the highest level of reporting disclosures per company for fiscal year 2023,
aligned with the TCFD recommendations was by region
by European companies. Approximately 80% of
companies in Europe reported on climate-related Region Number of
metrics and targets, including reporting on GHG disclosures
emissions at 84%, followed by 70% reporting on
Europe 6.4
board oversight (see Table 1.7). The reviewed
European companies, on average, reported on 6.4 North America 4.1
of the 11 recommended disclosures in 2023 (see Africa 3.7
Table 1.6).
Asia-Oceania 3.6
In comparison, reporting by companies in Africa,
Latin America and the Caribbean, North America Latin America and the Caribbean 3.3
and Asia-Oceania on climate-related metrics and
targets was approximately 20–30 percentage
points lower than by companies in Europe (see
Table 1.7). Section 1.3—TCFD-aligned reporting by
public companies by region provides more details
for the amount of TCFD-aligned disclosures for
each region.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 28

Table 1.7—Disclosure by region for fiscal year 2023

Percentage of companies
Recommendation Recommended disclosure

the Caribbean (119)

Latin America and

North America

Europe (717)
Asia-Oceania
Africa (113)

(1,111)

(1,754)
Governance a) Board oversight 50% 43% 59% 47% 70%

b) Management’s role 29% 28% 38% 24% 56%

Strategy a) Risks and opportunities 28% 27% 53% 24% 52%

b) Impact of risks and opportunities on company 34% 23% 31% 37% 52%

c) Resilience of strategy 9% 4% 8% 8% 22%

Risk management a) Risk identification and assessment processes 21% 23% 25% 19% 57%

b) Risk management processes 30% 29% 29% 30% 50%

c) Integration into overall risk management 17% 20% 20% 13% 29%
Metrics and targets a) Climate-related metrics 50% 44% 42% 52% 80%

b) GHG emissions 56% 50% 52% 62% 84%

c) Climate-related targets 47% 43% 49% 45% 83%
The numbers in parentheses represent the size of the review population.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 29

Trends by market capitalisation US$3.2 billion in market capitalisation reported
on an average of 3.4 recommended disclosures.
Key takeaway These findings are consistent with the findings in
the previous TCFD annual status reports.
Companies with a market capitalisation of
The highest rates of reporting by companies
at least US$3.2 billion were more likely to
with a market capitalisation of at least
disclose TCFD-aligned information than
US$12.3 billion were for GHG emissions, at
those with a market capitalisation of less than
70%, followed by climate-related metrics and
US$3.2 billion.
targets at approximately 60% (see Table 1.9).
Similarly, companies with market capitalisation
Companies with larger market capitalisation in the range US$3.2–12.3 billion reported most
were more likely to disclose TCFD-aligned frequently on GHG emissions at 65% and on
information than companies with smaller market climate-related metrics and targets at 56%.
capitalisation. The comparison of reporting for Reporting of GHG emissions by companies with
TCFD recommendations for companies of differing market capitalisation of less than US$3.2 billion
sizes for fiscal years 2022 and 2023 shows an was at 46%, whereas the rate of reporting on
increase or consistent levels of disclosures for climate-related metrics and targets was at 40%.
all four core recommendations (see Figure 1.5). Relatively similar rates of reporting on climate-
The increase in disclosures aligned with the TCFD related metrics and targets for each size group may
recommendations was the largest for companies be due to companies reporting on climate-related
with a market capitalisation of at least US$3.2 metrics because of their net-zero or other GHG
billion, which historically had higher reporting rates emissions reduction commitments.
(see, for example, the TCFD 2023 status report).
In addition, companies of all sizes reported
For example, reporting of companies with a market on board oversight of climate-related risks
capitalisation of at least US$12.3 billion increased and opportunities at approximately 50% or
by 6% for the governance recommendation, by higher. Reporting on resilience of strategy and
4% for the strategy recommendation, by 3% for integration of climate-related risks into overall
the risk management recommendation and by risk management was the lowest for all company
11% for disclosure of climate-related metrics sizes. These results are consistent with the overall
and targets. In comparison, companies with a trends in this report and in previous TCFD annual
market capitalisation of less than US$3.2 billion status reports.
had relatively consistent levels of disclosure or a
moderate increase in reporting across some of the Table 1.8—Average number of recommended
TCFD recommendations. disclosures per company for fiscal year 2023,
by market capitalisation
Tables 1.8 and 1.9 delve deeper into reporting that
aligns with the 11 TCFD recommended disclosures
Market capitalisation Number of
for fiscal year 2023. Companies with a market
(US$ billion) disclosures
capitalisation of at least US$12.3 billion reported
on an average of 4.6 of the 11 recommended >12.3 4.6
disclosures in 2023. Companies with market
3.2–12.3 4.5
capitalisation in the range US$3.2–12.3 billion
reported on an average of 4.5 recommended <3.2 3.4
disclosures, whereas companies with less than

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 30

Figure 1.5—TCFD-aligned disclosures by market capitalisation for fiscal years 2022 and 2023

2022 <US$3.2b US$3.2b–12.3b >US$12.3b

2023 market capitalisation (929) market capitalisation (879) market capitalisation (2,006)

Governance

45% 49% 46%

38% 40%
34%

Strategy

27% 30% 26% 30%

22% 24%

Risk management

27% 31% 27%

20% 21% 24%

Metrics and targets

59% 63%
54% 52%
39% 42%

The numbers in parentheses represent the size of the review population.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 31

Table 1.9—Disclosure by company size for fiscal year 2023

Percentage of companies
Recommendation Recommended disclosure
<US$3.2b US$3.2b– >US$12.3b
market 12.3b market market
capitalisation capitalisation capitalisation
(929) (879) (2,006)

Governance a) Board oversight 48% 61% 56%

b) Management’s role 29% 36% 36%

Strategy a) Risks and opportunities 39% 42% 35%

b) Impact of risks and opportunities on company 24% 38% 43%

c) Resilience of strategy 8% 10% 12%

Risk management a) Risk identification and assessment processes 24% 33% 28%

b) Risk management processes 25% 36% 36%

c) Integration into overall risk management 15% 23% 17%

Metrics and targets a) Climate-related metrics 40% 56% 60%

b) GHG emissions 46% 65% 70%

c) Climate-related targets 40% 56% 58%
The numbers in parentheses represent the size of the review population.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 32

1.3—TCFD-aligned reporting by public Table 1.11 provides descriptive statistics for seven
companies by region out of eight industry groups in Africa, including
an indication of companies’ size based on total
This section provides insights into TCFD‑aligned assets for financial institutions and total revenues
reporting practices by industry for each region— for non-financial companies. The median assets
Africa, Latin America and the Caribbean, for reviewed banks and insurance companies were
North America, Asia-Oceania and Europe. US$20.9 billion and US$4.9 billion, respectively.
The non-financial companies had median revenues
1.3.1—Africa
ranging from approximately US$300 million to
The AI review of companies headquartered in US$3 billion.
Africa included 113 companies in 13 jurisdictions.
The three jurisdictions with the largest number Table 1.11—Demographics of reviewed
of companies reviewed were South Africa companies in Africa
(69 companies), Nigeria and Egypt (10 companies
in each), as shown in Table 1.10. Number of companies and size range by industry

Total assets (US$ billion)

Table 1.10—Number of reviewed companies in
Africa by jurisdiction Financial Number of First Median Third
institutions companies quartile quartile
Banking 15 3.6 20.9 66.8
South Africa 69 Zambia 3
Insurance 10 1.4 4.9 36.2
Nigeria 10 Botswana 2
Revenue (US$ billion)
Egypt 10 Ghana 2 Non-financial Number of First Median Third
companies companies quartile quartile
Kenya 7 Mauritius 2
Agriculture, 21 0.4 0.6 0.8
Morocco 3 Zimbabwe 2 food and forest
products
In addition, there was one company each from
Consumer 19 1.1 3.0 6.0
Sudan, Togo and Uganda. goods
Energy 13 0.6 0.9 1.7
As discussed in Section 4.2—Issued and
proposed disclosure requirements aligned with Materials and 26 0.8 1.7 4.7
buildings
the TCFD recommendations, TCFD-aligned
disclosure requirements were in effect in Egypt, Technology and 1 – – –
media(a)
Kenya and Mauritius for fiscal year 2023.
Transportation 7 <0.1 0.3 1.0
(a) There were not enough companies to calculate statistics.

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As shown in Table 1.12, materials and buildings Table 1.12—Average number of recommended
companies, on average, reported on more disclosures per company in Africa
TCFD recommended disclosures than companies
in other industries (5.4 out of 11 recommended Industry Number of
disclosures on average). The banking and disclosures
insurance industries also had comparatively
similar levels of reporting aligned with the Materials and buildings 5.4
TCFD recommendations—these companies Banking 5.3
reported on average on 5.3 and 4.8 out of 11
Insurance 4.8
recommended disclosures. These three industries
also had the highest rates of reporting on all Consumer goods 2.9
11 recommended disclosures, respectively
Energy 2.9
(see Table 1.13). Specifically, insurance companies
had the highest levels of reporting on board Agriculture, food and forest products 2.3
oversight and climate-related targets—at 80%
Transportation 1.1
and 70%. Materials and buildings had the
highest rates of reporting on climate-related
metrics at 73%, GHG emissions at 81% and
lower rates of reporting on climate-related
targets at 62%. Companies in the transportation
industry, on average, reported in line with one
of the 11 recommended disclosures. There was
no reporting on five of the 11 recommended
disclosures for the transportation industry
(see Table 1.13). The lowest level of reporting in
each of the industries was on resilience of the
company’s strategy under different climate-related
scenarios (Strategy c). In fact, none of the reviewed
insurance, transportation or consumer goods
companies reported in line with Strategy c.

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Table 1.13—TCFD-aligned disclosures by industry for fiscal year 2023

Percentage of companies in Africa

Recommendation Recommended disclosure

Consumer goods (19)

Agriculture, food and
forest products (21)
Transportation (7)
Insurance (10)

buildings (26)
Materials and
Banking (15)

Energy (13)
Governance a) Board oversight 73% 80% 31% 69% 14% 24% 47%

b) Management’s role 53% 60% 15% 38% 0% 19% 16%

Strategy a) Risks and opportunities 27% 50% 23% 50% 0% 14% 21%
b) Impact of risks and
47% 30% 31% 54% 14% 19% 26%
opportunities on company
c) Resilience of strategy 13% 0% 15% 19% 0% 5% 0%
Risk management a) Risk identification and
40% 20% 15% 35% 0% 10% 16%
assessment processes
b) Risk management
47% 40% 23% 42% 14% 19% 21%
processes
c) Integration into overall
53% 20% 8% 15% 0% 5% 16%
risk management
Metrics and targets a) Climate-related metrics 53% 50% 46% 73% 29% 38% 42%
b) GHG emissions 67% 60% 46% 81% 29% 43% 47%
c) Climate-related targets 60% 70% 38% 62% 14% 33% 42%
The numbers in parentheses represent the size of the review population.

The review of reporting by companies in Africa for The largest increase—approximately seven
fiscal years 2022 and 2023 shows an increase in percentage points—was for disclosures of
or nearly consistent levels of disclosures for all climate‑related targets (Metrics and targets c),
TCFD recommended disclosures (see Figure 1.6). whereas the reporting on climate-related metrics
(Metrics and targets a) and board oversight
(Governance a) remained unchanged.

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Figure 1.6—TCFD-aligned disclosures in Africa for fiscal years 2022 and 2023
Percentage of companies in Africa

Recommendations Recommended disclosure Fiscal year

Governance a) Board oversight 2022 50%

2023 50%

b) Management’s role 2022 27%

2023 29%

Strategy a) Risks and opportunities 2022 25%

2023 28%

b) Impact of risks and 2022 31%

opportunities on company
2023 34%

c) Resilience of strategy 2022 10%

2023 9%

Risk management a) Risk identification and 2022 22%

assessment processes
2023 21%

b) Risk management 2022 32%

processes
2023 30%

c) Integration into overall 2022 19%

risk management
2023 17%

Metrics and targets a) Climate-related metrics 2022 50%

2023 50%

b) GHG emissions 2022 55%

2023 56%

c) Climate-related targets 2022 40%

2023 47%

0% 10% 20% 30% 40% 50% 60%

Average percentage

Base size: 113

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1.3.2—Latin America and the Caribbean Table 1.15—Demographics of companies
reviewed in Latin America and the Caribbean
The AI review of companies headquartered in
Latin America and the Caribbean consisted
Number of reviewed companies and size range by industry
of 119 companies reviewed in 10 jurisdictions.
The jurisdictions with the highest number of Total assets (US$ billion)
companies were Brazil (52 companies), Mexico (20 Financial Number of First Median Third
companies) and Chile (18 companies), as shown in institutions companies quartile quartile
Table 1.14. Banking 18 12.2 34.7 64.8
As discussed in Section 4.2—Issued and Insurance 8 10.0 16.2 41.3
proposed disclosure requirements aligned with
Revenue (US$ billion)
the TCFD recommendations, TCFD-aligned
Non-financial Number of First Median Third
disclosure requirements were in effect in Brazil,
companies companies quartile quartile
Chile and Colombia for fiscal year 2023.
Agriculture, 18 1.6 4.3 12.5
Table 1.15 provides descriptive statistics for food and forest
seven of eight industry groups in Latin America products
and the Caribbean, including an indication of the Consumer 10 2.8 13.4 16.8
companies’ sizes based on total assets for financial goods
institutions and total revenues for non-financial Energy 25 0.7 1.4 4.8
companies. The median assets for reviewed banks
Materials and 29 0.6 2.6 6.3
and insurance companies were US$34.7 billion buildings
and US$16.2 billion. The non-financial companies
Technology and – – – –
had median revenues ranging from approximately media(a)
US$1.4 billion to US$13.4 billion.
Transportation 10 0.9 1.4 2.2
Table 1.14—Number of reviewed companies in (a) There were not enough companies to calculate statistics.
Latin America and the Caribbean by jurisdiction

Brazil 52 Colombia 3

Mexico 20 Puerto Rico 3

Chile 18 Cayman Islands 2

Argentina 9 Jamaica 2

Bermuda 9 Peru 1

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The AI review results for Latin America and the Table 1.16—Average number of recommended
Caribbean are shown in Tables 1.16–1.17. disclosures per company in Latin America and
the Caribbean
The reviewed insurance companies reported on
more of the TCFD recommended disclosures
than companies in other industries. Insurance Industry Number of
companies also had the highest rates of reporting disclosures
on all the recommended disclosures except two— Insurance 6.9
climate-related targets (Metrics and targets c) and
the resilience of the company’s strategy under Materials and buildings 3.8
different climate-related scenarios (Strategy c). Consumer goods 3.4
In addition, insurance companies had the Banking 3.1
highest rate of reporting on board oversight and
integration of climate-related risks into overall risk Energy 3.0
management, both at 88%, which is consistent Agriculture, food and forest products 2.4
with the AI review results for the region in previous
Transportation 2.2
TCFD annual status reports.
Of the seven industries reviewed in Latin America
and the Caribbean, transportation companies had
the highest rates of reporting on climate-related
targets (Metrics and targets c) at 70%, and lower
rates of reporting on strategy and risk management
recommendations. In general, there was minimal
to no reporting on the resilience of companies’
strategies under different climate-related scenarios
and on integration of climate-related risks into
overall risk management (Risk management c).

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Table 1.17—TCFD-aligned disclosures by industry for fiscal year 2023

Percentage of companies in Latin America and the Caribbean

Recommendation Recommended disclosure

Consumer goods (10)

Agriculture, food and
forest products (18)
Transportation (10)
buildings (29)
Insurance (8)

Materials and
Banking (18)

Energy (25)
Governance a) Board oversight 56% 88% 48% 41% 20% 22% 40%

b) Management’s role 22% 75% 16% 34% 20% 17% 40%

Strategy a) Risks and opportunities 33% 75% 32% 14% 0% 28% 30%
b) Impact of risks and
6% 50% 28% 31% 10% 22% 10%
opportunities on company
c) Resilience of strategy 0% 0% 0% 14% 0% 0% 10%
Risk management a) Risk identification and
17% 50% 24% 31% 0% 17% 20%
assessment processes
b) Risk management
22% 63% 24% 41% 0% 17% 40%
processes
c) Integration into overall
22% 88% 16% 24% 10% 0% 10%
risk management
Metrics and targets a) Climate-related metrics 39% 75% 40% 48% 40% 33% 50%
b) GHG emissions 56% 75% 44% 52% 50% 44% 50%
c) Climate-related targets 33% 50% 32% 48% 70% 44% 40%
The numbers in parentheses represent the size of the review population.

The comparison of reporting by companies integration of climate‑related risks into overall risk
in Latin America and the Caribbean for fiscal management (Risk management c), followed by
years 2022 and 2023 shows an increase in or management and board oversight—approximately
generally consistent levels of disclosures for all five to seven percentage points (Governance a
TCFD recommended disclosures (see Figure 1.7). and b). There was a slight decrease in reporting on
The largest increase—approximately seven climate‑related targets (Metrics and targets c).
percentage points—was for disclosures of

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 39

Figure 1.7—TCFD-aligned disclosures in Latin America and the Caribbean for fiscal years 2022
and 2023
Percentage of companies in Latin America and the Caribbean

Recommendation Recommended disclosure Fiscal year

Governance a) Board oversight 2022 36%

2023 43%

b) Management’s role 2022 23%

2023 28%

Strategy a) Risks and opportunities 2022 28%

2023 27%

b) Impact of risks and 2022 24%

opportunities on company
2023 23%

c) Resilience of strategy 2022 4%

2023 4%

Risk management a) Risk identification and 2022 18%

assessment processes
2023 23%

b) Risk management 2022 27%

processes
2023 29%

c) Integration into overall 2022 13%

risk management
2023 20%

Metrics and targets a) Climate-related metrics 2022 43%

2023 44%

b) GHG emissions 2022 49%

2023 50%

c) Climate-related targets 2022 45%

2023 43%

0% 10% 20% 30% 40% 50% 60%

Base size: 119

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1.3.3—North America Table 1.19—Demographics of reviewed
companies in North America
The AI review of companies headquartered in
North America included 1,111 companies, with the Number of reviewed companies and size range by industry
majority headquartered in the United States (946
Total assets (US$ billion)
companies) and the remainder in Canada (165
companies), as shown in Table 1.18. Financial Number of First Median Third
institutions companies quartile quartile
As discussed in Section 4.2—Issued and
Banking 224 7.5 14.9 43.1
proposed disclosure requirements aligned with
the TCFD recommendations, no TCFD-aligned Insurance 52 6.9 34.3 93.0
disclosure requirements were in effect in fiscal year Revenue (US$ billion)
2023 in Canada or the US. Non-financial Number of First Median Third
companies companies quartile quartile
Table 1.19 provides descriptive statistics for
reviewed companies in eight industry groups Agriculture, 56 2.0 7.0 12.5
food and forest
along with an indication of their size based on total
products
assets for financial institutions and total revenue
for non-financial companies. The median assets Consumer 128 2.7 6.7 18.1
goods
for reviewed banks and insurance companies were
US$14.9 billion and US$34.3 billion, respectively. Energy 184 1.1 2.9 10.5
The non-financial companies had median revenues Materials and 336 1.2 2.7 6.8
ranging from approximately US$2.7 billion to buildings
US$7 billion. Technology and 75 1.0 2.8 9.2
media
Table 1.18—Number of reviewed companies in
Transportation 56 3.0 6.6 13.6
North America by jurisdiction

US 946

Canada 165

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The AI review results for North America are In six of the eight industries, close to or more than
shown in Tables 1.20–1.21. The reviewed energy 50% of the reviewed companies reported on GHG
companies reported, on average, in line with six emissions (Metrics and targets b). For all eight
of the 11 recommended disclosures—the highest industries, the lowest rates of reporting were on the
of all industries reviewed. They were followed resilience of the company’s strategy under different
by insurance companies, which disclosed an climate-related scenarios (Strategy c).
average of 4.7 of the 11 recommended disclosures.
Energy companies also had the highest rates Table 1.20—Average number of recommended
of reporting among the reviewed industries, disclosures per company in North America
reporting on eight of the 11 recommended
disclosures. The exceptions were reporting on the Industry Number of
three recommended disclosures related to risk disclosures
management. For these recommended disclosures, Energy 6.0
the reviewed insurance companies had the highest
rates of reporting. Insurance 4.7

Banks, consumer goods companies and Transportation 4.4

technology and media companies reported less Agriculture, food and forest products 4.3
climate-related information than companies in
the other reviewed industries. On average, these Materials and buildings 4.2
companies reported on two to three of the 11 Technology and media 3.4
recommended disclosures. The reporting on
targets of the reviewed North American banks was Consumer goods 3.3
at 23%, compared with the 79% reporting rate of Banking 2.8
the reviewed European banks (see Table 1.29).
The highest rates of reporting by companies
in the energy, insurance, transportation and
agriculture, food and forest products industries
were on their boards’ oversight of climate-related
issues (Governance a), whereas the highest rate
of reporting by banks was on their climate-related
risks and opportunities (Strategy a). In five of the
eight reviewed industries, more than 50% of the
companies reported on climate-related risks and
opportunities (Strategy a).

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Table 1.21—TCFD-aligned disclosures by industry for fiscal year 2023

Percentage of companies in North America

Recommendation Recommended disclosure

Agriculture, food and

forest products (56)

Consumer goods
Technology and
buildings (336)
Insurance (52)

Transportation
Banking (224)

Materials and
Energy (184)

media (75)

(128)
(56)
Governance a) Board oversight 36% 75% 82% 62% 64% 66% 52% 52%

b) Management’s role 26% 60% 61% 35% 41% 39% 29% 26%
Strategy a) Risks and opportunities 53% 58% 66% 52% 43% 48% 37% 51%
b) Impact of risks and
17% 35% 51% 34% 39% 34% 27% 20%
opportunities on company
c) Resilience of strategy 3% 8% 19% 8% 5% 9% 8% 5%
Risk management a) Risk identification and
21% 46% 32% 25% 27% 25% 19% 18%
assessment processes
b) Risk management
23% 50% 41% 30% 38% 23% 25% 13%
processes
c) Integration into overall risk
23% 31% 26% 15% 27% 20% 12% 12%
management
Metrics and targets a) Climate-related metrics 22% 23% 68% 47% 48% 41% 37% 38%

b) GHG emissions 29% 44% 79% 55% 54% 59% 49% 50%
c) Climate-related targets 23% 37% 74% 51% 59% 66% 48% 46%
The numbers in parentheses represent the size of the review population.

The comparison of reporting by companies in The largest increase—approximately three

North America for fiscal years 2022 and 2023 percentage points—was for disclosures of
shows generally consistent levels of TCFD-aligned GHG emissions (Metrics and targets b), followed
disclosures, with some recommended disclosures by an increase in reporting on climate‑related
experiencing slight increases or decreases (see targets of one percentage point (Metrics and
Figure 1.8). targets c). Reporting on risk management
processes (Risk management b) decreased by
approximately four percentage points and reporting
on management’s role (Governance a) and
impact of climate‑related risks and opportunities
on the company (Strategy b) both decreased by
approximately two percentage points.

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Figure 1.8—TCFD-aligned disclosures in North America, fiscal years 2022 and 2023
Percentage of companies in North America

Recommendation Recommended disclosure Fiscal year

Governance a) Board oversight 2022 59%

2023 59%

b) Management’s role 2022 40%

2023 38%

Strategy a) Risks and opportunities 2022 52%

2023 53%

b) Impact of risks and 2022 34%

opportunities on company
2023 31%

c) Resilience of strategy 2022 10%

2023 8%

Risk management a) Risk identification and 2022 27%

assessment processes
2023 25%

b) Risk management 2022 33%

processes
2023 29%

c) Integration into overall 2022 21%

risk management
2023 20%

Metrics and targets a) Climate-related metrics 2022 43%

2023 42%

b) GHG emissions 2022 50%

2023 52%

c) Climate-related targets 2022 48%

2023 49%

0% 10% 20% 30% 40% 50% 60%

Base size: 1,111

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 44

1.3.4—Asia-Oceania Table 1.23 provides descriptive statistics for
companies in eight industry groups, including
The AI review of companies headquartered in
an indication of companies’ sizes based on total
Asia-Oceania included 1,754 companies in
assets for financial institutions and total revenues
19 jurisdictions. As shown in Table 1.22, the
for non-financial companies. The median assets
jurisdictions with the highest number of reviewed
for reviewed banks and insurance companies
companies were Japan (359 companies), India
were US$18.5 billion and US$18.3 billion.
(311 companies), Chinese Taipei (308 companies),
The non‑financial companies had median revenues
China (125 companies) and Australia
ranging from approximately US$700 million to
(118 companies).
US$2.1 billion.
As discussed in Section 4.2—Issued and
proposed disclosure requirements aligned with Table 1.23—Demographics of reviewed
the TCFD recommendations, Chinese Taipei, companies in Asia-Oceania
Japan, New Zealand, Philippines, Singapore and
Number of reviewed companies and size range by industry
Thailand have introduced TCFD-aligned disclosure
requirements in effect in fiscal year 2023. Total assets (US$ billion)
Financial Number of First Median Third
Table 1.22—Number of reviewed companies in institutions companies quartile quartile
Asia-Oceania by jurisdiction
Banking 171 3.2 18.5 68.0
Insurance 44 2.1 18.3 166.5
Japan 359 South Korea 55
Revenue (US$ billion)
India 311 Singapore 27
Non-financial Number of First Median Third
companies companies quartile quartile
United Arab
Chinese Taipei 308 21
Emirates Agriculture, 136 0.5 1 3.1
food and forest
China 125 Philippines 21 products
Consumer 160 0.5 1.3 3.3
Australia 118 Kuwait 18
goods
Hong Kong SAR 94 Qatar 14 Energy 141 0.9 2.1 6.6

Thailand 74 Israel 9 Materials and 732 0.4 0.9 2.9

buildings
Saudi Arabia 68 Bahrain 4 Technology and 251 0.2 0.7 2.2
media
Indonesia 63 New Zealand 4
Transportation 119 0.7 2 6.9
Malaysia 61

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The AI review results for Asia-Oceania are shown Table 1.24—Average number of recommended
in Tables 1.24–1.25. disclosures per company in Asia-Oceania
On average, companies in the energy, insurance
and transportation industries disclosed more Industry Number of
information in line with the TCFD recommendations disclosures
than companies in the other industries. In Energy 4.4
comparison, companies in the consumer goods
industry provided less information in line with the Insurance 4.3
TCFD recommended disclosures, reporting on an Transportation 4.1
average of 2.9 out of 11 recommended disclosures
(see Table 1.24). Agriculture, food and forest products 3.6

Energy companies, on average, reported in line Technology and media 3.6

with 4.4 of the 11 recommended disclosures. They Materials and buildings 3.5
also had the highest rates of reporting on four of
Banking 3.3
the 11 recommended disclosures, with the highest
being reporting on GHG emissions (Metrics and Consumer goods 2.9
targets b) at 72%, which is 10 percentage points
higher than the average for the region (see Table
1.7). Insurance companies had higher levels of
reporting on risk management, with the highest
being reporting on risk management processes at
50%, which is 20 percentage points higher than the
average for the region (see Table 1.7).
The highest rates of reporting were on climate-
related metrics and targets, notably reporting on
GHG emissions, followed by reporting on board
oversight. Reporting on the resilience of strategy
and on integration of climate-related risks into
overall risk management was consistently low for
all industries in Asia-Oceania.

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Table 1.25—TCFD-aligned disclosures by industry for fiscal year 2023

Percentage of companies in Asia-Oceania

Recommendation Recommended disclosure

Agriculture, food and

forest products (136)

Consumer goods
Technology and
buildings (732)
Insurance (44)

Transportation
Banking (171)

Materials and
Energy (141)

media (251)
(119)

(160)
Governance a) Board oversight 41% 52% 57% 45% 51% 45% 57% 38%

b) Management’s role 23% 32% 29% 24% 31% 26% 22% 16%
Strategy a) Risks and opportunities 19% 34% 32% 24% 28% 22% 21% 21%
b) Impact of risks and
25% 39% 45% 38% 45% 38% 36% 29%
opportunities on company
c) Resilience of strategy 8% 16% 10% 8% 9% 10% 7% 6%
Risk management a) Risk identification and
24% 30% 23% 17% 18% 18% 21% 14%
assessment processes
b) Risk management
29% 50% 38% 29% 26% 28% 36% 20%
processes
c) Integration into overall risk
18% 18% 16% 10% 15% 12% 12% 15%
management
Metrics and targets a) Climate-related metrics 52% 52% 67% 53% 63% 48% 46% 45%
b) GHG emissions 61% 59% 72% 64% 65% 60% 61% 53%
c) Climate-related targets 36% 52% 49% 44% 55% 51% 47% 36%
The numbers in parentheses represent the size of the review population.

The comparison of reporting in Asia-Oceania for In comparison, the reporting on the resilience
fiscal years 2022 and 2023 shows an increase in of strategy (Strategy c) and the integration
reporting for all TCFD recommended disclosures of climate‑related risks into the overall risk
(see Figure 1.9). The largest increase— management (Risk management c) had the
approximately 19 percentage points—was for smallest increase at approximately three to
disclosures of GHG emissions (Metrics and targets five percentage points. The increasing rates of
b), followed by an increase in reporting of climate- disclosures in Asia‑Oceania might be related
related metrics (Metrics and targets a), board to the introduction of TCFD‑aligned disclosure
oversight (Governance a) and impact of climate- requirements in Japan, New Zealand, Singapore,
related risks and opportunities on the company Chinese Taipei and Thailand, starting with the
(Strategy b). fiscal year 2023; untabulated analyses for these
jurisdictions support this inference.

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Figure 1.9—TCFD-aligned disclosures in Asia-Oceania, fiscal years 2022 and 2023
Percentage of companies in Asia-Oceania

Recommendations Recommended disclosure Fiscal year

Governance a) Board oversight 2022 35%

2023 47%

b) Management’s role 2022 17%

2023 24%

Strategy a) Risks and opportunities 2022 16%

2023 24%

b) Impact of risks and 2022 25%

opportunities on company
2023 37%

c) Resilience of strategy 2022 5%

2023 8%

Risk management a) Risk identification and 2022 13%

assessment processes
2023 19%

b) Risk management 2022 21%

processes
2023 30%

c) Integration into overall 2022 8%

risk management
2023 13%

Metrics and targets a) Climate-related metrics 2022 36%

2023 52%

b) GHG emissions 2022 43%

2023 62%

c) Climate-related targets 2022 36%

2023 45%

0% 10% 20% 30% 40% 50% 60% 70%

Base size: 1,754

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 48

1.3.5—Europe Table 1.27—Demographics of reviewed
companies in Europe
The AI review of companies headquartered in
Europe included 717 companies in 23 jurisdictions. Number of companies and size range by industry
The jurisdictions with the highest number of
Total assets (US$ billion)
companies reviewed were the United Kingdom
(144 companies), Germany (78 companies), Financial Number of First Median Third
institutions companies quartile quartile
Sweden (75 companies) and Switzerland
(69 companies), as shown in Table 1.26. Banking 106 7.9 37.9 288.2

Table 1.27 provides descriptive statistics for Insurance 36 28.8 113.2 295.2
companies in eight industry groups in Europe, Revenue (US$ billion)
including an indication of companies’ sizes Non-financial Number of First Median Third
based on total assets for financial institutions companies companies quartile quartile
and total revenues for non-financial companies. Agriculture, 57 2.1 4.5 9.6
The median assets for reviewed banks and food and forest
insurance companies was US$37.9 billion and products
US$113.2 billion. The non-financial companies Consumer 77 1.4 5.2 11.8
had median revenues ranging from approximately goods
US$800 million to US$5.2 billion. Energy 81 0.8 3.8 18.4

Table 1.26—Number of reviewed companies in Materials and 275 1.2 3.6 7.7
buildings
Europe by jurisdiction
Technology and 35 0.5 0.8 2.0
media
UK 144 Denmark 25
Transportation 50 1.1 3.0 15.9
Germany 78 Türkiye 24

Sweden 75 Finland 20 As described in this report and previous

TCFD annual status reports, European companies
Switzerland 69 Ireland 17 have higher average rates of reporting on
France 50 Belgium 16 TCFD recommended disclosures than companies
in the other four regions (see Table 1.7).16
Italy 45 Austria 13 European companies, governments and
regulators have focused on climate-related
Norway 36 Greece 13
reporting issues for many years, well before the
Spain 31 Poland 11 TCFD recommendations were published, which
might explain these higher rates of reporting.
Netherlands 28 Portugal 9
Most jurisdictions in Europe have requirements that
The review also included five companies in are already in effect.
Luxembourg; three companies in Monaco; two
companies in Czechia and Jersey; and one
company in Faroe Islands.

16 See TCFD, Task Force on Climate-related Financial Disclosures: 2023 Status Report, TCFD, 2023, https://www.fsb.org/wp-content/uploads/
P121023-2.pdf; TCFD, Task Force on Climate-related Financial Disclosures: 2022 Status Report, TCFD, 2022, https://assets.bbhub.io/company/
sites/60/2022/10/2022-TCFD-Status-Report.pdf, page 16; TCFD, Task Force on Climate-related Financial Disclosures: 2021 Status Report,
TCFD, 2021, https://www.fsb.org/wp-content/uploads/P141021-1.pdf, pages 34–35; and TCFD, Task Force on Climate-related Financial
Disclosures: 2020 Status Report, TCFD, 2020, https://www.fsb.org/wp-content/uploads/P291020-1.pdf, page 14.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 49

The European Union issued requirements in late The highest rates of reporting for each of the
2014 for large companies to disclose information eight industries were on the three recommended
on environmental (including climate-related) and disclosures related to metrics and targets. More
other matters beginning in their 2017 fiscal year than 77% of the companies in all eight reviewed
reports.17 More recently, the EU issued a directive industries reported their climate-related metrics
on corporate sustainability reporting that builds on (Metrics and targets a) and more than 74%
the requirements issued in 2014. In May 2024 the reported on their GHG emissions (Metrics and
IFRS Foundation and EFRAG published guidance targets b). All reviewed insurance companies
illustrating the high degree of alignment, with a reported on climate-related targets. Reporting on
detailed analysis of the alignment in climate-related targets in other industries was also high, ranging
disclosures, between the ISSB Standards and from 71% for the technology and media companies
the European Sustainability Reporting Standards to 88% for the agriculture, food and forest
(ESRS), and offering practical guidance on how products companies.
a company can apply both sets of standards.18
The lowest rate of reporting in six of the eight
The UK and Switzerland have also issued
industries was on the resilience of the company’s
climate-related disclosure requirements. Section
strategy under different climate-related scenarios
4.3—Introduction of TCFD recommendations
(Strategy c), which is consistent with the AI review
or ISSB Standards in regulatory frameworks
results for the other regions and in the previous
by region provides an update on jurisdictional
TCFD annual status reports.
efforts and developments in Europe to support the
implementation of the TCFD recommendations or Table 1.28—Average number of disclosures per
the use of ISSB Standards. company in Europe
The AI review results for Europe are shown in
Tables 1.28–1.29. Overall, companies in all eight Industry Number of
reviewed industries disclosed information in disclosures
line with at least five of the 11 recommended Insurance 7.8
disclosures. Companies in the insurance industry
reported an average of 7.8 of the 11 recommended Energy 6.9
disclosures and companies in the banking and Banking 6.8
energy industries reported on an average of 6.8
of the 11 recommended disclosures. Reporting by Agriculture, food and forest products 6.5
companies in the transportation industry was lower, Materials and buildings 6.3
with an average of 5.1 of the 11 recommended
Consumer goods 5.9
disclosures. Reporting by companies in the
technology and media industry was similar, Technology and media 5.2
with an average of 5.2 of the 11 recommended
Transportation 5.1
disclosures. This finding is consistent with the
overall lower reporting rates for technology and
media companies.

17 See European Parliament and European Council, Non-Financial Reporting Directive, 22 October 2014, https://eur-lex.europa.eu/legal-content/
EN/TXT/PDF/?uri=CELEX:32014L0095. On 17 June 2019 the European Commission published additional guidelines that referenced the
TCFD recommendations—European Commission, Guidelines on Reporting Climate-related Information, European Commission, 2019, https://
ec.europa.eu/finance/docs/policy/190618-climate-related-information-reporting-guidelines_en.pdf.
18 See ESRS–ISSB Standards: Interoperability Guidance, the IFRS Foundation and EFRAG, 2024, https://www.ifrs.org/content/dam/ifrs/supporting-
implementation/issb-standards/esrs-issb-standards-interoperability-guidance.pdf.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 50

Table 1.29—TCFD-aligned disclosures by industry for fiscal year 2023

Percentage of companies in Europe

Recommendation Recommended disclosure

Agriculture, food and

forest products (57)

Consumer goods
Technology and
buildings (275)
Insurance (36)

Transportation
Banking (106)

Materials and
Energy (81)

media (35)
(50)

(77)
Governance a) Board oversight 75% 81% 77% 69% 66% 70% 54% 64%

b) Management’s role 62% 78% 58% 56% 40% 54% 40% 51%
Strategy a) Risks and opportunities 55% 81% 58% 55% 38% 54% 31% 40%
b) Impact of risks and
48% 67% 59% 50% 38% 60% 40% 57%
opportunities on company
c) Resilience of strategy 17% 31% 35% 22% 4% 33% 9% 19%
Risk management a) Risk identification and
66% 81% 62% 56% 46% 58% 43% 47%
assessment processes
b) Risk management
59% 64% 62% 47% 32% 54% 34% 49%
processes
c) Integration into overall risk
46% 36% 36% 27% 16% 19% 26% 18%
management
Metrics and targets a) Climate-related metrics 83% 81% 80% 80% 78% 77% 86% 78%

b) GHG emissions 86% 86% 83% 83% 74% 82% 89% 86%
c) Climate-related targets 79% 100% 80% 85% 78% 88% 71% 78%
The numbers in parentheses represent the size of the review population.

The comparison of reporting by companies in In comparison, reporting on risks and opportunities

Europe for fiscal years 2022 and 2023 shows (Strategy a), the resilience of strategy (Strategy c)
generally consistent or increasing levels of and GHG emissions (Metrics and targets b) had
disclosure for all TCFD recommended disclosures the smallest increases.
(see Figure 1.10). The largest increase—
approximately six percentage points—was for
disclosures of risk identification and assessment
processes (Risk management a), followed
by increases in reporting on board oversight
(Governance a), risk management processes
(Risk management b) and climate-related metrics
and targets (Metrics and targets a and c).

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 51

Figure 1.10—TCFD-aligned disclosures in Europe for fiscal years 2022 and 2023
Percentage of companies in Europe

Recommendations Recommended disclosure Fiscal year

Governance a) Board oversight 2022 66%

2023 70%

b) Management’s role 2022 54%

2023 56%

Strategy a) Risks and opportunities 2022 51%

2023 52%

b) Impact of risks and 2022 50%

opportunities on company
2023 52%

c) Resilience of strategy 2022 21%

2023 22%

Risk management a) Risk identification and 2022 52%

assessment processes
2023 57%

b) Risk management 2022 47%

processes
2023 50%

c) Integration into overall 2022 30%

risk management
2023 29%

Metrics and targets a) Climate-related metrics 2022 78%

2023 80%

b) GHG emissions 2022 83%

2023 84%

c) Climate-related targets 2022 80%

2023 83%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

Base size: 717

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 52

1.4—Companies referencing The IFRS Foundation collected, categorised
ISSB Standards and analysed references to the ISSB in those
reports to analyse the companies’ level of
To understand companies’ progress in preparing commitment to using ISSB Standards, using three
to use ISSB Standards, the IFRS Foundation reference categories.
reviewed publicly available reports of some listed
and private companies. The findings from this The reference categories include general reference
review provide insights into the state of corporate to the ISSB, planned alignment and stated
reporting practices and the progress being made alignment with the sustainability-related disclosure
towards the use of ISSB Standards in various requirements in ISSB Standards.19
regions and sectors. Table 1.30 provides definitions and examples for
each category.

Table 1.30—Reference categories and examples

Reference category Reference example

1 General reference—a company referenced ‘Various global regulators and standard setting
the ISSB: bodies, including the ISSB, are publishing
guidelines and standards aligned with the
• as a standard-setter in the sustainability
TCFD recommendations.’
disclosure landscape, without stating that
it had applied or intended to apply ISSB ‘We support the ISSB in its aim to develop
Standards to disclose information; consistent, comparable and reliable global
sustainability standards.’
• to describe its past, current or future
participation in activities organised by the ‘We remain vocal in our support and active in
ISSB or the IFRS Foundation; an engagement that endorses efforts toward
further harmonisation and standardisation of
• to voice its support for the global
sustainability reporting. In line with this, we
baseline, without stating it intends to align
continue participating in consultations with
its disclosures with ISSB Standards; or
the ISSB.’
• in the context of its current or planned
‘In addition, the company responds in this
alignment with the SASB Standards or
report to the indicators identified for the
the Integrated Reporting Framework, not
“Electric Utilities and Power Generators” and
ISSB Standards.
“Gas Utilities and Distributors” sectors by
the SASB Standards, which are under the
supervision of the ISSB.’
continued ...

19 The review of the references is an analysis of references companies made about their use or planned use of ISSB Standards rather than
an analysis of information provided by companies.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 53

 Reference category Reference example

2 Planned alignment—a company ‘We are in the early stages of aligning our
referenced the ISSB in the context of climate-related disclosures with the IFRS S2
its future alignment in reporting with requirements.’
the sustainability‑related disclosure
‘We are pleased to share that our 2024
requirements in ISSB Standards.
financial report will align to IFRS S1 and
IFRS S2 to disclose sustainability-related
financial information.’

3 Stated alignment—a company ‘We have started to align our reporting with the
referenced the ISSB in the context of ISSB Standards.’
its current alignment in reporting with
‘This year, the company also considered the
the sustainability‑related disclosure
new ISSB Standards in completing this report
requirements in ISSB Standards.
and included relevant indicators.’

The sample of companies analysed consisted of Table 1.31—Number of companies referencing

companies, both listed and private, available within the ISSB by region
the data providers’ platforms that referenced the
ISSB between October 2023 and March 2024. Region Number of
When a company made multiple references to companies
the ISSB during the period, the IFRS Foundation Africa 80
selected the reference demonstrating the highest
level of commitment to use ISSB Standards based Latin America and the Caribbean 115
on the reference categories to ensure the results North America 186
accurately present the current state of commitment
to using ISSB Standards. Asia-Oceania 474
Europe 296
1.4.1—ISSB reference analysis by region
Total 1,151
Table 1.31 provides a breakdown of the number
of companies that referenced the ISSB between
October 2023 and March 2024, by region. In Africa, out of the 80 companies that referenced
the ISSB, more than 50% mentioned current
Table 1.32 provides a detailed breakdown by region
or future alignment in reporting with the
of these companies, using the three reference
sustainability‑related disclosure requirements in
categories and analysing for each region the five
ISSB Standards. Among the 44 South African
jurisdictions with the highest number of companies
companies that referenced the ISSB, 43%
that referenced the ISSB.
mentioned the ISSB in the context of their future
alignment in reporting with the sustainability-related
disclosure requirements in ISSB Standards and 5%
did so in the context of their current alignment in
reporting with the sustainability-related disclosure
requirements in ISSB Standards.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 54

Among the 11 Nigerian companies that referenced Out of the 474 companies that referenced the
the ISSB, 64% did so in the context of current ISSB in Asia-Oceania, 49% mentioned the ISSB in
alignment in reporting with the sustainability- the context of their current or future alignment in
related disclosure requirements in ISSB Standards. reporting with the sustainability-related disclosure
Four companies from Kenya that referenced the requirements in ISSB Standards and 51%
ISSB between October 2023 and March 2024 provided a general reference to the ISSB. Among
recognised the ISSB as a standard-setter in the the 81 Australian companies that referenced the
sustainability disclosure landscape, but did not ISSB, 64% mentioned the ISSB in the context
specify the use or intended use of ISSB Standards of their future alignment in reporting with the
to disclose information. sustainability‑related disclosure requirements in
ISSB Standards and 6% did so in the context
Out of the 115 companies that referenced the
of their current alignment in reporting with the
ISSB in Latin America and the Caribbean,
sustainability-related disclosure requirements in
35% mentioned the ISSB in the context of their
ISSB Standards. The majority of the 39 Japanese
current or future alignment in reporting with the
companies that referenced the ISSB provided a
sustainability-related disclosure requirements
general reference.
in ISSB Standards and 65% provided a general
reference to the ISSB. Among the 38 Brazilian Out of the 296 companies that referenced the ISSB
companies that referenced the ISSB, 50% in Europe, 62% provided a general reference and
mentioned the ISSB in the context of their future 38% mentioned the ISSB in the context of their
alignment in reporting with the sustainability-related current or future alignment in reporting with the
disclosure requirements in ISSB Standards and 5% sustainability-related disclosure requirements in
did so in the context of their current alignment in ISSB Standards. Among the 119 UK companies
reporting with the sustainability-related disclosure that referenced the ISSB, 49% mentioned the
requirements in ISSB Standards. The majority ISSB in the context of their future alignment in
of the companies in Costa Rica and Chile that reporting with the sustainability-related disclosure
referenced the ISSB provided a general reference requirements in ISSB Standards and 2% did
without stating their current or future alignment in so in the context of their current alignment in
reporting with the sustainability-related disclosure reporting with the sustainability-related disclosure
requirements in ISSB Standards. requirements in ISSB Standards. The majority of
the 24 French companies that referenced the ISSB
Out of the 186 companies that referenced the
provided a general reference. Eighteen companies
ISSB in North America, 60% provided a general
in Spain provided a general reference to the ISSB.
reference and 40% mentioned the ISSB in the
context of their current or future alignment in
reporting with the sustainability-related disclosure In Africa and Asia-Oceania, approximately
requirements in ISSB Standards. Among the 107 half of the 554 companies that referenced
Canadian companies that referenced the ISSB, the ISSB mentioned their current or
more than 50% mentioned the ISSB in the context future alignment in reporting with the
of their current or future alignment in reporting with sustainability‑related disclosure requirements
the sustainability-related disclosure requirements in ISSB Standards.
in ISSB Standards. The majority of the companies
in the US that referenced the ISSB provided a
general reference.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 55

Table 1.32—Companies referencing ISSB Standards by the top five jurisdictions represented in the
review in each region (October 2023 to March 2024)

Percentage of companies that referenced the ISSB

Region Jurisdiction Number of companies General reference Planned alignment Stated alignment
Africa South Africa (44) 52% 43% 5%
(80) Nigeria (11) 18% 18% 64%
Mauritius (7) 43% 57% 0%
Kenya (4) 100% 0% 0%
Zambia (3) 33% 0% 67%
Region total average 45% 38% 17%
Latin America Brazil (38) 45% 50% 5%
and the
Chile (30) 87% 13% 0%
Caribbean
(115) Mexico (14) 64% 36% 0%
Costa Rica (8) 87% 13% 0%
Colombia (7) 57% 43% 0%
Region total average 65% 33% 2%
North America Canada (107) 48% 42% 10%
(186) United States (79) 77% 18% 5%
Region total average 60% 32% 8%
Asia-Oceania Australia (81) 30% 64% 6%
(474) China (59) 46% 30% 24%
Malaysia (54) 64% 30% 6%
Singapore (39) 48% 49% 3%
Japan (39) 85% 10% 5%
Region total average 51% 40% 9%
Europe UK (119) 49% 49% 2%
(296) France (24) 84% 8% 8%
Switzerland (21) 62% 33% 5%
Italy (20) 75% 15% 10%
Spain (18) 100% 0% 0%
Region total average 62% 35% 3%
The numbers in parentheses represent the size of the review population.
Base size: 1,151

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 56

1.4.2—ISSB reference analysis by Table 1.34 provides a detailed breakdown by sector
Sustainable Industry Classification of these companies, using the three reference
System sectors categories and analysing for each sector the five
industries with the highest number of companies
Table 1.33 provides a breakdown of the number
that referenced the ISSB. The way companies
of companies that referenced the ISSB between
referenced the ISSB varied between sectors.
October 2023 and March 2024 in 11 sectors
For example, out of the 52 companies that
defined according to the Sustainable Industry
referenced the ISSB in the services sector, 49%
Classification System® (SICS®).20
provided a general reference, 47% mentioned the
Table 1.33—Number of companies referencing ISSB in the context of their future alignment in
the ISSB by sector reporting with the sustainability-related disclosure
requirements in ISSB Standards and 4%
Sector Number of mentioned the ISSB in the context of their current
companies alignment in reporting with the sustainability-related
disclosure requirements in ISSB Standards.
Consumer goods 49
Out of the 372 companies that referenced the
Extractives and minerals processing 168 ISSB in the financials sector, 65% provided a
Financials 372 general reference, 28% mentioned the ISSB in the
context of their future alignment in reporting with
Food and beverage 69 sustainability-related disclosure requirements in
Healthcare 44 ISSB Standards and 7% mentioned the ISSB in the
context of their current alignment in reporting with
Infrastructure 181 the sustainability-related disclosure requirements in
Renewable resources and ISSB Standards.
alternative energy 18 Out of the 18 companies that referenced the ISSB
Resource transformation 91 in the renewable resources and alternative energy
sector, 78% provided a general reference and
Services 52
22% mentioned the ISSB in the context of their
Technology and communications 62 current or future alignment in reporting with the
sustainability-related disclosure requirements in
Transportation 45
ISSB Standards.
Total 1,151

The way companies referenced the ISSB

varied between sectors.

20 SASB, Sustainable Industry Classification System® (SICS®) is available at https://sasb.ifrs.org/find-your-industry. As discussed in Appendix 1—Company
selection and AI review methodology, the industries and sub-industries used for the analysis in Section 1.2—TCFD-aligned reporting by public
companies and Section 1.3—TCFD-aligned reporting by public companies by region are on the Global Industry Classification Standard®
(GICS®); the GICs sectors and sub-industries differ from those in SICS.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 57

Table 1.34—Public companies referencing ISSB Standards by the top five SICS industries in each
SICS sector (October 2023 to March 2024)

Percentage of companies that referenced the ISSB

Sector(a) Industry(a) Number of General Planned Stated
companies reference alignment alignment
Consumer goods Multiline and specialty retailers
(23) 74% 22% 4%
(49) and distributors
Building products and furnishings (8) 37% 63% 0%
Apparel, accessories and footwear (7) 86% 14% 0%
Household and personal products (7) 72% 14% 14%
Appliance manufacturing (3) 0% 100% 0%
Sector total average 65% 31% 4%
Extractives Metals and mining (58) 41% 54% 5%
and minerals Oil and gas—exploration
processing (49) 63% 33% 4%
and production
(168)
Construction materials (16) 87% 13% 0%
Oil and gas—services (14) 64% 22% 14%
Oil and gas—refining and marketing (10) 40% 60% 0%
Sector total average 56% 39% 5%
Financials Commercial banks (190) 66% 29% 5%
(372) Asset management and
(63) 68% 27% 5%
custody activities
Insurance (61) 62% 35% 3%
Investment banking and brokerage (38) 61% 21% 18%
Consumer finance (8) 75% 12% 13%
Sector total average 65% 28% 7%
Food and Processed foods (16) 44% 37% 19%
beverage Agricultural products (14) 57% 43% 0%
(69)
Meat, poultry and dairy (13) 62% 38% 0%
Food retailers and distributors (10) 40% 50% 10%
Non-alcoholic beverages (5) 80% 20% 0%
Sector total average 53% 40% 7%
continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 58

Percentage of companies that referenced the ISSB
Sector(a) Industry(a) Number of General Planned Stated
companies reference alignment alignment
Healthcare Biotechnology and pharmaceuticals (23) 70% 13% 17%
(44) Healthcare delivery (8) 62% 38% 0%
Medical equipment and supplies (8) 50% 12% 38%
Drug retailers (4) 75% 0% 25%
Managed care (1) 0% 100% 0%
Sector total average 64% 18% 18%
Infrastructure Real estate (80) 53% 41% 6%
(181) Electric utilities and
(48) 71% 21% 8%
power generators
Engineering and
(33) 79% 12% 9%
construction services
Gas utilities and distributors (6) 67% 33% 0%
Real estate services (5) 60% 40% 0%
Sector total average 63% 30% 7%
Renewable Solar technology and project
(7) 86% 14% 0%
resources and developers
alternative
Pulp and paper products (5) 80% 20% 0%
energy
(18) Fuel cells and industrial batteries (2) 0% 0% 100%
Wind technology and project
(2) 100% 0% 0%
developers
Biofuels (1) 100% 0% 0%
Sector total average 78% 11% 11%
Resource Chemicals (37) 65% 22% 13%
transformation Industrial machinery and goods (37) 40% 49% 11%
(91)
Aerospace and defence (7) 86% 14% 0%
Containers and packaging (5) 40% 40% 20%
Electrical and electronic equipment (5) 60% 0% 40%
Sector total average 55% 32% 13%
continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 59

Percentage of companies that referenced the ISSB
Sector(a) Industry(a) Number of General Planned Stated
companies reference alignment alignment
Services Professional and commercial
(24) 63% 29% 8%
(52) services
Casinos and gaming (8) 37% 63% 0%
Hotels and lodging (8) 50% 50% 0%
Media and entertainment (5) 40% 60% 0%
Advertising and marketing (4) 0% 100% 0%
Sector total average 49% 47% 4%
Technology and Telecommunication services (26) 46% 35% 19%
communications Software and IT services (21) 71% 29% 0%
(62)
Hardware (6) 100% 0% 0%
Semiconductors (5) 60% 20% 20%
Internet media and services (4) 25% 75% 0%
Sector total average 59% 31% 10%
Transportation Marine transportation (13) 62% 38% 0%
(45) Auto parts (7) 57% 29% 14%
Air freight and logistics (6) 67% 33% 0%
Airlines (6) 50% 50% 0%
Automobiles (4) 25% 75% 0%
Sector total average 55% 42% 3%
The numbers in parentheses represent the size of the review population.
Base size: 1,151

(a) Sectors and industries are defined according to the Sustainable Industry Classification System (SICS ).
® ®

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 60

1.5—Reporting by asset managers and The IFRS Foundation recognised that asset
asset owners owners sit at the top of the investment chain and
their disclosure of information on climate-related
1.5.1—Introduction information—to the extent possible given data and
method constraints—allows beneficiaries and other
The TCFD conducted annual surveys of asset
audiences to assess the asset owners’ investment
managers and asset owners to explore their
considerations and approaches to climate change.
approaches to climate-related financial reporting.
In 2024 the IFRS Foundation undertook a similar
survey not only to continue to assess asset The IFRS Foundation excluded asset
managers’ and asset owners’ perspectives with managers and asset owners from the
respect to climate-related financial reporting AI review because the types of reports
using the TCFD recommendations, but also to required for analysis were not always publicly
understand how asset managers and asset owners available. Instead, in early 2024 the IFRS
use (or plan to use) ISSB Standards. Foundation surveyed asset managers and
Table 1.35 provides background information about asset owners to gain insight into how they
the activities of asset managers and asset owners. report climate-related financial information to
their clients and beneficiaries, consistent with
Asset managers’ and asset owners’ reporting the approach previously taken by the TCFD.
is intended to satisfy the needs of clients,
beneficiaries, regulators and oversight bodies,
and often follows a format different from that of This section:
corporate financial reporting. • describes the scope of the review and the
To gain insight into how asset managers and approach used to collect information on
asset owners use the TCFD recommendations (or asset managers’ and asset owners’ reporting
ISSB Standards), the IFRS Foundation focused practices; and
on asset managers’ and asset owners’ reporting • summarises the results from the survey and
to their clients and beneficiaries. However, the highlights key findings related to the results.
IFRS Foundation also recognised that many
asset managers and asset owners report climate-
related financial information to a broader range
of stakeholders. Asset managers that are public
companies have two distinct audiences for their
climate-related financial information. The first
audience is shareholders (who need to understand
enterprise-level risks and opportunities and how
the asset manager manages those risks and
opportunities) and the second is clients (for whom
product-, investment strategy- or client-specific
disclosures are more relevant).

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Table 1.35—What is an asset manager or asset owner?

Asset manager Asset owner

An asset manager, also known as an investment An asset owner might be a public- or private-
manager, is hired by a client to invest assets on sector pension plan, an insurance or reinsurance
the client’s behalf. In this role, an asset manager company, an endowment or a foundation. An
acts as a fiduciary. An asset manager invests asset owner invests assets on its own behalf or
within the guidelines specified by its client on behalf of its beneficiaries and according to
for a given mandate set out in an investment a mandate or investment strategy set out by its
management agreement or product specification. oversight body or beneficiaries.
Importantly, the investment results, whether
Asset owners have various investment horizons
positive or negative, belong to the client.
that influence their risk tolerance and investment
Additionally, some asset managers issue debt or
strategies. Many asset owners have investment
equity and may be required to provide additional
portfolios that contain broadly diversified
reporting for capital markets.
investment strategies, asset classes and regions,
Asset managers’ reporting to clients varies and portfolios with thousands of underlying
depending on regulatory requirements, individual company and government exposures.
a client’s requirements and the types of An asset owner might hire an asset manager to
investments made. invest on its behalf. Like asset managers, some
asset owners issue debt or equity and may
be required to provide additional reporting for
capital markets.
Asset owners’ reporting requirements and
practices vary widely and differ from what is
required of companies with public debt or
equity. Some asset owners provide no public
reporting, whereas others provide extensive
public reporting.

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1.5.2—Scope and approach: survey of asset Figure 1.11—Composition of asset manager and
managers and asset owners asset owner survey respondents
Between February and April 2024 the IFRS Is your organisation implementing TCFD
Foundation surveyed asset managers and asset recommendations or ISSB Standards?
owners to understand how their climate‑related
financial reporting aligns with the TCFD 86% 14%
recommendations, how they use (or plan to use) Base size: 72
Yes (62) No (10)
ISSB Standards and the challenges they anticipate
with the implementation of ISSB Standards. The numbers in parentheses represent the number
of respondents.
The survey was distributed to more than
500 financial institutions through the IFRS Respondents that said ‘Yes’ currently report
Foundation’s investor network, resulting in 72 climate‑related information or plan to do so.
responses from asset managers, asset owners and
insurance companies.21 Figure 1.12 provides an overview of the
composition of the asset managers and asset
As shown in Figure 1.11, of these responses: owners that responded to the survey. Asset
• 62 respondents stated that they currently report managers represented 64% of the respondents
or plan to report climate-related information, with (46 respondents) and asset owners (including
these respondents representing approximately insurance companies) represented 36% of the
US$30 trillion in assets under management respondents (26 respondents).
(AUM); and
Figure 1.12—Composition of asset manager
• 10 respondents stated they currently and asset owner survey respondents
do not report or do not plan to report
climate‑related information. Organisation type

64% 36%

Asset managers (46) Base size: 72

Asset owners (26)

The numbers in parentheses represent the number
of respondents.

21 A similar survey distributed by the TCFD in 2023 to approximately 1,300 financial institutions resulted in 150 responses from asset managers and
asset owners. Although the IFRS Foundation’s 2024 survey received fewer responses, the response rate between the two surveys is comparable
(12% in 2023 and 14% in 2024).

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 63

Figure 1.13 shows the geographical distribution of The survey asked asset managers and asset
respondents that currently report or plan to report owners about how they disclose information
climate-related information. Most respondents were aligned with the TCFD recommendations
headquartered in North America (58%), followed (or ISSB Standards) and what challenges they face
by Europe (21%), Asia-Oceania (18%) and Latin in making such disclosures.
America and the Caribbean (2%). No responses
The survey also included questions relating
were received from asset managers or asset
to providing information in accordance
owners based in Africa.
with ISSB Standards and anticipated
Figure 1.13—Composition of asset manager implementation challenges.
and asset owner survey respondents Other topics covered include the types of reports in
that currently report or plan to report which asset managers and asset owners provide
climate‑related information climate-related financial information, the amount
of their AUM and information about whether they
Geographical distribution of respondents
are implementing or are planning to implement
Percentage of respondents by region
ISSB Standards.
North America 58% Figure 1.14 provides an analysis of the size of the
asset managers and asset owners that responded
Europe 21%
to the survey that currently report or plan to report
Asia-Oceania 18% climate-related information (62 respondents).
Latin America and 2% The majority of respondents to the 2024
the Caribbean IFRS Foundation survey had US$100 billion or
more in AUM.
Africa 0%
In contrast, the majority of respondents to a similar
Top five jurisdictions by number of respondents
survey carried out by the TCFD in 2023 had less
2024 survey 2023 survey than US$10 billion in AUM.
(IFRS Foundation) (TCFD)
US 26 31 On average, the respondents to the 2024
IFRS Foundation survey are larger in terms
Canada 10 11
of AUM than the respondents to the 2023
UK 8 24 TCFD survey.
Japan 6 9
Australia 2 9

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Figure 1.14—Analysis of asset manager and asset owner survey respondents

Respondent distribution by AUM (2024 survey)

Asset managers (41)

Asset owners (21)
Total (62)
52%

35% 34%
28% 27%
26% 26%
24%

10% 10%
8%
5% 5% 5% 5%

<US$1b US$1–9b US$10–99b US$100–499b >US$500b

Respondent distribution by AUM (2023 Survey)

Asset managers (106)

Asset owners (44)
Total (150)

36%
29%
27%
25% 24% 25%
22% 23% 23%

14% 15%
11%
8% 9% 9%

<US$1b US$1–9b US$10–99b US$100–499b >US$500b

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The survey asked asset managers who currently 1.5.3—Summary of reporting of
report or plan to report climate-related information climate‑related information
about the types of services they offer (see
The survey asked asset managers and asset
Figure 1.15). Of the 88% that offered more than
owners whether they currently report, plan to report
one service, 67% said they offered fiduciary
or do not plan to report climate-related information
management or other outsourced discretionary
to their clients and beneficiaries.
fund allocation; 33% offered fund of funds,
manager of managers or sub-advised products; As shown in Figure 1.17, most respondents
22% offered wealth management; and 33% offered currently report climate-related information
other types of services. to their clients or beneficiaries—78% of
asset managers and 81% of asset owners—
Figure 1.15—Services offered by asset and most of the remainder plan to report
manager respondents climate‑related information.

Offering more than one service (36) 88% Figure 1.17—Reporting of climate-related
information to clients and beneficiaries
Fiduciary management 67%
Status of reporting
Fund of funds 33%
Percentage of those that currently report
Wealth management 22%
Other 33% All respondents (72) 79%

Execution and advisory only (5) 12% Asset managers 78%

Asset owners 81%
Figure 1.16 provides information about what type of
asset owners responded to the survey.
Respondents that said they do not plan to report
Figure 1.16—Types of asset owner respondents climate-related information to their clients or
beneficiaries—11% of asset managers (5) and 19%
Non-corporate pension 48% of asset owners (5)—were not asked to answer
questions about their reporting on information
Insurance company 24% aligned with the TCFD recommended disclosures
Corporate pension 14% (or ISSB Standards).

Sovereign wealth fund 5%

Family office or other 10%

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Figure 1.18 shows the reasons asset managers Figure 1.19 shows two common reporting channels
and asset owners report or plan to report climate- asset managers and asset owners use to report
related information to their clients and beneficiaries. climate-related information to their clients and
The most cited reasons by asset managers for beneficiaries—reports that are publicly available
reporting were ‘Requests from clients (including in and reports that are made available to clients or
investment mandates)’ and ‘Required by regulators’ beneficiaries only.
followed by ‘Climate-related financial information
Figure 1.19—Reporting of climate-related
is material’. Asset owners cited ‘Climate‑related
information to clients and beneficiaries
financial information is material’ and ‘Senior
management priority’ as the main reasons they Channels for reporting to clients and
report or plan to report climate-related information. beneficiaries(a)
Figure 1.18—Reporting of climate-related
Percentage of those using publicly available reports to
information to clients and beneficiaries
communicate climate-related financial information to
Reasons for reporting(a) clients and beneficiaries
(respondents could select more than one reason)
All respondents (57) 95%

Climate-related financial 78% Asset managers 92%

information is material
86% Asset owners 100%
Peers report information 56% (a) O
 nly respondents that said they currently report climate-related
information to their clients and beneficiaries were asked this question.
62%
Requests from clients The vast majority of asset managers (92%) said
83% they use publicly available reports to communicate
62% climate-related financial information to their
Required by regulators stakeholders with the remainder (8%) saying that
83% they only use reports that are made available
48% to clients or beneficiaries only to communicate
Senior management climate-related financial information. All asset
61% owners (100%) who responded to the survey said
priority
86% they communicate climate-related information to
their stakeholders via publicly available reports.
(a) O
 nly respondents that said they currently report climate-related
information to their clients and beneficiaries were asked this question.

Asset managers Asset owners

The IFRS Foundation found that of asset managers

and asset owners that said one of the reasons for
reporting is because of regulatory requirements,
48% were in North America, 32% in Europe and
the remaining 20% in Asia-Oceania.

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1.5.4—Reporting of climate-related Those that report on the recommended disclosures
information by asset managers most commonly report on management’s role
(Governance b), at 86%. The next highest rates of
Almost 78% of the asset manager respondents
reporting were on board oversight (Governance a)
said they currently report information in line
at 83% and on risks and opportunities (Strategy a)
with the TCFD recommendations and, of those,
at 80%. The lowest rate of reporting—at 42%—was
37% said they currently report on all 11 TCFD
on the resilience of the company’s strategy under
recommended disclosures.
different climate-related scenarios (Strategy c), with
Table 1.36 shows the percentages of asset 34% of asset managers saying they plan to report
manager respondents that currently report, plan on this recommended disclosure.
to report, or are undecided about reporting to their
clients on the TCFD recommended disclosures.

Table 1.36—Asset managers: rates of reporting on recommended disclosures

Recommendation Recommended disclosures Percentage for each reporting option

Currently Plan to Undecided /
report report other
Governance a) Board oversight 83% 12% 5%

b) Management’s role 86% 12% 2%

Strategy a) Risks and opportunities 80% 15% 5%

b) Impact of risks and opportunities on company 68% 22% 10%

c) Resilience of strategy 42% 34% 24%

Risk management a) Risk identification and assessment processes 76% 17% 7%

b) Risk management processes 78% 15% 7%

c) Integration into overall risk management 76% 20% 4%

Metrics and targets a) Climate-related metrics 76% 20% 4%

b) GHG emissions 71% 20% 9%

c) Climate-related targets 49% 22% 29%
Base size: 41

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The survey also asked respondents about seven or investment strategy (54%). The least-reported
specific climate-related metrics and targets, as metrics were the extent to which AUM align with a
shown in Figure 1.20. The IFRS Foundation was well-below 2°C scenario (39%) and other climate-
interested in the level of reporting on some metrics related targets (32%).
included in the TCFD supplemental guidance,
including GHG emissions associated with AUM
Compared with the 2023 TCFD survey, asset
and the weighted average carbon intensity for each
manager respondents in 2024 had much
product or investment strategy.22
higher rates of reporting on all metrics and
Figure 1.20 shows the percentage of asset targets. It is noted that these rates might
managers that currently report on each of the reflect the size of respondents compared
seven metrics to their clients. More than half of with the respondents in the previous year.
the asset managers (61%) said they report on the Overall, the respondents to the 2024
GHG emissions associated with their AUM and on IFRS Foundation survey are larger in
targets related to GHG emissions. These metrics terms of AUM than the respondents to the
are followed by other climate metrics (59%) and 2023 TCFD survey.
weighted average carbon intensity for each product

Figure 1.20—Asset managers that currently report on specific metrics and targets

Metrics and targets Percentage responding

(a) Alignment with <2°C scenario: AUM(a) 46%

Alignment with <2°C scenario: products and strategies 39%
Other climate-related metrics 59%

(b) GHG emissions of AUM 61%

Weighted average carbon intensity: products 54%
and investment strategies

(c) Targets related to GHG emissions 61%

Other climate-related targets 32%

Base size: 41

(a) A
 s discussed in Section 2.2—Reconciliation between TCFD recommendations and requirements in ISSB Standards, IFRS S2 is broadly
consistent with TCFD recommended disclosure c) about describing the resilience of a company’s strategy. However, IFRS S2 does not specify
particular scenarios for a company to use in its climate-related scenario analysis and therefore does not require a company to use a below
2°C scenario.

22 TCFD, Implementing the Recommendations of the Task Force on Climate-related Financial Disclosures, TCFD, 2021, https://assets.bbhub.io/
company/sites/60/2021/07/2021-TCFD-Implementing_Guidance.pdf, pages 48–49.

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Along with asking asset managers about the types stakeholder scrutiny as a challenge, particularly
of climate-related information they report to their in reporting on metrics and targets. Insufficient
clients, the survey asked asset managers about information from companies was less of a
the challenges they face in reporting information on challenge for those surveyed this year compared
the TCFD core content recommendations. with respondents in prior years. The survey asked
respondents whether the issue of insufficient
Table 1.37 lists the challenges reported by asset
information related to public companies, private
managers. A lack of resources and concerns about
investments, other sources or some combination
negative regulatory or other stakeholder scrutiny
of the three options (respondents could select
were the two most frequently cited challenges.
more than one option). Of asset managers that
Almost 40% of asset manager respondents cited insufficient information as a challenge, 78%
said a lack of resources is a challenge for their said the issue related to private investments, 68%
reporting in general and especially for reporting said to public companies and 63% said to other
on strategy and metrics and targets. Overall, 29% sources.
cited concern about negative regulatory or other

Table 1.37—Asset managers: challenges reporting climate-related information

Risk Metrics and

Challenge Governance Strategy Overall
management targets

Lack of resources 5% 29% 15% 24% 39%

Concern about negative scrutiny 15% 17% 12% 22% 29%

Insufficient information
7% 15% 20% 27% 27%
from companies

Lack of expertise or capabilities 0% 12% 5% 7% 15%

Lack of methodologies 0% 5% 5% 7% 15%

Lack of board or senior

management support 5% 5% 0% 7% 12%

Base size: 41

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The IFRS Foundation also reviewed asset These results are generally consistent with
managers’ reporting on information based on their those for the AI review of public companies,
size using AUM. Table 1.38 shows the percentage which showed that a higher percentage of larger
of asset managers in each AUM size category that companies than smaller companies disclosed
currently report on the recommended disclosures. climate-related information.

Table 1.38—Asset managers: currently report climate-related information by AUM

Recommendation Recommended disclosure <US$1b US$1–9b US$10–99b >US$100b

(4) (2) (10) (25)

Governance a) Board oversight 50% 100% 90% 84%

b) Management’s role 75% 50% 90% 88%
Strategy a) Risks and opportunities 75% 50% 80% 84%
b) Impact of risks and opportunities on company 75% 50% 70% 68%
c) Resilience of strategy 50% 0% 40% 44%
Risk management a) Risk identification and assessment processes 50% 100% 70% 80%
b) Risk management processes 75% 100% 70% 80%
c) Integration into overall risk management 75% 50% 60% 84%
Metrics and targets a) Climate-related metrics 50% 100% 60% 84%
b) GHG emissions 50% 100% 60% 76%
c) Climate-related targets 50% 0% 50% 52%
The numbers in parentheses represent the number of respondents.
Base size: 41

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Table 1.39 provides a breakdown of the types of the types of reports in which asset managers
reports in which asset managers currently report stated they would report climate-related information
climate-related information to their clients. Most to their clients if they had done so.
asset managers currently report in sustainability
More than 65% of asset managers currently report
reports (75%) or reports available to only their
through climate-specific reports and 22% are
clients (at 73%).
planning to report to clients in this way, with 20%
For asset managers that do not currently provide saying they report to clients through financial filings
climate-related information to their clients (that is, and 10% that they plan to report this way.
plan to report, do not plan to report or are
undecided), Table 1.39 provides information about

Table 1.39—Asset managers: location of climate-related reporting

(Respondents could select more than one report type)

Reporting status

Report type Currently Plan to Do not plan Undecided

report report to report
Sustainability report 75% 12% 5% 5%
Client report 73% 15% 2% 7%
Climate-specific report 68% 22% 5% 5%
Annual report 27% 7% 27% 15%
Financial filing 20% 10% 27% 20%
Other 12% 2% 0% 2%
Base size: 41

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1.5.5—Reporting of climate-related Those who report on the recommended disclosures
information by asset owners most commonly reported on governance,
specifically board oversight and management’s role
Almost 77% of asset owner respondents
(both 95%) and on impact of climate-related risks
currently report information in line with the TCFD
and opportunities on the company (Strategy b)
recommendations (or ISSB Standards) and 38%
and risk identification and assessment processes
report on all 11 TCFD recommended disclosures.
(Risk management a, both 95%). The lowest level
Table 1.40 shows the percentages of asset owner of reporting—at 57%—was on the resilience of the
respondents that currently report, plan to report, or company’s strategy under different climate-related
are undecided about reporting to their beneficiaries scenarios (Strategy c), with 19% of asset owners
on the recommended disclosures. saying they plan to report on this disclosure.

Table 1.40—Asset owners: rates of reporting on recommended disclosures

Recommendation Recommended disclosure Percentage for each reporting option

Currently Plan to Undecided
report report
Governance a) Board oversight 95% 0% 5%

b) Management’s role 95% 0% 5%

Strategy a) Risks and opportunities 90% 5% 5%

b) Impact of risks and opportunities on company 95% 0% 5%

c) Resilience of strategy 57% 19% 24%

Risk management a) Risk identification and assessment processes 95% 0% 5%

b) Risk management processes 90% 5% 5%

c) Integration into overall risk management 85% 5% 10%

Metrics and targets a) Climate-related metrics 80% 10% 10%

b) GHG emissions 90% 5% 5%

c) Climate-related targets 71% 10% 19%
Base size: 21

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The survey also asked respondents about seven Figure 1.21 shows the percentage of asset owners
specific climate-related metrics and targets that currently report on these seven metrics to their
included in the TCFD supplemental guidance, beneficiaries. More than two thirds of asset owners
as shown in Figure 1.21. The IFRS Foundation report on GHG emissions (71%) and targets
was interested in the rate of reporting on these related to GHG emissions (76%). These metrics
particular metrics, including GHG emissions and were the most frequently reported on, followed by
the weighted average carbon intensity for each other climate-related metrics (67%) and climate-
product or investment strategy.23 related targets (43%). The least-reported metric—
at 14%—was the extent to which products and
strategies align with a well-below 2°C scenario.

Figure 1.21—Asset owners that currently report on specific metrics and targets

Metrics and targets Percentage responding

(a) Alignment with <2°C scenario: AUM(a) 29%

Alignment with <2°C scenario: products and strategies 14%
Other climate-related metrics 67%

(b) GHG emissions of AUM 71%

Weighted average carbon intensity: products 38%
and investment strategies

(c) Targets related to GHG emissions 76%

Other climate-related targets 43%

Base size: 21

(a) A
 s discussed in Section 2.2—Reconciliation between TCFD recommendations and requirements in ISSB Standards, IFRS S2 is broadly
consistent with TCFD recommended disclosure c) about describing the resilience of a company’s strategy. However, IFRS S2 does not specify
particular scenarios for a company to use in its climate-related scenario analysis and therefore does not require a company to use a below
2°C scenario.

23 TCFD, Implementing the Recommendations of the Task Force on Climate-related Financial Disclosures, TCFD, 2021, https://assets.bbhub.io/
company/sites/60/2021/07/2021-TCFD-Implementing_Guidance.pdf, pages 41–42.

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Along with asking asset owners about the types information related to public companies, private
of climate-related information they report to their investments, other sources or some combination
beneficiaries, the survey asked asset owners about of the three options (respondents could select
the challenges they face in reporting information on more than one option). Of asset owners that cited
the TCFD core content recommendations. insufficient information from investee companies
as a challenge, most said the issue related to
Table 1.41 lists the challenges identified by asset
private investments (76%) and approximately half
owners. Consistent with the 2023 TCFD survey,
said the issue related to public companies or other
insufficient information from investee companies
sources (52%).
was the most frequently cited challenge.
A further 24% cited jurisdictional requirements
Almost 30% of asset owner respondents said
as a challenge. Those who cited jurisdictional
insufficient information from investee companies
requirements as a challenge highlighted the
is a challenge for their reporting in general and
inconsistency of standards, the varying pace
especially for reporting on metrics and targets.
of adoption of some standards by national
Anticipating that insufficient information would
regulators, the varying levels of clarity and detail
be identified as a significant challenge again this
in regulations, integration challenges with local
year, the IFRS Foundation’s 2024 survey asked
regulations and inconsistent methods.
respondents whether the issue of insufficient

Table 1.41—Asset owners: challenges reporting climate-related information

Challenge Governance Strategy Risk Metrics and Overall

management targets
Insufficient information from
0% 10% 10% 29% 29%
investee companies

Jurisdictional requirements 14% 19% 14% 24% 24%

Lack of resources 0% 10% 14% 19% 19%

Concern about negative scrutiny 10% 14% 10% 14% 19%

Lack of methodologies 0% 5% 5% 5% 5%

Lack of expertise or capabilities 0% 5% 5% 5% 5%

Lack of board or senior

management support 0% 0% 0% 0% 0%

Base size: 21

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Table 1.42 provides a breakdown of the types of For asset owners that do not currently report
reports in which asset owners currently report climate-related information to their beneficiaries
climate-related information to their beneficiaries. (that is, plan to report, do not plan to report or are
Most asset owners currently report in sustainability undecided), Table 1.42 provides information about
reports (67%), climate-specific reports (57%) the types of reports in which asset owners stated
or annual reports (57%). Reporting of climate- they would report climate-related information to
related information in financial filings or in direct their beneficiaries if they had done so.
client reports is used by 10% of asset owners who
responded to the survey.

Table 1.42—Asset owners: location of climate-related reporting

(Respondents could select more than one report type)

Reporting status
Report type Currently Plan to Do not plan Undecided
report report to report

Financial filing 10% 10% 24% 14%

Annual report 57% 10% 10% 10%

Sustainability report 67% 0% 10% 10%

Climate-specific report 57% 5% 14% 14%

Client report 10% 0% 24% 24%

Other 14% 5% 5% 5%
Base size: 21

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1.5.6—ISSB-specific questions emphasises that interoperability is vital for
maintaining consistency between reporting regimes
As mentioned previously, the IFRS Foundation
and reducing the compliance burden on companies
also included questions in the survey to better
(see Section 4.4—Interoperability of ISSB
understand asset managers’ and asset owners’
Standards with other standards and initiatives).
reporting practices in relation to ISSB Standards.
The IFRS Foundation’s findings are shown in Furthermore, some respondents said it would be
Figure 1.22. helpful for jurisdictions that require companies to
comply with particular standards to permit the use
of ISSB Standards to reduce the reporting burden
Of those asset managers and asset owners
on companies.
that responded to the optional questions
about ISSB Standards, 84% of asset Figure 1.22—Asset manager and asset
managers and 100% of asset owners want owner respondents’ comments about the
or expect portfolio companies to make the transition from TCFD recommendations to
transition from disclosures prepared using ISSB Standards
the TCFD recommendations to disclosures
Percentage wanting or expecting portfolio
prepared using ISSB Standards.
companies to make the transition from disclosures
prepared using the TCFD recommendations to
These respondents cited the integration of the disclosures prepared using ISSB Standards
TCFD recommendations into ISSB Standards,
89% 11%
the comparability of information provided through
use of ISSB Standards and jurisdictional adoption Yes (49) No (6) Base size: 55
of ISSB Standards as primary reasons for
The numbers in parentheses represent the number
their expectations.
of respondents that answered optional questions
The most common factors respondents gave pertaining to ISSB Standards and the TCFD
that could accelerate the adoption of ISSB recommendations.
Standards were:
• regulatory factors and action; Percentage wanting or expecting portfolio
companies to make the transition from disclosures
• more guidance on implementation; and prepared using the TCFD recommendations to
• examples of reporting in accordance with ISSB disclosures prepared using ISSB Standards by
Standards in practice. organisation type

Respondents also emphasised the critical

importance of interoperability between ISSB All respondents (55) 89%
Standards and other established standards and
Asset managers 84%
frameworks to streamline and enhance the quality
of sustainability reporting. Many respondents Asset owners 100%
expressed strong support for the information
required by ISSB Standards to be consistent with
that required by other standards that already have
widespread use, such as ESRS. This response

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SECTION 2—FROM TCFD
RECOMMENDATIONS TO The transition from disclosures prepared
using the TCFD recommendations to
ISSB STANDARDS disclosures prepared using ISSB Standards
is made more straightforward by the decision
2.1—Introduction to use the TCFD recommendations as a
The TCFD recommendations and overall basis for the requirements in IFRS S2. This
framework for climate-related financial disclosure decision also enables companies using ISSB
were well received by both the private sector Standards to provide the information covered
and the public sector. These recommendations by the TCFD recommendations.
served as the foundation for several jurisdictional
and international climate-related disclosure
The comparison document also describes areas in
requirements and standards.
which IFRS S2 extends beyond the TCFD’s initial
The requirements in IFRS S2 Climate-related disclosures, including requiring the provision of
Disclosures are aligned with the industry-specific metrics, such as those pertinent to
TCFD recommendations. IFRS S2 is accompanied asset managers.
by the Industry-based Guidance on Implementing
The TCFD set the groundwork for
IFRS S2 (Industry-based Guidance), which was
climate‑related financial disclosures through
derived from the industry-based requirements
its four core recommendations encompassing
in the SASB Standards, to enable a company to
governance, strategy, risk management,
identify risks and opportunities and to provide
and metrics and targets, complemented by
decision-useful information for investors in
11 supporting recommended disclosures.
accordance with the requirements in IFRS S2 to
These recommendations guide companies
provide industry-based information.
worldwide in disclosing information about
The alignment between the TCFD climate‑related risks and opportunities that affect
recommendations and ISSB Standards marked a their prospects.
pivotal moment in corporate sustainability reporting.
IFRS S2 not only integrates and builds on these
IFRS S1 General Requirements for Disclosure
foundation elements but also introduces new
of Sustainability-related Financial Information
dimensions to reporting on climate-related financial
and IFRS S2 are both structured based on the
information. It requires disclosure of industry-based
four pillars in the TCFD recommendations of
metrics, ensuring relevant information is provided
governance, strategy, risk management, and
about sustainability-related risks and opportunities
metrics and targets, with IFRS S2 specifically
given a company’s activities. Moreover, IFRS S2
setting out disclosure requirements about
requires disclosures about companies’ climate-
climate-related risks and opportunities. The
related targets, including information about the
IFRS Foundation’s Comparison—IFRS S2
planned use of carbon credits to achieve any
Climate-related Disclosures with the TCFD
net emissions target. Additionally, it expands the
Recommendations underscores this alignment,
transparency around financed emissions, a critical
highlighting the comprehensive coverage of
aspect for financial institutions in understanding the
climate-related disclosures that companies using
climate-related transition risks and opportunities
ISSB Standards will achieve, building on and
related to their lending and investment activities.
including the disclosures set out in the TCFD
recommendations, as described in Section 2.2—
Reconciliation between TCFD recommendations
and requirements in ISSB Standards.
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Integrating the TCFD recommendations in In developing other climate‑related disclosure
ISSB Standards is an important evolution in requirements, notably ESRS and the US Securities
climate-related financial reporting. ISSB Standards and Exchange Commission (US SEC) climate rule,
are designed to meet the needs of investors, other organisations have also built on the TCFD
although other parties, such as regulatory bodies, recommendations. This common basis assists in
are expected to find information in the resulting achieving interoperability for companies that need
sustainability-related financial disclosures useful. or want to use those requirements in addition to
By ensuring that companies using ISSB Standards using ISSB Standards.
also provide the information covered by the
The ISSB Taxonomy enables companies to
TCFD recommendations, the ISSB has built on
consistently tag information prepared using
pre-existing practice, facilitating the transition
ISSB Standards and can be used with other digital
from disclosures prepared using the TCFD
taxonomies. It supports the dialogue between
recommendations to disclosures prepared using
companies and investors, enabling investors to
ISSB Standards. This transition requires a strategic
digitally process sustainability-related financial
approach as discussed in Section 2.3—Transition
disclosures as discussed in Section 2.4—The role
from TCFD recommendations to ISSB Standards.
of digital taxonomies and digital reporting for
climate-related data.

2.1.1—Key takeaways
Table 2.1 summarises the key takeaways of Section 2.

Table 2.1—Key takeaways

The requirements in IFRS S2 integrate and are consistent with the TCFD recommendations.
Companies using ISSB Standards provide the information covered by the
TCFD recommendations.24

Areas in which IFRS S2 differs from the TCFD recommendations reflect differences
between IFRS S2 and the TCFD’s guidance, not the TCFD’s core recommendations or
recommended disclosures.

Making the transition from disclosures prepared using the TCFD recommendations to
disclosures prepared using ISSB Standards requires a step-by-step approach, starting
from understanding the ISSB Standards.

Digital taxonomies enable digital reporting of climate-related information, which in turn

reduces the costs of searching through documents, enables automated data collection,
leads to more efficient information processing and facilitates the consumption of
information by investors for their investment decisions.

24 It is not necessary to apply the TCFD recommendations in addition to ISSB Standards to obtain information in line with the TCFD
recommendations. However, some companies may still be required to use the TCFD recommendations because of jurisdictional requirements.

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2.2—Reconciliation between TCFD
recommendations and requirements The requirements in IFRS S2 integrate,
and are consistent with, the TCFD’s four
in ISSB Standards
core recommendations and 11 supporting
IFRS S2 builds upon the TCFD recommendations recommended disclosures. Areas in
by introducing more specific requirements and which IFRS S2 differs from the TCFD
guidance to facilitate the enforceability of IFRS S2 recommendations reflect differences
and to support comparability in climate-related between IFRS S2 and the TCFD’s guidance,
financial information. The main difference between not the TCFD’s core recommendations or
IFRS S2 and the TCFD recommendations is recommended disclosures.
that IFRS S2 contains additional requirements
and guidance, to explain the information that a
company is required to disclose. Tables 2.2–2.6 summarise similarities and
In addition, to support its global application, differences between IFRS S2 and the TCFD’s core
IFRS S2 provides additional guidance to recommendations, recommended disclosures and
ensure that the requirements are proportionate guidance. For aspects that differ, differences take
and scalable to meet companies’ varying three forms. Specifically, IFRS S2:
circumstances. For example, IFRS S2 requires a • uses different wording to capture the same
company to provide disclosures about its resilience information as the TCFD recommendations.
and that these disclosures be informed by scenario In these instances, the requirements in
analysis using an approach to resilience analysis IFRS S2 are broadly consistent with the TCFD
that is based on the company’s skills, capabilities recommendations.
and resources.
• requires the provision of information that is in
Building on the core content of the TCFD line with the TCFD recommendations, but that is
recommendations, IFRS S1 extends to cover more detailed.
the provision of material information on all
sustainability-related risks and opportunities • differs from the TCFD guidance—but not from
reasonably expected to affect a company’s cash the TCFD’s overall recommendations—mainly
flows, its access to finance or cost of capital by providing some additional requirements
over the short, medium or long term. IFRS S1 and guidance.
also sets out how disclosures about those risks
and opportunities relate to a company’s financial
statements, including that the sustainability-related
financial disclosures be included as part of the
general purpose financial reports.

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Table 2.2—Overall comparison of IFRS S2 and TCFD recommendations

TCFD’s four core

IFRS S2 summary comparison
recommendations

1—Governance • Broadly consistent.

• Requires a company to consider and refer to its Industry-based

Guidance.

2—Strategy • Requires disclosure of additional information regarding resilience.

• Does not specify which climate-related scenarios to use.
• Provides additional application guidance and reliefs.

• Requires additional disclosures on the processes a company uses to

3—Risk management
identify, assess, prioritise and monitor opportunities.

• Requires disclosure of industry-based metrics.

• Requires disclosure of information about Scope 1 and Scope 2
GHG emissions only if it is material.
4—Metrics and targets
• Requires additional disclosures related to a company’s
GHG emissions and planned use of carbon credits.
• Provides additional application guidance and reliefs.

In Tables 2.3–2.6, formatted text is used in the right-hand column of the table to illustrate differences
between IFRS S2 and the TCFD recommendations:
• black bold text indicates a requirement in IFRS S2 that is in line with the TCFD
recommendations but is more detailed; and
• black bold text highlighted in grey indicates a requirement in IFRS S2 that is not in the TCFD
recommendations.

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Table 2.3—Detailed comparison of IFRS S2 and TCFD recommendations on governance

TCFD recommendations, recommended IFRS S2

disclosures and guidance

1—Governance

Disclose the company’s governance around Disclose information that enables users of general purpose
climate-related risks and opportunities. financial reports to understand the governance processes, controls and
procedures used to monitor, manage and oversee climate-related risks
and opportunities.

1 Recommended disclosure a) IFRS S2 is broadly consistent with recommended disclosure a).

Board oversight IFRS S2 requires the disclosure of more detailed information—
Describe the board’s oversight of for example, how a governance body’s or individual’s responsibilities
climate-related risks and opportunities. for climate-related risks and opportunities are reflected in terms of
reference, mandates, role descriptions and other related policies
applicable to that body or individual.

2 Recommended disclosure b) IFRS S2 is broadly consistent with recommended disclosure b).

Management’s role
Describe management’s role
in assessing and managing
climate‑related risks and opportunities.

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Table 2.4—Detailed comparison of IFRS S2 and TCFD recommendations on strategy

TCFD recommendations, recommended IFRS S2

disclosures and guidance

2—Strategy

Disclose the actual and potential impacts of Disclose information that enables users of general purpose
climate-related risks and opportunities on the financial reports to understand a company’s strategy for managing
company’s businesses, strategy and financial climate‑related risks and opportunities.
planning where such information is material.

3 Recommended disclosure a) IFRS S2 is broadly consistent with recommended disclosure a).

Risks and opportunities IFRS S2 also requires a company to refer to and consider the applicability
Describe the climate-related risks of industry-based disclosure topics in its industry‑based guidance
and opportunities the company has in identifying climate-related risks and opportunities.
identified over the short, medium and IFRS S2 also requires disclosure of more detailed information about
long term. where in the company’s business model and value chain risks and
opportunities are concentrated

4 Recommended disclosure b) IFRS S2 is broadly consistent with recommended disclosure b).

Impact of risks and opportunities IFRS S2 requires disclosure of more detailed information describing
on company the effects of climate-related risks and opportunities. For example, how
Describe the impact of climate- a company has responded to, and plans to respond to, the identified
related risks and opportunities on the risks and opportunities, any transition plans it has and how it plans to
company’s businesses, strategy and achieve its climate-related targets.
financial planning. In the requirements related to the current and anticipated effects
of climate-related risks and opportunities on a company’s financial
position, financial performance and cash flows, IFRS S2 sets out
criteria for circumstances in which quantitative and qualitative
information is required. Companies are permitted to disclose only
qualitative information in some circumstances—for example, if a
company cannot separately identify the effects of the risk or
opportunity or if the level of measurement uncertainty involved is
too high.
IFRS S2 requires a company preparing disclosures on the anticipated
financial effects of climate-related risks and opportunities to use all
reasonable and supportable information that is available at the
reporting date without undue cost or effort. IFRS S2 also provides
that a company use an approach that is commensurate with
the company’s circumstances in preparing disclosures about the
anticipated financial effects of a climate-related risk or opportunity.

continued ...

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TCFD recommendations, recommended IFRS S2
disclosures and guidance

5 Recommended disclosure c) IFRS S2 is broadly consistent with recommended disclosure c).

Resilience of strategy However, IFRS S2 does not specify particular scenarios for a
company to use in its climate-related scenario analysis.(a)
Describe the resilience of the
company’s strategy, taking into IFRS S2 requires a company to provide additional information
consideration different climate- regarding its resilience on:
related scenarios, including a 2°C or • significant areas of uncertainty the company has considered in its
lower scenario. assessment;
• the company’s capacity to adjust and adapt its strategy and business
model over time; and
• how and when the company has carried out its climate-related
scenario analysis.
IFRS S2 provides that a company carrying out climate-related scenario
analysis use an approach that is commensurate with the company’s
circumstances and consider all reasonable and supportable
information that is available at the reporting date without undue
cost or effort.

(a) IFRS S2 does not specify particular scenarios for a company to use in its climate-related scenario analysis because the relevant scenarios
would depend on the company’s facts and circumstances, including the nature and location of its operations and the physical and transition
risks to which it is exposed. IFRS S2 requires a company to select scenarios that are relevant to its circumstances in order to provide useful
information to users of general purpose financial reports and to explain which climate-related scenarios it has used, including whether they
are related to transition or physical risks and whether the company used, among its scenarios, a climate-related scenario aligned with the
latest international agreement on climate change.

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Table 2.5—Detailed comparison of IFRS S2 and TCFD recommendations on risk management

TCFD recommendations, recommended IFRS S2

disclosures and guidance

3—Risk management

Disclose how the company identifies, Disclose information that enables users of general purpose financial
assesses and manages climate-related risks. reports to understand the processes a company has used to identify,
assess, prioritise and monitor climate-related risks and opportunities,
including whether and how those processes are integrated into and
inform the company’s overall risk management process.

6 Recommended disclosure a) IFRS S2 is broadly consistent with recommended disclosure a).

Risk identification and IFRS S2 requires disclosure of more detailed information—
assessment processes for example:
Describe the company’s processes • what input parameters a company uses to identify risks (such as
for identifying and assessing data sources, the scope of operations covered and the detail used in
climate‑related risks. assumptions);
• whether and how the company uses climate-related scenario
analysis to inform its identification of risks; and
• whether the company has changed the processes used to identify,
assess, prioritise and monitor risks compared with the prior
reporting period.
IFRS S2 also requires additional disclosures on the processes a
company uses to identify, assess, prioritise and monitor opportunities.

7 Recommended disclosure b) IFRS S2 is broadly consistent with recommended disclosure b). The risk
Risk management processes management disclosure requirements in IFRS S2 focus on a company
providing information about the processes it uses to identify, assess,
Describe the company’s processes for prioritise and monitor climate-related risks and opportunities.(a)
managing climate-related risks.

8 Recommended disclosure c) IFRS S2 is broadly consistent with recommended disclosure c).

Integration into overall risk IFRS S2 requires additional disclosures on the extent to which, and
management how, the processes a company uses to identify, assess, prioritise and
Describe how processes for monitor opportunities are integrated into and inform the company’s
identifying, assessing and managing overall risk management process.
climate‑related risks are integrated
into the company’s overall risk
management.

(a) Information that enables users of general purpose financial reports to understand a company’s strategy for managing risks and opportunities
is required by the strategy disclosure requirements of IFRS S2.

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Table 2.6—Detailed comparison of IFRS S2 and TCFD recommendations on metrics and targets

TCFD recommendations, recommended IFRS S2

disclosures and guidance

4—Metrics and targets

Disclose the metrics and targets Disclose information that enables users of general purpose financial reports
used to assess and manage relevant to understand a company’s performance in relation to its climate-related
climate‑related risks and opportunities risks and opportunities, including progress towards any climate-related
where such information is material. targets it has set, and any targets it is required to meet by law or regulation.

9 Recommended disclosure a) IFRS S2 requires the same categories of cross-industry metrics as the
Climate-related metrics TCFD guidance.
Disclose the metrics used by IFRS S2 also requires disclosure of industry-based metrics relevant to a
the company to assess climate- company’s business model and activities.
related risks and opportunities The Industry-based Guidance on Implementing IFRS S2 is required to be
in line with its strategy and risk considered in providing this information.
management process.

10 Recommended disclosure b) IFRS S2 is broadly consistent with recommended disclosure b). However,
GHG emissions whereas the TCFD recommendations include the disclosure of Scope 1
and Scope 2 GHG emissions ‘independent of materiality’, and Scope 3
Disclose Scope 1, Scope 2 and, if GHG emissions ‘as appropriate’, ISSB Standards require a company to
appropriate, Scope 3 greenhouse disclose information only if it is material.(a)
gas (GHG) emissions, and the
IFRS S2 requires additional disclosures related to a company’s GHG
related risks.
emissions, including:
• separate disclosure of Scope 1 and Scope 2 GHG emissions for (1)
the consolidated accounting group and (2) associates, joint ventures,
unconsolidated subsidiaries or affiliates not included in the consolidated
accounting group;
• disclosure of Scope 2 GHG emissions using a location-based approach
and providing information about any contractual instruments that is
necessary to inform users’ understanding;
• disclosure of Scope 3 GHG emissions, including additional information
about the company’s financed emissions if the company has activities
in asset management, commercial banking or insurance; and
• information about the measurement approach, inputs and assumptions
the company has used in measuring Scope 3 GHG emissions.
IFRS S2 also sets out a Scope 3 measurement framework to provide
guidance for preparing Scope 3 GHG emissions disclosures.
IFRS S2 does not require a company to disaggregate its GHG emissions
disclosures by the constituent gases. However, IFRS S1 includes
requirements on disaggregation that would result in the disclosure of
the constituent gases being required if such disaggregation provides
material information.

(a) T
 he TCFD provided guidance to support companies in developing climate-related financial disclosures consistent with the recommendations
and recommended disclosures it published in 2017. In 2021 the TCFD updated its guidance Implementing the Recommendations of the Task
Force on Climate-related Financial Disclosures to encourage companies to disclose information about Scope 1 and Scope 2 GHG emissions
independent of an assessment of materiality.

continued ...
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TCFD recommendations, recommended IFRS S2
disclosures and guidance

11 Recommended disclosure c) IFRS S2 is broadly consistent with recommended disclosure c).

Climate-related targets IFRS S2 differs from the TCFD guidance in, for example, requiring
Describe the targets used by the disclosures about how the latest international agreement on climate
company to manage climate‑related change has informed the target and whether the target has been validated
risks and opportunities and by a third party.
performance against targets. IFRS S2 requires disclosure of more detailed information on GHG
emissions targets, including additional information about a company’s
planned use of carbon credits to achieve its net GHG emissions targets.
IFRS S2 also includes additional requirements to disclose information
about the approach to setting and reviewing each target, and how the
company monitors progress against each target, including whether the
target was derived using a sectoral decarbonisation approach.

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2.3—Transition from TCFD with the financial statements as part of general
recommendations to ISSB Standards purpose financial reports and, at the same time,
reporting of connected information and the
Companies could benefit considerably from definition of material information. More information
applying ISSB Standards. The ISSB Standards related to IFRS S1 and IFRS S2 can be found via
focus on critical information that investors need the IFRS Sustainability Standards Navigator.
for decision making. They integrate and build upon
the core elements of the TCFD framework and Comparison analysis
other widely used sustainability frameworks and Refer to Tables 2.3–2.6 for a detailed comparison
standards to streamline the corporate sustainability of the TCFD recommendations and IFRS S2
reporting process. to understand the similarities and differences
The implementation of ISSB Standards not only between the two.
boosts the quality of information disclosed by
companies but also increases the transparency 2.3.2—Gap analysis
of that information, helping companies attract
Identify gaps
investment more effectively and at reduced costs.
In providing information necessary for reporting Compare the company’s current climate-related
it also enhances corporate strategic planning disclosures with the requirements in IFRS S2.
and coordination among employees, suppliers Make a note of any gaps in disclosures, especially
and customers. in areas for which the requirements in IFRS S2
go beyond the TCFD recommendations, such as
Adoption or other use of ISSB Standards facilitates industry-based metrics, use of carbon credits,
more cost-effective reporting in jurisdictions. additional information on targets, GHG emissions
Companies that have provided information using including financed emissions and Scope 3 GHG
the TCFD recommendations are well positioned emissions, and use of scenario analysis to assess
to use the ISSB Standards. However, making the climate resilience.
transition from disclosures prepared using the Consider whether the climate-related risks and
TCFD recommendations to disclosures prepared opportunities and value chain considered are
using ISSB Standards requires a strategic aligned with the reporting entity concept as set out
approach. The next paragraphs include a step- in IFRS S1. For example, the information provided
by-step guide to help companies to manage this with consolidated financial statements needs to
transition smoothly. provide information regarding the climate-related
risks and opportunities for the consolidated group.
2.3.1—Understanding ISSB Standards
Close gaps
Read and familiarise
Develop a plan to close these gaps, which might
Begin by thoroughly reading both IFRS S1 and
involve gathering new data, improving reporting
IFRS S2. These documents lay the foundation
processes or developing new ones.
for sustainability-related financial disclosures,
including climate-related disclosures using ISSB
Standards. IFRS S1 provides crucial context for
applying IFRS S2, such as the requirements to
provide sustainability-related financial information

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2.3.3—Governance, risk management 2.3.5—Training and internal communication
and strategy
Internal training
Governance Provide training for relevant internal stakeholders
Review the company’s governance structures on the similarities and differences between the
and processes to prepare for the enhanced TCFD recommendations and the requirements in
transparency and comparability required by IFRS S2, and on the importance of the disclosures
IFRS S1 and IFRS S2, and possible assurance of in enhancing investor–company dialogue.
sustainability-related financial disclosures.
Internal buy-in
Risk management Foster a culture of sustainability within the
Review the company’s risk management processes company, emphasising the role of enhanced
and policies to understand sustainability-related disclosures in improving access to and lowering
risks and opportunities over the short, medium and the cost of capital.
long term as required by IFRS S1 and IFRS S2.
2.3.6—External communication and
Strategy engagement
Review the company’s strategy to assess
Stakeholder engagement
sustainability-related risks, set and meet emissions
and other targets, and communicate long-term Communicate with investors and other
sustainability goals. stakeholders on how the company plans to
enhance the quality and comparability of
2.3.4—Update reporting processes sustainability-related financial disclosures.

Sustainability reporting External assurance

Align the company’s reporting processes with the Consider obtaining external assurance for
requirements in IFRS S1 and IFRS S2, ensuring the company’s sustainability-related financial
that financial statements and sustainability-related disclosures to enhance their credibility
financial disclosures are published simultaneously. and reliability.
Be mindful of the transition relief available in the
first year of preparing sustainability-related financial 2.3.7—Monitor regulatory developments
disclosures in accordance with IFRS S1.
Stay informed
Continuous improvement Keep abreast of further developments from the ISSB
Implement processes for continuous monitoring and regulatory changes in jurisdictions that might
and updating of disclosures to allow for evolving affect sustainability-related disclosure requirements.
standards and stakeholder expectations.
Ultimately, the transition from disclosures
prepared using the TCFD recommendations
to disclosures prepared using ISSB
Standards is not just about compliance,
but about seizing the opportunity to lead in
sustainability reporting and create long-term
value for all stakeholders.

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2.4—The role of digital taxonomies However, the quality of the model-generated output
and digital reporting for is highly dependent on the quality and structure
of the underlying data, which can be improved
climate‑related data
through the adoption of digital reporting practices.
In addition to standard-setting work, the ISSB has
Digital taxonomies like the ISSB Taxonomy
prioritised the development of a digital taxonomy to
will enable digital reporting of climate-related
enable the digital reporting of sustainability-related
information, which in turn will reduce the costs of
financial information.
searching through documents, enable automated
The ISSB believes the primary benefit of digital data collection, lead to more efficient information
reporting, compared to paper-based reporting, is processing and help expand the population of
the improved ability to search, extract and compare possible global investment targets.
reported information.
The IFRS Foundation’s website contains more Digital taxonomies and digital financial
information regarding the IFRS Foundation’s efforts reporting are major steps forward in
to increase the availability and usage of digital enhancing the availability, accessibility
information, including the introductory article and comparability of data. Additionally,
Digital Financial Reporting—Facilitating digital by reducing the costs associated with
comparability and analysis of financial reports searching and processing information, these
published in April 2024. advancements might facilitate more efficient
In addition to posing challenges for companies and effective analysis and help to improve
and their executives, factoring in climate-related market oversight.
information has imposed substantial information
processing costs on investors, creditors, data
providers, assurance providers, regulators In addition, as emphasised in the 2023 TCFD
and other consumers of information. Investors status report, having central access to digital
interested in climate-related data have often had reports plays an important role. Central access
to engage in time consuming, manual efforts to to digital reports can help reporting companies
gather data from disparate sources available at and their investors carry out more efficient and
different times. Such constraints make comparison accurate benchmarking and peer analyses. More
of climate-related information among companies a broadly, the availability of digital reports will result
real challenge. Users of climate-related information in more efficient market oversight and enforcement
can benefit from having relevant information reviews, enable automated validation checks and
presented in a digital format. technology-driven monitoring and improve overall
data sharing in the market.
For example, similar to the approach used for the
analysis discussed in Section 1.2—TCFD-aligned Advancements in digital reporting not only build
reporting by public companies, some investors upon the work of the TCFD and of the ISSB, but
and other stakeholders interested in examining also support the establishment of central, globally
the extent and quality of companies’ climate comparable sustainability data repositories.
reporting develop machine learning or AI models to The development of a global open repository for
examine large volumes of relevant reports for many climate data will provide free, public access to
companies simultaneously. a central source of climate-related information,
in line with the TCFD recommendations and the
requirements in IFRS S2.

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2.4.1—What is the ISSB Taxonomy? Without a digital taxonomy, companies might use
various descriptions to refer to the same concepts
The ISSB Taxonomy provides a list of defined
or use the same description for diverse concepts.
elements (commonly referred to as tags) needed
For example, companies might use ‘Scope 1
to make computer-readable information prepared
greenhouse gas emissions’ to refer to both absolute
in accordance with IFRS S1 and IFRS S2. As
and relative emissions. Without additional context
such, the ISSB Taxonomy provides a structure
from each company’s disclosures, users of
and classification for consistently and comparably
climate‑related information would need to invest
rendering sustainability-related information
additional effort in determining the measurement
(including climate-related information) computer-
unit of the concept along with the level of rounding.
readable.
However, if each company tags its disclosure with
The ISSB Taxonomy: the ‘AbsoluteGrossScope1GHGEmissions’ element
• is derived from ISSB Standards and reflects from the ISSB Taxonomy, a computer will be able
both the requirements in the Standards and the to determine the concept a company is referring
accompanying materials; to and its unit of measurement. In other words,
tags contain information (metadata) about the
• can be used with XBRL (eXtensible Business reporting period to which information relates and, if
Reporting Language) and other digital reporting applicable, the currency, unit of measurement and
formats; level of rounding of reported information. Tags also
• is regularly updated to reflect amendments to contain references to the related requirements in
ISSB Standards or new ISSB Standards; and ISSB Standards. These references allow users of
climate-related information:
• is distinct from the ‘green’ taxonomies used
for assessing or categorising the sustainability • to identify the specific reporting requirements to
ratings or attributes of a company or which information relates; and
product or the sustainability attributes of • to automatically search digitally tagged general
economic activities. purpose financial reports for information that
The IFRS Foundation also maintains the relates to a specific requirement.
SASB Standards Taxonomy, which companies Figure 2.1 provides an example of information
can use to make computer-readable information tagging as per the ISSB Taxonomy.
reported in accordance with the industry-based
SASB Standards. Table 2.7 summarises why digital financial
reporting is important.

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Figure 2.1—Illustration of ISSB Taxonomy for absolute gross Scope 1 emissions

Scope 1 GHG emissions

60
PDF
ISSB Taxonomy ‘tag’ 50

MtCO2e (thousands)
40
Co. A: Gross scope 1 emissions xxx Name ifrs-sds:AbsoluteGrossScope1
GHGEmissions 30
Co. B: Scope 1 GHG emissions xxx 20
Value xxx,000
Co. C: Scope 1 (direct GHG emissions) xxx 10
Units MtCO2e
Co. D: 스코프 1 온실가스배출량 xxx Period 202X-01-01 to 202X-12-31 0
A B C D E
Co. E: 範圍一温室氣體排放 xxx Decimals -3
Company

Table 2.7—Why digital financial reporting is important

Investors • automated data collection and reduced search costs

benefit from
• more efficient information processing
• reduced information asymmetry

Companies • increased analyst coverage and access to capital, including foreign investment,
benefit from fostering a broad and stable investor base
• more efficient and accurate benchmarking and peer analysis
• reduced burden of submitting the same information to more than one organisation
or government agency

Regulators • increased capital formation

benefit from
• more efficient market oversight and enforcement reviews
• automated validation checks and technology-driven monitoring
• improved data sharing between regulators and government agencies

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Digital financial reporting can improve capital The ISSB plays an important role in realising these
market transparency and efficiency. Improved benefits by developing the ISSB Taxonomy to help
transparency promotes capital formation and investors and other stakeholders digitally compare
allows companies to raise capital at a lower cost. and analyse sustainability-related financial
This opens up greater opportunities for investment, disclosures.
which in turn leads to economic growth and
Overcoming the challenges associated with digital
development. Research suggests that introducing
financial reporting will require effort from regulators
digital financial reporting requirements has led
and other stakeholders to ensure that:
to economic and other benefits for a multitude of
stakeholders.25 • digital financial reports are prepared using the
ISSB Taxonomy alongside ISSB Standards;
What is needed to realise the benefits of digital
• digital financial reports are assured by auditors
climate-related reporting?
and reviewed by regulators (including validation
Companies’ financial reports may or may not checks) to give investors confidence in the
be digital. If they are, they vary in how they are quality of the reports;
rendered computer-readable, data quality and
• digital financial reporting mandates require all
accessibility. Consequently, investors often cannot
information in sustainability-related financial
digitally extract and compare company reports
disclosures to be publicly and centrally
from various jurisdictions—or even from the same
accessible in a computer-readable, structured
jurisdiction.
data format at the same time that reported
For investors and other stakeholders to realise the information is available in other formats; and
full benefits of digitally tagged information, digital
• materials are made available to explain how
reports should be:
data from digital financial reporting repositories
• a complete and accurate representation of can be accessed, searched and extracted.
reported information;
• structured in a digitally comparable format;
• publicly available at the same time as reported
information; and
• centrally accessible in an easy-to-use format.

25 For example, since 2009, the US Securities and Exchange Commission (US SEC) has gradually introduced requirements for listed companies to
file their financial statements in eXtensible Business Reporting Language (XBRL), a computer-readable, structured data format. In 2019, the US
SEC started to introduce requirements for listed companies to file their financial statements in Inline XBRL (iXBRL), a computer- and human-
readable format. Foreign private issuers that report in the US using IFRS Accounting Standards are required to apply the IFRS Accounting
Taxonomy. Public digital filings with the US SEC can be accessed through the Electronic Data Gathering, Analysis, and Retrieval system
(EDGAR) at https://www.sec.gov/edgar/search. For a summary of academic research on benefits, see I. Troshani and N. Rowbottom, ‘Digital
corporate reporting: Research developments and implications’, Australian Accounting Review, vol 31, no 3, September 2021, pages 213–232
https://doi.org/10.1111/auar.12334 and I. Goldstein, S. Yang and L. Zuo, ‘The real effects of modern information technologies: Evidence from
the EDGAR implementation’, Journal of Accounting Research, vol 61, no 5, pages 1699–1733, June 2023, https://onlinelibrary.wiley.com/doi/
abs/10.1111/1475-679X.12496.

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2.5—Examples of companies preparing to move from TCFD recommendations
to ISSB Standards
This section provides examples of companies that are preparing the transition from disclosures prepared
using the TCFD recommendations to disclosures prepared using ISSB Standards. The information in the
examples is extracted from the companies’ public reports for fiscal year 2023.
Additional examples of companies preparing to use ISSB Standards are included in Section 1.4—
Companies referencing ISSB Standards.
The examples are not intended to assess the quality of companies’ disclosures’ alignment with the TCFD
recommendations or with sustainability-related disclosure requirements in ISSB Standards, but instead to
illustrate how companies are preparing to use ISSB Standards.

About Company A

Company A is a publicly traded property and casualty insurance company. With operations in more
than 50 jurisdictions, it provides commercial and personal property and casualty insurance, personal
accident and supplemental health insurance, reinsurance and life insurance to a diverse group of
clients. The parent company is listed on the New York Stock Exchange. It maintains executive offices
in several locations and employs approximately 40,000 people worldwide.

Extract from Company A’s 2023 Climate-related financial disclosure report(a)

We are proud to present our third annual TCFD Report, which reflects our ongoing work to manage
our climate risks and opportunities and take an evidence-based approach to addressing climate
change. We remain firmly committed to our responsibility to encourage the transition to a net-zero
economy while recognising the ongoing energy needs of the global economy. We will continue to be
guided by the fundamental underwriting principles that underlie our business and the best available
climate science as we seek to work with our clients and provide essential risk transfer capacity to
support the net-zero transition.
We actively assess new climate disclosure recommendations as they arise to identify emerging
trends. In the preparation of this year’s report, we have reviewed ISSB Standards, the SASB
Standards for insurance and the Net Zero Insurance Alliance’s Target Setting Protocol. While we have
some substantive and process concerns about the proliferation of various climate disclosure regimes,
we have endeavoured to include relevant and applicable data responsive to these standards.
continued ...

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Extract from Company A’s 2023 Climate-related financial disclosure report(a)

Over the last year, a number of approaches to climate disclosure have been newly promulgated or
elevated in prominence. We actively evaluate new approaches to climate disclosures to assess their
alignment with our broader business strategy. Our assessment of frameworks and methods turns on
(1) alignment with our broader climate strategy, (2) assessment of potential financial materiality of
information and (3) assessment of whether the framework or methodology helps us to evaluate our
role in facilitating the transition to the net-zero economy. We favour approaches that allow us to focus
on financially material issues and facilitating the reduction of GHG emissions in the real economy
over those that remain narrowly focused on counting or are overly reliant on estimation of data.
Our views on key emerging climate disclosure frameworks and methodologies are as follows.
IFRS S2: we appreciate the work of the ISSB and its ongoing focus on providing material information
to investors. We agree with the ISSB’s adoption of the TCFD framework as a useful tool to identify
and report financially material information to investors. We are continuing to work to evaluate and
understand the ISSB’s specific requirements for the calculation of financed emissions, and their
applicability to our business. In considering materiality metrics that may apply to climate and
sustainability reporting, we believe that financial materiality is the most appropriate.
SASB Insurance Sector Standard: ISSB Standards encourage adoption of the SASB sector-specific
Standards. We are currently in the process of evaluating the SASB Standards and their materiality for
our business.

(a) Some minor edits have been made to the language in this extract.

About Company B

Company B is a prominent life insurance group publicly listed on the Hong Kong Stock Exchange.
It operates throughout Asia-Oceania, providing life insurance, pensions, and accident and health
insurance to a diverse client base. With strategic executive offices established in several locations,
Company B employs a vast workforce committed to delivering security and wellbeing to its customers.
It employs approximately 23,000 people worldwide.

Extract from Company B’s 2023 ESG report(a)

We embrace our role to address climate change as an insurer, asset owner and responsible business.
This commitment is evident in our formulation and implementation of our ESG Strategy and Climate
Transition Plan launched in 2023. Our emission reduction levers enable us to effectively identify,
assess and manage climate-related risks and opportunities across our Operations, Investments and
Life and Health insurance portfolio. Our goal is to achieve net-zero greenhouse gas (GHG) emissions
by 2050.
continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 95

Extract from Company B’s 2023 ESG report(a)

We are dedicated to setting credible targets to address climate risks and opportunities, reinforcing our
support for global efforts towards a net-zero economy. Since 2018 we have supported the voluntary
adoption of the TCFD recommendations and continue to respond to and participate in regulatory
consultations in many markets to align with the TCFD recommendations. These efforts have extended
to markets such as Australia, Malaysia, Singapore, Hong Kong and New Zealand. This report’s
climate-related disclosures adhere to the TCFD’s Guidance for All Sectors and the Supplemental
Guidance for the Financial Sector.
IFRS S1 and IFRS S2: we responded in general support of the proposed ISSB Standards and are
committed to demonstrating progress towards adhering to the ISSB’s IFRS S1 (General Requirements
for Disclosure of Sustainability-related Financial Information) and IFRS S2 (Climate‑related
Disclosures). This commitment is reflected in our detailed presentation of our climate risk and
opportunity management processes in this report. The global adoption of ISSB Standards by regulatory
reporting bodies underscores their importance in guiding companies towards transparent and
comprehensive sustainability performance disclosures.

(a) Some minor edits have been made to the language in this extract.

About Company C

Company C is a mobile network operator listed on the Johannesburg Stock Exchange. Serving over
270 million subscribers in 20 markets in Africa and the Middle East, Company C offers voice, data,
fintech, digital, enterprise, wholesale and API services.

Extract from Company C’s 2023 sustainability report (a)

To support the widespread adoption of the new investor-focused standards, IFRS S1 and IFRS S2,
by the International Sustainability Standards Board, our company has pledged to begin the journey
of adopting these standards. We will have built upon our work on TCFD and have reported against
IFRS S2 rather than TCFD this year. This is because IFRS S1 and IFRS S2 disclosures meet the
TCFD disclosure requirements as these have been fully integrated.
While understanding sustainability-related risks and opportunities is a complex and iterative process,
we have developed significant processes around TCFD. These processes are now applied with
respect to IFRS S2. While we mature our alignment to IFRS S2, we are working proactively to prepare
for IFRS S1.
continued ...

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Extract from Company C’s 2023 sustainability report (a)

We understand that IFRS S2 needs to be applied in conjunction with IFRS S1. This is because
an entity is required to apply IFRS S2 in accordance with the conceptual foundations, general
requirements and the requirements related to judgements, uncertainties and errors in IFRS S1.
Our company embarked on this journey, following the publication of IFRS S1 and IFRS S2 in 2023,
aiming to mature our understanding of sustainability-related risks and opportunities and work towards
compliance with the framing required by ISSB Standards.
IFRS S1 and IFRS S2: to ensure group-wide alignment, we provided capacity development sessions
to our group executives and operating companies, outlining the implications of the new disclosure
guidance and its impact on our stakeholder communications through reporting. We have commenced
the process of aligning our reporting suite with IFRS S2 disclosure guidance, as demonstrated in our
2023 Climate Report.

(a) Some minor edits have been made to the language in this extract.

About Company D

Company D is a regional multilateral development bank that promotes the development of the private
sector and entrepreneurial initiative in more than 35 economies across three continents. The bank is
owned by more than 70 countries and public organisations. Its investments are aimed at making the
economies in its regions competitive, well governed, green, inclusive, resilient and integrated.

Extract from Company D’s 2023 TCFD report(a)

In 2023 the bank continued to act as a catalyst for the low-carbon transition across the economies in
which it operates. As a leading provider of climate finance, with established governance overseeing
climate-related risks and opportunities, the bank considers and assesses climate adaptation and
mitigation in all of its investment decisions.
The bank has been committed to applying the recommendations of the TCFD and reporting on its
progress since 2020. As climate risk practices continue to develop, the availability of sophisticated
tools and comprehensive datasets increases and regulatory frameworks become more established,
the bank will continue to reflect evolving expectations and guidance.
continued ...

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Extract from Company D’s 2023 TCFD report(a)

The 2023 climate disclosure showcases how the bank continues to mainstream policies and
procedures to meet its climate strategy and the expectations of shareholders and stakeholders in
the economies where it operates but is conscious that more needs to be done. In line with the core
TCFD pillars of governance, strategy, risk management, and metrics and targets, some key highlights
of this report are:
• all bank’s investment activities are aligned with the Paris Agreement approach agreed by multilateral
development banks and green finance accounts for at least 50% of the bank’s annual investment.
• every bank’s investment is assessed for climate risk and reviewed periodically. The assessment,
review and monitoring process will continue to develop, in line with the bank’s planned reporting in
line with ISSB Standards.
• the bank continuously refines its methodologies and procedures for assessing and managing
carbon transition and physical climate risks for all types of financing instrument.
• the carbon transition stress-testing exercise now covers 75% of the corporate and sub-sovereign
portfolio, using both a long-term Network for Greening the Financial System scenario and an in-
house short-term scenario. The bank also conducted a pilot physical risk stress test.
• as well as measuring and monitoring its own emissions, the bank increased coverage of its
financed emissions measurement.
While the regulatory environment continues to evolve more needs to be done to ensure that
disclosures lead to better decisions by investors. The bank closely observes emerging international
standards and regulatory developments, particularly in the EU and internationally, and promotes good
corporate sustainability practices. The bank expects to report under ISSB Standards for the 2025
financial year, at the latest.

(a) Some minor edits have been made to the language in this extract.

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SECTION 3—CLIMATE-RELATED • companies need to focus on reporting the impact
INFORMATION AND FINANCIAL of climate-related matters on their businesses,
strategies and financial planning.
STATEMENTS
The findings in this report show similar disclosure
3.1—Introduction patterns—for example, lower levels of disclosure
on climate-related risk management processes
The TCFD recommended that companies include and strategy. However, the report also states that
climate-related financial information in their annual more companies are including climate-related
financial filings—that is, the annual reporting disclosures in their financial filings—climate‑related
packages in which companies are required to risks and opportunities are becoming part of
deliver their audited financial results under the companies’ routine annual financial reporting
corporate, compliance or securities laws of the (see Section 1—State of climate-related
jurisdictions in which they operate. Although financial disclosures).
reporting requirements vary internationally, financial
As many companies prepare to make the transition
filings generally contain financial statements and
from disclosures prepared using the TCFD
other information such as governance statements
recommendations to disclosures prepared using
and management commentary.
ISSB Standards, more progress is expected in
The TCFD 2017 status report suggested that the climate-related financial disclosures and financial
TCFD recommendations could be useful to help statements being connected.
companies to comply more effectively with their
Specifically, ISSB Standards require:
disclosure obligations and enhance shareholder
engagement and broader use of climate-related • material climate-related information to be
financial disclosures, thereby promoting a more disclosed and the information provided in
informed understanding of climate-related general purpose financial reports;
risks and opportunities among investors and • sustainability-related financial information
other stakeholders.26 In monitoring companies’ to be provided at the same time as financial
progress in disclosing information aligned with its statements; and
recommendations, the TCFD found that companies
were more likely to disclose such information in • information to be provided about the effects of
their sustainability reports or in their annual or climate and other sustainability-related risks and
integrated reports than in their financial filings. In opportunities on both current and anticipated
2023 the TCFD concluded that: financial statements.

• despite an increase in the amount of

climate‑related financial information included
by companies in their financial filings, more
progress is necessary; and

26 TCFD, Final Report—Recommendations of the Task Force on Climate-related Financial Disclosures, TCFD, 2017, https://assets.bbhub.io/
company/sites/60/2021/10/FINAL-2017-TCFD-Report.pdf, pages 33–34.

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 This section discusses:
ISSB Standards and general purpose
financial reports • climate-related financial information,
IFRS Accounting Standards and financial
ISSB Standards require companies to provide statements; and
sustainability-related financial information
• the ISSB’s progress in ensuring climate-related
simultaneously with the financial statements as
financial disclosures and financial statements
part of their general purpose financial reports.
are connected.

3.1.1—Key takeaways
Table 3.1 summarises the key takeaways of Section 3.

Table 3.1—Key takeaways

Investors and other stakeholders are increasingly concerned about climate change’s
effect on business models, cash flows, financial position and financial performance,
necessitating better climate-related disclosures in financial statements.

More guidance is available for companies as they assess the effects of climate-related
matters on their financial statements. The International Accounting Standards Board
(IASB) proposed eight examples illustrating how a company applies IFRS Accounting
Standards to report the effects of climate-related and other uncertainties in its
financial statements.

As companies take the necessary steps to make the transition from disclosures prepared
using the TCFD recommendations to disclosures prepared using ISSB Standards, they
also get ready to provide sustainability-related financial information simultaneously with
the financial statements as part of their general purpose financial reports.

Companies applying ISSB Standards include in their sustainability-related disclosures

financial data and assumptions that are consistent with those used in the financial
statements, to the extent possible, considering the requirements in IFRS Accounting
Standards or other relevant generally accepted accounting principles.

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3.2—Climate-related financial Moreover, a company applying IFRS Accounting
information, IFRS Accounting Standards needs to disclose additional information
beyond that specifically required by the IFRS
Standards and financial statements
Accounting Standards if such information is
Investors and other stakeholders show growing necessary to enable investors to understand the
interest in understanding the potential effects of effects of climate-related matters on the company’s
climate change on companies’ business models, financial position and financial performance.
cash flows, financial position and financial
performance. Climate change affects, or is likely
3.2.1—IFRS Foundation guidance
to affect, all economic sectors. According to a
on climate-related matters in
report by the Intergovernmental Panel on Climate
financial statements
Change, many climate-related risks are higher The IFRS Foundation has developed
than previously thought and the long-term effects educational material to help companies applying
of climate-related risks are projected to be much IFRS Accounting Standards determine how to
greater than currently experienced.27 The report consider climate-related matters in preparing their
also suggested that the projected adverse financial statements:
effects and related losses and damages resulting
• Effects of climate-related matters on financial
from climate change would escalate with every
statements (republished in July 2023)—
increment of global warming.
educational material published by the IFRS
Given these findings, companies must consider Foundation reminding stakeholders of the
climate-related matters in preparing their financial long-standing requirements in IFRS Accounting
statements and disclose information about the Standards to report on the effects of climate-
effects of these matters when that information related matters in the financial statements if
is material. those effects are material.
• Effects of climate-related matters on financial
IFRS Accounting Standards do not refer statements prepared in accordance with
explicitly to climate-related matters. However, the IFRS for SMEs Accounting Standard—
companies must consider climate-related educational material published by the
matters in applying IFRS Accounting IFRS Foundation similar to the Effects of
Standards when the effect of those matters climate-related matters on financial statements
is material in the context of the financial but tailored to companies without public
statements taken as a whole. accountability that publish general purpose
financial statements for external users.

27 Intergovernmental Panel on Climate Change, Climate Change 2023—Synthesis Report—Summary for Policymakers, Intergovernmental Panel
on Climate Change, 2023, https://www.ipcc.ch/report/ar6/syr/downloads/report/IPCC_AR6_SYR_SPM.pdf.

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3.2.2—IASB’s project on climate- Based on this research, the IASB decided:
related and other uncertainties in the • to generalise the project’s objective to cover
financial statements climate-related and other uncertainties; and
In March 2023 the IASB started a project to explore • to propose examples to illustrate how a
targeted actions to improve the reporting of the company applies the requirements in IFRS
effects of climate-related risks in the financial Accounting Standards to report the effects of
statements (see Connectivity in practice: the climate-related and other uncertainties in its
IASB’s new project on Climate-related Risks in financial statements.
the Financial Statements, published by the IASB in
March 2023). In July 2024 the IASB published the Exposure
Draft Climate-related and Other Uncertainties
The project started in response to strong demand in the Financial Statements proposing eight
from investors and other stakeholders that were examples that illustrate how a company applies
concerned that the information about the effects the requirements in IFRS Accounting Standards
of climate-related risks in the financial statements to report the effects of climate-related and other
was sometimes insufficient or appeared to be uncertainties in its financial statements. The
inconsistent with the information provided outside illustrative examples focus on how a company:
the financial statements. Specifically, stakeholders
raised questions such as: • determines whether information about how
climate-related and other uncertainties affected
• why do companies that are expected to be its financial position and financial performance
affected by climate-related risks not provide is material, including considering connections
information about these effects in their financial to information it provides in other general
statements; purpose financial reports (Examples 1–2 in the
• why do companies that have made net-zero Exposure Draft);
commitments not recognise liabilities or impair • discloses information about how climate-related
the value of their assets as a result of those assumptions and other sources of estimation
commitments; and uncertainty affected the carrying amounts of
• how should companies factor long-term its assets and liabilities (Examples 3–7 in the
uncertainties into the measurement of amounts Exposure Draft); and
in the financial statements? • disaggregates information about its assets
The IASB carried out research to understand the and liabilities based on dissimilar climate-
nature and causes of stakeholder concerns about related risk characteristics (Example 8 in the
reporting the effects of climate-related risks in the Exposure Draft).
financial statements.

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Although the examples predominantly focus
on climate-related uncertainties, the illustrated Key takeaway
principles and requirements are equally applicable
Investors and other stakeholders increasingly
to other types of uncertainties. The IASB expects
consider climate-related risks in their
that these proposed illustrative examples
investment decisions. IFRS Accounting
will enhance the reporting of the effects of
Standards already require companies
climate‑related and other uncertainties in financial
to consider those risks in preparing
statements and strengthen the connections
financial statements. The IASB’s proposed
between a company’s general purpose
illustrative examples are expected to help
financial reports.
improve the application of IFRS Accounting
As the next steps, the IASB will review the Standards and the reporting of the effects of
feedback on the Exposure Draft and decide climate‑related and other uncertainties in the
whether to move forward with the proposed financial statements.
illustrative examples.
Throughout its work on the project, the IASB has
collaborated with members and technical staff
of the ISSB. The goal of this collaboration was
to help strengthen the connections between the
information a company provides in its financial
statements and the information it provides in other
parts of its general purpose financial reports.

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3.3—ISSB’s progress in ensuring
climate-related financial disclosures 3 Connected information
and financial statements
are connected The ISSB has built concepts from the Integrated
The ISSB has made substantial progress Reporting Framework into IFRS S1 and introduced
in ensuring that climate and other requirements for ‘connected information’ in IFRS S1
sustainability‑related financial disclosures and and IFRS S2.
financial statements are connected. This progress Companies applying ISSB Standards:
has been achieved by using materials from
the IFRS Accounting Standards and concepts • prepare sustainability-related financial
from the Integrated Reporting Framework. disclosures for the same reporting entity and
These connections will however be achieved covering the same reporting period as their
whether a company uses IFRS Accounting financial statements;
Standards or other generally accepted • publish sustainability-related financial
accounting principles. disclosures and financial statements
simultaneously;
1 Material information • include sustainability-related financial disclosures
in the general purpose financial reports;

The ISSB and the IASB use an aligned definition • include in their sustainability-related disclosures
of ‘material information’, ensuring that companies financial data and assumptions that are
applying ISSB Standards and IFRS Accounting consistent with those used in the financial
Standards provide information necessary to inform statements, to the extent possible, considering
investor decisions. the requirements in IFRS Accounting Standards
or other relevant generally accepted accounting
According to both boards, information is considered principles; and
material if omitting, misstating or obscuring
it could reasonably be expected to influence • disclose information about significant differences
investor decisions. in financial data and assumptions used for the
sustainability-related disclosures compared with
Reasonable and supportable those used to prepare the financial statements.
2 information
4 Current and anticipated effects
IFRS S1 and IFRS S2 include the concept of
‘reasonable and supportable information available
at the reporting date without undue cost or effort’. IFRS S1 and IFRS S2 require companies to
This concept is also present in IFRS 9 Financial link sustainability-related financial disclosures
Instruments and IFRS 17 Insurance Contracts, and to information in the financial statements.
allows companies to disclose information that is Companies applying ISSB Standards therefore
less costly to obtain as long as that information is disclose both current and anticipated effects
reasonable and supportable. of sustainability‑related risks and opportunities
(including climate-related risks and opportunities).
This requirement fosters a holistic view of
the company.

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SECTION 4—INTRODUCTION OF Support from governments, regulators, stock
CLIMATE-RELATED DISCLOSURE exchanges and standard-setters resulted in:

REQUIREMENTS IN REGULATORY • the introduction of the TCFD

FRAMEWORKS AND OTHER recommendations—in full or in part—into
laws, rules and guidance on climate-related
INITIATIVES disclosure; or

4.1—Introduction • a reference to the recommendations as a basis

for companies’ disclosure requirements.
The issuance of ISSB Standards in June 2023
marked the ‘culmination of the work of the The TCFD recommendations have been a driver
TCFD’. As discussed in Section 2—From TCFD of greater consistency among the major climate-
recommendations to ISSB Standards, the ISSB related disclosure regimes that were already in
Standards integrate the TCFD recommendations. effect when the TCFD was created, as well as
Having fulfilled its remit, the TCFD disbanded in among the climate-related disclosure requirements
October 2023. and standards that have been developed more
recently, such as IFRS S1 and IFRS S2.
Between the publication of the TCFD
recommendations in 2017 and the disbandment The ISSB, the EU and the US SEC, among others,
of the TCFD in 2023, more than 4,800 companies have drawn on the TCFD recommendations
and organisations—including industry associations when developing their climate-related disclosure
and governments—from various sectors and requirements.
jurisdictions expressed support for the TCFD’s Several major climate-related disclosure regimes
goals. The highest percentage of supporters (51%) have integrated the TCFD recommendations into
were in Asia-Oceania, with most being in Japan. their materials, such as:
• the Principles for Responsible Investment;
The list of supporters is no longer active now • the Climate Disclosure Standards Board; and
that the TCFD has disbanded.
• CDP.
In 2024 CDP updated its questionnaire to
Importantly, not all companies and organisations
align it with IFRS S2, having previously done
that supported the TCFD recommendations
the same with the TCFD recommendations.
implemented them. Some organisations expressed
The questionnaire can provide an effective tool to
support by convening their members and helping
support companies on their path to compliance
them to implement the recommendations
with ISSB Standards.
consistently, whereas others—such as
governments and regulators—encouraged or
required companies and other organisations to Although the TCFD was a voluntary initiative,
implement the recommendations. support from governments and financial
regulators helped develop a holistic approach
to improving climate-related financial
disclosures. This approach is now evolving
with the introduction of sustainability‑related
disclosure requirements into many
regulatory frameworks.

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This section provides information on jurisdictions This section also discusses interoperability of
that have issued or proposed climate-related ISSB Standards with other standards and initiatives
disclosure requirements that integrate or draw and the collaboration between the ISSB and
from the TCFD recommendations, together with other organisations.
information about the status of adoption or other
use of ISSB Standards.

4.1.1—Key takeaways
Table 4.1 summarises the key takeaways of Section 4.

Table 4.1—Key takeaways

The issuance of ISSB Standards—which integrate the TCFD recommendations—marked

the ‘culmination of the work of the TCFD’. Having fulfilled its remit, the TCFD disbanded.

In May 2024 the IFRS Foundation published the Inaugural Jurisdictional Guide for
the adoption or other use of ISSB Standards to promote globally comparable climate
and other sustainability-related disclosures for capital markets. A growing number of
jurisdictions are using the guide to help them to move ahead with their plans to adopt or
otherwise use ISSB Standards.

In the past 12 months jurisdictions representing approximately 57% of global gross

domestic product have made progress towards the adoption or other use of ISSB
Standards. These jurisdictions include both jurisdictions that have issued or proposed
disclosure requirements aligned with the TCFD recommendations previously
(14 jurisdictions) and other jurisdictions mainly in Africa, Latin America and the Caribbean,
and Asia-Oceania, that are introducing sustainability-related disclosure requirements for
the first time (an additional 16 jurisdictions).

The TCFD recommendations have been a driver of greater consistency among the
major climate-related disclosure regimes that were already in effect when the TCFD was
created, as well as among the climate-related disclosure requirements and standards
that have been developed more recently, such as ISSB Standards, ESRS and the US
SEC climate rule. In addition to adoption or other use of ISSB Standards resulting in
information being provided that is consistent with the TCFD recommendations, in the case
of ESRS and the US SEC climate rule their use of the TCFD recommendations facilitates
interoperability with ISSB Standards.

The collaboration of the ISSB with other organisations reduces the complexity of the
sustainability disclosure landscape, which simplifies the process for both companies
and investors.

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4.2—Issued and proposed disclosure An additional 16 jurisdictions have made progress
requirements aligned with the TCFD towards the adoption or other use of ISSB
Standards, without having previously issued or
recommendations
proposed disclosure requirements aligned with the
As of September 2024: TCFD recommendations.
• companies in 14 jurisdictions are subject The requirements in these jurisdictions cover a
to disclosure requirements aligned with the range of company types. Some requirements
TCFD recommendations for fiscal year 2023; apply to listed companies, others apply to
• companies in three additional jurisdictions will specific financial institutions and others apply to
be subject to such requirements from fiscal a combination of financial institutions and large
year 2024; and companies.

• companies in three additional jurisdictions will Table 4.2 provides an overview of jurisdictions that
be subject to such requirements from fiscal have issued or proposed disclosure requirements
year 2025. aligned with the TCFD recommendations or have
made progress towards the adoption or other use
Furthermore, one jurisdiction has proposed of ISSB Standards, by region.
disclosure requirements that integrate or draw from
the TCFD recommendations with proposed effect
from fiscal year 2025.
In the past 12 months, 14 of these 21 jurisdictions
have made progress towards the adoption or other
use of ISSB Standards, making the transition
from climate-related disclosure requirements
based on the TCFD recommendations to
sustainability‑related disclosure requirements
based on ISSB Standards.

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Table 4.2—Overview of jurisdictions that have issued or proposed disclosure requirements aligned
with the TCFD recommendations

Jurisdictions
Number that have made progress towards the adoption Number that have issued
or other use of ISSB Standards(a) or proposed disclosure
Region of which have previously of which have not previously requirements aligned with the
issued or proposed disclosure issued or proposed disclosure TCFD recommendations, but
requirements aligned with the requirements aligned with the have not made progress towards
TCFD recommendations TCFD recommendations the adoption or other use of
ISSB Standards
Africa 1 6 2
Latin America and 2 4 1
the Caribbean
North America 1 - 1
Asia-Oceania 7 5 3
Europe 3 1 -
Total 14 16 7
(a) ISSB Standards integrate the TCFD recommendations.

Table 4.3 provides, for each of these jurisdictions, The summary in Table 4.3 is based on information
a summary of the issued or proposed available to the IFRS Foundation as of
disclosure requirements aligned with the TCFD September 2024.
recommendations, with information regarding:
• new standards, such as the status of adoption or Jurisdictions representing approximately
other use of ISSB Standards. The jurisdictions 57% of global gross domestic product, more
that have made progress towards the adoption than 40% of the global market capitalisation
or other use of ISSB Standards represent and more than half of global GHG emissions
approximately 57% of the global gross domestic have made progress towards the adoption or
product, more than 40% of the global market other use of ISSB Standards.
capitalisation and more than half of global GHG
emissions.28
• proposals or requirements regarding some form
of assurance of reported information.

28 For 2023, global gross domestic product (GDP) was approximately US$105 trillion, the global market capitalisation was approximately
US$117 trillion and global GHG emissions were approximately 54 gigatons of CO2 equivalent (GtCO2e). Global GDP data is sourced from the
International Monetary Fund. Global GHG emissions data is sourced from EDGAR—Emissions Database for Global Atmospheric Research. For
most jurisdictions the market capitalisation data is current as of 31 December 2023, or as close as possible to that date when data for a specific
jurisdiction was not available for that date, and is sourced from CEIC Data. IMF, ‘IMF Datamapper’, accessed 29 June 2024, https://www.imf.org/
external/datamapper/NGDPD@WEO/WEOWORLD/AUS/CHL/EUQ; EDGAR—Emissions Database for Global Atmospheric Research, accessed
6 July 2024, https://edgar.jrc.ec.europa.eu.

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Table 4.3—Issued or proposed disclosure requirements aligned with the TCFD recommendations
by jurisdiction

Includes information on new standards and assurance of reported information

Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of

reported information
Authority(a) Time frame Report type
and scope(b)
Australia Department of Phased Annual report Disclosures are required in Phased
the Treasury FY 2025—companies – separate accordance with Australian Proposed limited assurance
(September that exceed two of sustainability Sustainability Reporting for some disclosures in
2024) three criteria (revenue section Standards (ASRS) the first year of reporting
>A$500 million, assets developed by the Australian progressing to reasonable
>A$1 billion, >500 Accounting Standards Board assurance for all disclosures
employees) (AASB). The AASB issued in the fourth year of
the first set of ASRS in reporting, based on the
FY 2026—companies September 2024, which are
that exceed two of Proposed Australian
based on ISSB Standards. Standard on Sustainability
three criteria (revenue
>A$200 million, assets Assurance published by
>A$500 million, >250 the Auditing and Assurance
employees); asset Standards Board published
owners with assets in September 2024.
>A$5 billion
FY 2027—companies
that exceed two of
three criteria (revenue
>A$50 million,
assets >A$25 million,
>100 employees)

Bangladesh Central Bank of FY 2024—banks and Phased The Central Bank of –

Bangladesh financial institutions FY 2024— Bangladesh has issued
(December report to a circular requiring
2023) Central Bank disclosures based on
of Bangladesh ISSB Standards.
FY 2025—
annual report
continued ...

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Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of
reported information
Authority(a) Time frame Report type
and scope(b)
Bolivia Consejo FY 2024—companies General CTNAC has endorsed CTNAC is monitoring the
Técnico are permitted to use purpose ISSB Standards for use progress of the International
Nacional de ISSB Standards financial by companies that carry Auditing and Assurance
Auditoría y FY 2027—companies reports out economic activities Standards Board (IAASB)
Contabilidad are required to use throughout Bolivia. in developing a global
(CTNAC) of the ISSB Standards sustainability assurance
Contadores standard and considering
Públicos de the adoption of the
Bolivia International Standard on
(March 2024) Sustainability Assurance
5000 General Requirements
for Sustainability Assurance
Engagements (ISSA 5000).
Brazil Central Bank of FY 2022—regulated Sustainability CVM and the Brazilian In accordance with the
Brazil institutions except report Ministry of Finance have standards issued by the
(September Segment 5 endorsed ISSB Standards Federal Accounting Council
2021) (October 2023). sustainability-related
FY 2024—companies financial disclosures are
Securities FY 2022—regulated Annual
are permitted to use subject to assurance by
and Exchange issuers report or
ISSB Standards. an independent auditor
Commission sustainability
registered with the CVM:
(CVM) report FY 2026—listed companies,
investment funds and (a) limited assurance until
(March 2022)
securitisation companies the end of FY 2025; and
are required to apply (b) reasonable assurance
standards issued by from FY 2026.(d)
the Comitê Brasileiro
de Pronunciamentos de
Sustentabilidade (CBPS
Standards), which are based
on ISSB Standards.
continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 110

Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of
reported information
Authority(a) Time frame Report type
and scope(b)
Canada Office of the FY 2024—domestic Left to the OSFI updated Guideline –
Superintendent systemically discretion of B-15: Climate Risk
of Financial important banks and the reporting Management to align with
Institutions internationally active entity but IFRS S2.
(OSFI) insurance groups expected to
(March 2023) FY 2025—all other be publicly
in-scope federally available
(March 2024
update) regulated financial
institutions
Autorité des FY 2024—Group A Public Risk disclosures intended to
marchés financial institutions, disclosure align with IFRS S2.
financiers of to be identified by the (type not
Quebec (AMF) AMF prescribed)
(July 2024) FY 2025—all other
in-scope financial
institutions
Canadian Phased—regulated Financial filing The Canadian Sustainability
Securities issuers Standards Board (CSSB)
Administrators published proposed
(CSA) sustainability-related
(October disclosure standards
2021— for public consultation,
proposed) which are based on
ISSB Standards.
(March 2024
update— CSA determines whether
proposed) and how the standards
developed by CSSB will
be incorporated into
the Canadian regulatory
framework.
Chile Financial Phased Annual report In August 2024 CMF –
Markets FY 2022—large proposed that companies
Commission non‑financial would be required to apply
(CMF) companies ISSB Standards from FY
(November 2026, with early application
FY 2023— permitted.
2021) medium‑sized
non‑financial
companies
FY 2024—financial
companies and
small‑sized companies
continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 111

Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of
reported information
Authority(a) Time frame Report type
and scope(b)
China Ministry of – Sustainability The Ministry of Finance –
Finance of report published Corporate
the People’s Sustainability Disclosure
Republic of Standards—Basic Standards
China for public consultation,
(May 2024— which are based on IFRS S1.
proposed)
Colombia Financial FY 2023—large Annual report In July 2023 the national –
Superintendence issuers standard-setter, the Consejo
of Colombia Técnico de la Contaduria
(December Pública, created a Technical
2021) Sustainability Expert
Committee to analyse
the possible alignment of
local sustainability-related
disclosure requirements
with ISSB Standards.
Costa Rica Costa Rican Phased General The Colegio de Contadores –
Institute of FY 2024—companies purpose Públicos announced the
Certified Public are permitted to use financial adoption of ISSB Standards.
Accountants ISSB Standards reports
(January 2024) FY 2025—regulated
companies
FY 2026—companies
classified as high
tax payers
Egypt Financial FY 2022—issued Annual report – –
Regulatory capital or net
Authority(e) ownership >500
(July 2021) million Egyptian
pounds
El Salvador Supervisory FY 2025—companies General CVPCPA permits some –
Board of that prepare financial purpose companies to use ISSB
the Public statements applying financial Standards.
Accounting IFRS Accounting reports
and Auditing Standards
Profession
(CVPCPA)
(August 2024)
continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 112

Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of
reported information
Authority(a) Time frame Report type
and scope(b)
EU European FY 2023—large Prudential EU companies apply the Phased
Commission institutions that disclosures European Sustainability External limited
(November are issuers on EU Reporting Standards assurance, progressing to
2022) regulated markets (ESRS). reasonable assurance for
European FY 2024—large EU Annual report The climate-related all sustainability-related
Parliament and undertakings subject – separate disclosure requirements matters (FY 2024–2028).
Council to the Non-Financial sustainability in ESRS are highly
Reporting Directive section aligned with those in ISSB
(December
Standards. The alignment is
2022) FY 2025—large EU
described in the ESRS–ISSB
undertaking
Standards Interoperability
FY 2026—small Guidance.
and medium EU
undertaking
FY 2028—non-EU
undertaking
Ghana Institute of Phased General ICAG endorsed ISSB Assurance of reported
Chartered FY 2024—companies purpose Standards and published a information would be
Accountants, are permitted to use financial roadmap towards adoption required from the second
Ghana (ICAG) ISSB Standards reports of ISSB Standards. year of application of
(March 2024) ISSB Standards. Type of
FY 2027—significant assurance required will be
public interest entities determined on the basis of
FY 2028—other ISSA 5000.
companies meeting
specific parameters
Hong Kong Hong Kong FY 2025—all issuers Sustainability Hong Kong’s Financial The Accounting and
SAR Stock Exchange report Services and the Treasury Financial Reporting Council
(April 2024) Bureau issued a vision will lead the development
statement outlining their of local sustainability-
commitment to developing related assurance and
a robust sustainability ethics standards, taking into
disclosure ecosystem in line account the latest global
with ISSB Standards. developments, such as
The Hong Kong Institute of relevant discussions at the
Certified Public Accountants IAASB and International
proposed local sustainability Ethics Standards Board for
reporting standards, which Accountants.
are fully aligned with ISSB
Standards.
continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 113

Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of
reported information
Authority(a) Time frame Report type
and scope(b)
India Reserve Bank Financial institutions Financial filing – –
of India FY 2025–2026—
(February information on
2024— governance, strategy
proposed) and risk management
FY 2027–2028—
information on metrics
For tier IV primary
(urban) co-operative
banks requirements
would apply one year
later
Japan Financial FY 2023—all issuers Financial filing The Sustainability Standards Assurance is expected
Services Board of Japan (SSBJ) to be required for listed
Agency (JFSA) proposed sustainability companies required to
(January 2023) disclosure standards apply SSBJ’s standards.
for public consultation,
which are based on
ISSB Standards. JFSA
is determining which
companies will be required
to apply the SSBJ’s
standards.
Kenya Central Bank of FY 2023—licensed Left to the FY 2024—companies –
Kenya institutions discretion of are permitted to apply
(October 2021) the reporting ISSB Standards.
entity as The Institute of Certified
appropriate Public Accountants of Kenya
and has stated its intention to
accessible adopt ISSB Standards and
to its is developing an adoption
stakeholders roadmap.
In September 2024 the
Central Bank of Kenya
published a draft Climate
Risk Disclosure Framework
intended to align with
IFRS S2.
South Korea Korea The relevant To be KSSB proposed –
Sustainability governmental authorities determined sustainability disclosure
Standards and regulators will by the South standards for public
Board (KSSB) determine the effective Korean consultation, which are
(April 2024— dates and which government based on ISSB Standards.
proposed) companies will be
required to apply the
KSSB’s standards
continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 114

Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of
reported information
Authority(a) Time frame Report type
and scope(b)
Malaysia Bursa Malaysia FY 2025—specific Annual report The Advisory Committee Phased
Stock Exchange listed issuers on Sustainability Reporting Subject to further
(September has developed the National consultations and
2022) Sustainability Reporting engagements, the Advisory
Framework using ISSB Committee on Sustainability
Central Bank of FY 2024—financial Financial
Standards as the basis for Reporting aims to require
Malaysia institutions filing, annual
reporting requirements for reasonable assurance of
(November report or
companies in Malaysia. information about Scope 1
2022) sustainability
report FY 2025—large issuers and Scope 2 GHG emissions
listed in the Main Market from FY 2027.
are required to apply ISSB
Standards (with reliefs for
two years).
FY 2026—other issuers
listed in the Main Market
are required to apply ISSB
Standards (with reliefs for
two years).
FY 2027—issuers listed
in the growth market (ACE
Market) and large non-listed
companies are required to
apply ISSB Standards (with
reliefs for three years).
Mauritius Central Bank of FY 2023—licensed Annual report – –
Mauritius banks and deposit-
(April 2022) taking non-banks

Mexico National FY 2025—non- General CNBV would require Proposal to require

Banking and financial companies purpose non‑financial companies to assurance of reported
Securities financial use ISSB Standards from information in accordance
Commission reports FY 2025. with assurance standards
(CNBV) issued by the IAASB.
(September
2024—
proposed)
continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 115

Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of
reported information
Authority(a) Time frame Report type
and scope(b)
New Zealand New Zealand FY 2023—issuers Annual report – External limited assurance
Government(f) with securities for Scope 1, Scope 2 and
(October 2021) >NZ$60 million Scope 3 GHG emissions,
Banks with assets using International Standard
>NZ$1 billion, on Assurance (NZ) 3410
asset managers Assurance Engagements on
with assets under Greenhouse Gas Statements
management (AUM) or International Organization
>NZ$1 billion, insurers for Standardization (ISO)
with premium income 14064-3 Greenhouse
>NZ$250 million gases—Part 3: Specification
with guidance for the
verification and validation of
greenhouse gas statements,
from FY 2024.
Nigeria Financial Phased General The FRC has issued a Phased
Reporting FY 2024—companies purpose roadmap for the adoption Limited assurance starting
Council of are permitted to use financial of ISSB Standards and from the third year of
Nigeria (FRC) ISSB Standards reports has amended the Financial reporting, progressing to
(March 2024) Reporting Act to reflect reasonable assurance for
FY 2028—all public
the application of ISSB all sustainability-related
interest entities
Standards. matters from the sixth year
except government
and government of reporting.
organisations
FY 2030—small and
medium-sized entities
Pakistan Institute of Phased General ICAP, through its Assurance in accordance
Chartered FY 2025—companies purpose Sustainability Working with ISSA 5000 would be
Accountants of meeting two out of financial Group, explored whether required from the second
Pakistan (ICAP) three criteria (annual reports to adopt ISSB Standards in year of reporting.
(December revenue >Pakistani Pakistan and published a
2023— rupees 25 billion, report recommending the
proposed) >1,000 employees and time frame and scope of the
total assets >Pakistani requirements.
rupees 12.5 billion)
FY 2026—companies
meeting two out of
three criteria (annual
revenue >Pakistani
rupees 12.5 billion,
>500 employees and
total assets >Pakistani
rupees 6.25 billion)
FY 2027—other listed
companies
continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 116

Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of
reported information
Authority(a) Time frame Report type
and scope(b)
Philippines Securities FY 2022—all Financial The Securities and Exchange –
and Exchange registrants filing or Commission requested
Commission sustainability comments on Revised
(February report Sustainability Reporting
2019) Guidelines for Publicly
Listed Companies and the
Securities and Exchange
Commission Sustainability
Reporting Form (SuRe
Form), both of which take
into account requirements
in ISSB Standards in the
reporting form.
The Philippines
Sustainability Reporting
Committee endorsed ISSB
Standards for use from FY
2025 subject to the issuance
of regulations roadmap
adopted by the relevant
regulators.
Singapore Singapore FY 2023—listed Sustainability In September 2024 SGX Issuers are encouraged
Exchange companies operating in report or RegCo amended its listing to obtain independent
(SGX) specific industries annual report rules to require issuers external assurance on
(December FY 2024—listed to provide climate-related the sustainability report.
2021) companies operating in disclosures based on SGX RegCo will conduct a
specific industries ISSB Standards. separate public consultation
FY 2025—issuers are on the mandatory
The Accounting Phased Sustainability
required to refer to assurance requirements for
and Corporate All issuers and large report or
Regulatory annual report ISSB Standards in preparing climate‑related disclosures
non-listed companies in the future.
Authority and climate-related disclosures
Singapore and to disclose Scope 1 and
Exchange Scope 2 GHG emissions
Regulation and the measurement
(ACRA and approach used.
SGX RegCo)
(July 2023—
proposed)

continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 117

Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of
reported information
Authority(a) Time frame Report type
and scope(b)
Sri Lanka The Institute Phased General CA Sri Lanka has issued –
of Chartered FY 2024—companies purpose Sri Lankan Sustainability
Accountants of are permitted to use financial Disclosure Standards based
Sri Lanka (CA ISSB Standards reports on ISSB Standards.
Sri Lanka)
FY 2025—top 100
(March 2024) public companies on
main board
FY 2026—all listed
companies on main
board
FY 2027—all listed
companies in the stock
exchange
FY 2028—companies
with revenue >Sri
Lankan rupees 10
billion
FY 2029—companies
with revenue >Sri
Lankan rupees 2.5
billion
FY 2030—all specified
business enterprises
Switzerland Federal Council FY 2024—public Sustainability The Swiss Stock Exchange –
(November companies, banks and report has included ISSB
2022) insurance companies Standards in the list of
with ≥500 employees internationally recognised
and assets >SFr20 standards for sustainability
million or revenue reporting under the SIX
>SFr40 million Exchange Regulation.
Federal Council FY 2027—companies Sustainability The Federal Council It is expected that the
(June 2024— or groups with ≥250 report proposed to require level of assurance and
proposed) employees and assets companies to choose other details will follow
>SFr25 million or to apply either ESRS or the same path as the EU
revenue >SFr45 million equivalent standards, requirements.
for two consecutive such as ISSB Standards
fiscal years in combination with GRI
Standards.
continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 118

Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of
reported information
Authority(a) Time frame Report type
and scope(b)
Chinese Taipei Financial FY 2023—banks and Annual report FSC has endorsed ISSB Assurance specified for
Supervisory insurance companies Standards and released a Scope 1 and Scope 2
Commission roadmap. GHG emissions only, from
(FSC) FY 2026—listed companies FY 2029.
(August 2023) with capital >NT$10 billion
are required to apply ISSB
Standards.
FY 2027—listed companies
with capital in the range
NT$5–10 billion are required
to apply ISSB Standards.
FY 2028—other listed
companies are required to
apply ISSB Standards.
Tanzania National Board FY 2025—public General NBAA endorsed ISSB Assessment of the
of Accountants interest entities purpose Standards and published a consistency between
and Auditors financial roadmap towards adoption sustainability-related
(NBAA) reports of ISSB Standards. financial disclosures
(July 2024) and financial statements
in accordance with
ISA 720 The Auditor’s
Responsibilities Relating to
Other Information.
Thailand Central Bank of FY 2023—all financial Annual – –
Thailand(g) institutions report or
(February sustainability
2023) report

Türkiye Public FY 2024—listed General KGK has issued Turkish Assurance required from FY
Oversight, companies that exceed purpose Sustainability Disclosure 2025.
Accounting two of three criteria financial Standards based on ISSB
and Auditing in two consecutive reports Standards.
Standards reporting periods (total
Authority assets >Turkish lira
(KGK) 500 million; annual net
(December sales revenue >Turkish
2023) lira 1 billion; >250
employees) and banks

continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 119

Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of
reported information
Authority(a) Time frame Report type
and scope(b)
Uganda Institute of FY 2026—companies General ICPAU has launched a ICPAU is considering the
Certified Public are permitted to use purpose consultation on the adoption introduction of mandatory
Accountants ISSB Standards financial of ISSB Standards. assurance on the basis of
of Uganda FY 2028—public reports ISSA 5000.
(ICPAU) interest entities
(July 2024—
proposed)
UK Financial FY 2022—issuers of Annual report After the endorsement of –
Conduct standard listed shares ISSB Standards by the
Authority (FCA) and global depositary UK government, the FCA
(December receipts will consult on amending
2021) Asset managers with its disclosure rules to
AUM >£50 billion, move from the TCFD
(May 2024 recommendations to UK-
update) asset owners with
AUM >£25 billion endorsed ISSB Standards
for listed companies.
FY 2023—asset
managers and asset
owners with AUM
>£5 billion
UK Parliament FY 2022—specific UK Annual report The UK government has –
(January 2022) companies and limited committed to introducing
liability partnerships ISSB Standards into its
>500 employees and regulatory framework,
revenue >£500 million subject to a formal
FY 2022—occupational assessment and
pension schemes with endorsement process in the
assets >£5billion first quarter of 2025.

FY 2023—occupational
pension schemes with
assets >£1 billion
continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 120

Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of
reported information
Authority(a) Time frame Report type
and scope(b)
US US Securities Phased Financial filing The US SEC climate Climate-related financial
and Exchange FY 2026—large or annual rule does not provide an information included in
Commission accelerated filers report alternative reporting regime a registrant’s financial
(US SEC) for foreign private issuers statements is subject to
FY 2027—accelerated to meet the US SEC’s requirements for the audit
(March 2024)(h) filers
climate-related disclosure of financial statements
FY 2028—all other requirements through and internal control
listed companies ISSB Standards at this over financial reporting.
time. However, the US SEC GHG emissions disclosures
recognised that companies are subject to limited
registered with the US SEC assurance beginning
might operate or be listed in in the third year after
jurisdictions that will adopt initial disclosures;
ISSB Standards. large accelerated filers’
GHG emissions disclosures
are subject to reasonable
assurance from FY 2033.
On or before 1 January
California State Climate- California Senate Bill No. –
Legislature 2026—companies related 261 requires companies
(October 2023) operating in California financial risk to disclose information
with annual revenue report about their climate-
>US$500 million related financial risk in
accordance with TCFD
recommendations or ISSB
Standards.(i)
Zambia Zambia FY 2025—publicly General ZiCA issued a circular –
Institute of accountable entities purpose requiring public accountable
Chartered financial entities to use ISSB
Accountants reports Standards. Other entities
(ZiCA) are permitted to use ISSB
(November Standards.
2023)
continued ...

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 121

Jurisdiction TCFD-aligned disclosure requirements New standards(c) Assurance of
reported information
Authority(a) Time frame Report type
and scope(b)
Zimbabwe Public FY 2024—companies General PAAB announced adoption –
Accountants operating in Zimbabwe purpose of the ISSB Standards
and Auditors financial and is developing an
Board (PAAB) reports adoption roadmap.
(August 2023)
(a) The date in parentheses refers to the date of publication of the requirements or proposed requirements by the authority.
(b) The time frames refer to the first fiscal year in which the requirements apply.
(c) T
 he new standards integrate the TCFD recommendations. For jurisdictions that have previously issued or proposed disclosure requirements
aligned with the TCFD recommendations, the column ‘new standards’ includes information about the time frames and scope for the application
of the new standards.
(d) CVM, CVM Resolution No. 193, Article 6, 20 October 2023, https://www.gov.br/cvm/en/foreign-investors/regulation-files/ResolutionCVM193.pdf.
(e) In July 2021 the Financial Regulatory Authority of Egypt issued resolutions requiring companies listed on the Egyptian Stock Exchange and
companies operating in non-bank financial activities whose issued capital or net ownership rights are not less than 500 million Egyptian
pounds to provide climate-related disclosures in accordance with the TCFD recommendations. The announcement of the Financial Regulatory
Authority of Egypt is in Arabic. The United Nations Sustainable Stock Exchanges Initiatives provides a summary of the announcement in
English.
(f) A
 ccording to New Zealand’s Financial Sector (Climate-related Disclosures and Other Matters) Amendment Act 2021, passed in October 2021,
from fiscal year 2023 large publicly listed companies, insurers, banks, non-bank deposit takers and investment managers are required to provide
climate-related information in accordance with Aotearoa New Zealand climate standards developed by New Zealand’s External Reporting Board
(XRB) in line with the TCFD recommendations. Financial Sector (Climate-related Disclosures and Other Matters) Amendment Act 2021,
https://www.legislation.govt.nz/act/public/2021/0039/latest/LMS479636.html. External Reporting Board (XRB) Aotearoa New Zealand Climate
Standards, XRB, https://www.xrb.govt.nz/standards/climate-related-disclosures/aotearoa-new-zealand-climate-standards.
(g) In February 2023 the Bank of Thailand released a policy statement requesting that all financial institutions disclose climate-related information
in line with the TCFD recommendations at least once a year from fiscal year 2023. Bank of Thailand, ‘Policy statement of the Bank of Thailand
Re: internalizing environmental and climate change aspects into financial institution business’, Bank of Thailand, 2023, https://www.bot.or.th/
content/dam/bot/fipcs/documents/FPG/2566/EngPDF/25660028.pdf.
(h) O
 n 4 April 2024 the US SEC issued an order to stay the rule, pending completion of an ongoing judicial review, ‘In the Matter of the
Enhancement and Standardization of Climate-Related Disclosures for Investors: Order Issuing Stay, US SEC, 2024, https://www.sec.gov/files/
rules/other/2024/33-11280.pdf.
(i) In September 2024 California Senate Bill No. 261 was amended by Senate Bill No. 219, https://leginfo.legislature.ca.gov/faces/billNavClient.
xhtml?bill_id=202320240SB219.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 122

4.3—Introduction of TCFD 4.3.1—Africa
recommendations or ISSB Standards
Ghana
in regulatory frameworks by region
In March 2024 the Institute of Chartered
This section summarises the efforts and Accountants, Ghana published a roadmap towards
developments by governments, regulatory the adoption of ISSB Standards.29
authorities, international and regional standard-
setters, and stock exchanges that support the The roadmap describes a phased approach:
introduction of TCFD recommendations or ISSB • all companies can apply ISSB Standards on a
Standards in regulatory frameworks, by region. voluntary basis from fiscal year 2024;
This section focuses on developments that have • significant public entities will be required to apply
occurred since the TCFD published its last status ISSB Standards from fiscal year 2027; and
report in October 2023. If—based on information
• other companies—excluding companies
available to the IFRS Foundation—a government,
without public accountability meeting specific
regulatory authority or stock exchange issued
parameters and government organisations not
or proposed requirements based on TCFD
applying IFRS Accounting Standards—will be
recommendations or ISSB Standards during this
required to apply ISSB Standards from fiscal
period, a brief description of the requirements is
year 2028.
included in this section.
In May 2024 the IFRS Foundation published the Kenya
Inaugural Jurisdictional Guide for the adoption or In June 2023 the national standard-setter, the
other use of ISSB Standards to promote globally Institute of Certified Public Accountants of Kenya,
comparable climate and other sustainability‑related stated its intention to adopt ISSB Standards.
disclosures for capital markets by helping a
Companies in Kenya are permitted to apply
growing number of jurisdictions as they move
ISSB Standards from fiscal year 2024.30
ahead with their plans to adopt or otherwise use
ISSB Standards.

29 Institute of Chartered Accountants, Ghana (ICAG), ‘IFRS Sustainability Disclosure Adoption Roadmap for Ghana’, ICAG, 2024, https://www.icagh.
org/wp-content/uploads/2024/06/PRESS-RELEASE-IFRS-S1-S2.pdf.
30 Institute of Certified Public Accountants of Kenya (ICPAK), ‘Adopt IFRS standards to boost investor trust, Kenyan firms urged’, ICPAK, 2024,
https://www.icpak.com/adopt-ifrs-standards-to-boost-investor-trust-kenyan-firms-urged.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 123

Nigeria Zambia
In March 2024 the Adoption Readiness Working In November 2023 the Zambia Institute of
Group of Nigeria, under the leadership of the Chartered Accountants adopted ISSB Standards,
Financial Reporting Council, introduced a roadmap requiring all publicly accountable entities in Zambia
for the adoption of ISSB Standards.31 to use ISSB Standards from fiscal year 2025.
Other entities can use ISSB Standards on a
The roadmap describes four phases of adoption,
voluntary basis.34
starting with voluntary adoption by all groups of
Nigerian reporting entities from fiscal year 2024. Zimbabwe
Public interest entities, except government and
In November 2022 the Zimbabwe Minister of
government organisations, will be required to
Finance and Economic Development issued a
apply ISSB Standards from fiscal year 2028,
resolution to adopt ISSB Standards early.
with requirements extending to SMEs in fiscal
year 2030. The Public Accountants and Auditors Board (PAAB)
is responsible for establishing an implementation
Tanzania roadmap that will be informed by an assessment
In September 2023 the National Board of of ISSB Standards’ suitability for application in
Accountants and Auditors of Tanzania endorsed Zimbabwe. In August 2023 PAAB published a call
ISSB Standards.32 for evidence.35
All public interest entities in Tanzania are
required to apply ISSB Standards from fiscal year
2025. Early application of the ISSB Standards
is encouraged.

Uganda
In September 2024 the Institute of Certified Public
Accountants of Uganda launched a consultation
on its roadmap for the adoption of ISSB Standards.
Companies would be permitted to use ISSB
Standards from fiscal year 2026. Public interest
entities would be required to use ISSB Standards
from fiscal year 2028.33

31 Financial Reporting Council of Nigeria (FRC), ‘Roadmap Report for Adoption of IFRS Sustainability Disclosure Standards in Nigeria’, FRC, 2024,
https://frcnigeria.gov.ng/wp-content/uploads/2024/07/FINAL-COPY-OF-SUSTAINABILITY-ROADMAP1.pdf.
32 National Board of Accountants and Auditors of Tanzania (NBAA), ‘Technical pronouncement no. 1 of 2024, Adoption and implementation of
sustainability reporting standards in Tanzania’, NBAA, 2024, https://www.nbaa.go.tz/2024/july/1q2024.pdf.
33 Institute of Certified Public Accountants of Uganda (ICPAU), ‘Adoption of sustainability Disclosure Standards – Uganda, Public consultation’,
ICPAU, 2024, https://www.icpau.co.ug/sites/default/files/Resources/Consultation%20Paper%20-%20ADOPTION%20OF%20
SUSTAINABILITY%20DISCLOSURE%20STANDARDS%20IN%20UGANDA_0.pdf.
34 Zambia Institute of Chartered Accountants, Circular 4/2023, Adoption of sustainability standards and Integrated Reporting Framework, 2023.
35 Public Accountants and Auditors Board (PAAB), Zimbabwe Adoption of IFRS S1 & S2—Call for Evidence, PAAB, 2023, https://paab.org.zw/wp-
content/uploads/2023/08/PAAB-Adoption-of-IFRS-S1-and-S2-Call-for-Evidence-1.pdf.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 124

Spotlight on Nigeria

The African Finance Ministers announced their support of ISSB Standards, with the Financial Reporting Council of
Nigeria being the first to formally announce its intention to adopt them, in stages.

2023–2027 2028 2030 To be determined

Mandatory application of ISSB Standards

Public interest entities, SMEs(a) Government and

except government and government
government organisations organisations(b)
Voluntary use of ISSB
Standards Assurance requirements are also to be phased in. These requirements are based on
International Standard on Sustainability Assurance 5000 General Requirements for
Sustainability Assurance Engagements, which is being developed by the International
Auditing and Assurance Standards Board for sustainability assurance engagements
designed to provide limited or reasonable assurance.

(a) Small and medium-sized entities (SMEs) are defined by the roadmap as ‘entities that may not have public accountability and: (a) their debt
or equity instruments are not traded in a public market; (b) they are not in the process of issuing such instruments for trading in a public
market; (c) they do not hold assets in a fiduciary capacity for a broad group of outsiders as one of their primary businesses; (d) the amount
of their annual turnover is not more than Nigerian Nairas 500 million or such amount as may be fixed by the Corporate Affairs Commission;
(e) their total asset value is not more than Nigerian Nairas 200 million or such amount as may be fixed by the Corporate Affairs Commission;
(f) no Board members are an alien; (g) no members are a government or a government corporation or agency or its nominee, and (h) the
directors among them hold not less than 51 percent of its equity share capital’.
(b) Government and government organisations are defined by the roadmap as ‘public sector entities that are required to apply the International
Public Sector Accounting Standards (IPSAS) in line with the IPSAS applicability Statement issued by the Financial Reporting Council. Such
entities: (a) are responsible for the delivery of services to benefit the public and/or to redistribute income and wealth; (b) mainly finance their
activities, directly or indirectly, by means of taxes and/or transfers from other levels of government, social contributions, debt, or fees; and (c)
do not have a primary objective to make profits’.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 125

4.3.2—Latin America and the Caribbean Chile
Since fiscal year 2022 the Financial Market
Bolivia
Commission (CMF) has required large non-
In March 2024 the national standard-setter, financial companies to provide sustainability-
the Consejo Técnico Nacional de Auditoría y related financial information in their annual
Contabilidad (CTNAC) of the Contadores Públicos reports, with medium-sized non-financial
de Bolivia, approved CTNAC Resolution No. companies to follow in fiscal year 2023 and
01/2024 to adopt ISSB Standards. In the absence financial companies and small-sized companies
of jurisdiction-specific technical pronouncements in fiscal year 2024.38 These companies are
or local regulations on specific matters, companies required to provide information aligned with
that carry out economic activities in Bolivia are the TCFD recommendations and to report,
required to apply ISSB Standards in full as of on a ‘comply or explain’ basis, on the SASB
1 January 2027, with early application permitted. sustainability metrics relevant to their industries.
A three-year deadline was set for disclosure, risk
In August 2024 the CMF proposed that companies
identification and training in ISSB Standards.36
would be required to apply ISSB Standards from
Brazil fiscal year 2026, with early application permitted.39
Since fiscal year 2022 the Central Bank Colombia
of Brazil and the Brazilian Securities and
In December 2021 the Colombian government
Exchange Commission (CVM) have required
agency responsible for overseeing financial
regulated institutions and listed companies
regulation and market systems, the
to provide information in line with the TCFD
Superintendencia Financiera de Colombia, adopted
recommendations.
the TCFD recommendations and the SASB
In October 2023 CVM and the Ministry of Finance Standards, via Circular no. 31/2021, requiring
announced that ISSB Standards will be integrated large issuers to provide climate-related financial
into the jurisdiction’s regulatory framework. CVM disclosures from fiscal year 2023.
Resolution No. 193 permits listed companies,
In July 2023 the national standard-setter, the
investment funds and securitisation companies to
Consejo Técnico de la Contaduria Pública, created
apply ISSB Standards from fiscal year 2024 and
a Technical Sustainability Expert Committee
requires listed companies to apply the Standards
to explore aligning local sustainability-related
from fiscal year 2026.37
disclosure requirements with ISSB Standards.

36 Consejo Técnico Nacional de Auditoría y Contabilidad (CTNAC) of the Contadores Públicos de Bolivia, Resolution No. 01/2024, CTNAC, 2024,
https://auditorescontadoresbolivia.org/wp-content/uploads/2024/07/resolucionctnacn01.2024.pdf.
37 CVM, CVM Resolution No. 193, 20 October 2023, https://www.gov.br/cvm/en/foreign-investors/regulation-files/ResolutionCVM193.pdf.
38 Financial Market Commission, ‘Press release—CMF issues regulation incorporating sustainability and corporate governance requirements in
annual reports’, Financial Market Commission, 2021, https://www.cmfchile.cl/portal/principal/613/w3-article-49809.html.
39 Financial Market Commission, ‘Press release—CMF publishes for consultation regulatory proposal perfecting instructions on Integrated Annual
Reports’, Financial Market Commission, 2024, https://www.cmfchile.cl/portal/principal/613/w3-article-84195.html.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 126

Costa Rica Mexico
In January 2024 the Costa Rican Institute of In December 2021 the TCFD Mexico Consortium
Certified Public Accountants, the Colegio de was launched to support voluntary use of the
Contadores Públicos, announced the adoption of TCFD recommendations in Mexico.42
ISSB Standards.40
The national standard-setter, Consejo Mexicano
The Standards will be implemented using a phased de Normas de Información Financiera y de
approach, which states: Sostenibilidad, is promoting:
• all companies can apply ISSB Standards on a • application of ISSB Standards for
voluntary basis from fiscal year 2024; listed companies and public interest
organisations; and
• regulated companies will be required to apply
ISSB Standards from fiscal year 2025; and • application of local standards based on ISSB
Standards for SMEs.
• companies that are classified as high tax payers
will be required to apply ISSB Standards from In September 2024 the National Banking and
fiscal year 2026. Securities Commission, the Comisión Nacional
Bancaria y de Valores, proposed to require
El Salvador non‑financial companies to use ISSB Standards
In August 2024 the national standard-setter, from fiscal year 2025.43
the Consejo de Vigilancia de la Profesión de
Contaduría Pública y Auditoría, issued a resolution
permitting companies that prepare financial
statements applying IFRS Accounting Standards to
use ISSB Standards from fiscal year 2025.41

40 Colegio de Contadores Públicos, Circular No. 33-2023-Adopción de Normas Internacionales de Información Financiera Relacionadas con
Sostenibilidad, Colegio de Contadores Públicos, 2023,
https://www.ccpa.or.cr/circular-n-33-2023-adopcion-normas-internacionales-de-informacion-financiera-relacionadas-con-sostenibilidad/.
41 Consejo de Vigilancia de la Profesión de Contaduría Pública y Auditoría, Resolution 82, 2024 https://www.cvpcpa.gob.sv/resolucion-82.
42 International Climate Initiative (IKI), ‘Official launch of the TCFD Mexico Consortium’, IKI, 2021,
https://iki-alliance.mx/en/lanzamiento-oficial-del-consorcio-tcfd-mexico/.
43 Comisión Nacional Bancaria y de Valores, (CNBV), Resolución que modifica las disposiciones de carácter general aplicables a las emisoras
de valores y a otros participantes del mercado de valores, CNBV, 2024, https://www.cofemersimir.gob.mx/portales/resumen/57550.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 127

Spotlight on Brazil

The sustainability-related disclosure requirements for regulated institutions and listed companies are based on the
TCFD recommendations. The Brazilian Securities and Exchange Commission (CVM) permits the use of ISSB Standards
from fiscal year 2024 and requires listed companies to apply ISSB Standards from fiscal year 2026.

TCFD recommendations ISSB Standards

2018 2020 2021–2022 2023–2024

Voluntary—the Brazilian Federation of Banks Mandatory—the Central Bank of Brazil (BCB)

(FEBRABAN) has encouraged the Brazilian banking and CVM require regulated institutions and listed
sector to apply the TCFD recommendations. companies to provide information in line with the
TCFD recommendations. Companies are permitted to
apply ISSB Standards from fiscal year 2024.

FEBRABAN started an In January 2020 BCB issued disclosure CVM approved a

initiative to implement the FEBRABAN published a requirements for resolution:
TCFD recommendations progress report describing regulated institutions to be • permitting listed
in the Brazilian banking the Brazilian banking implemented in two phases companies, investment
sector, following a roadmap sector’s progress in (governance, strategy and funds and securitisation
to support the sector. implementing the TCFD risk management in the companies to apply
recommendations in 2019. first phase, and quantitative ISSB Standards from
aspects—such as metrics fiscal year 2024; and
and targets—in the second
phase). • requiring listed
companies to apply
CVM amended its rules—
ISSB Standards from
effective from 2023—to
fiscal year 2026.
require securities issuers to
state whether they disclose The Brazilian national
sustainability‑related standard-setter,
information and whether Comitê Brasileiro de
the information is Pronunciamentos de
aligned with the TCFD Sustentabilidade (CBPS),
recommendations or other and the Conselho Federal
standards or frameworks. de Contabilidade published
two exposure drafts of
local translated standards
(CBPS 01 and CBPS 02).

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 128

4.3.3—North America time to implement the disclosures and related
assurance requirements.
Canada
The rule will be implemented using a phased
In March 2024 the Canadian Sustainability approach:
Standards Board proposed sustainability-related
disclosure standards for public consultation, which • large accelerated filers will be required to apply
are based on ISSB Standards.44 the rule from fiscal year 2025, with a one-year
transition relief for some disclosures, including
To become mandatory under Canadian securities disclosures of Scope 1 and Scope 2 GHG
legislation, the Canadian Sustainability Disclosure emissions;
Standards are required to be integrated into a rule
of the Canadian Securities Administrators, which • accelerated filers will be required to apply
anticipates consulting on a revised rule setting out the rule from fiscal year 2026, with two-year
climate-related disclosures once the Canadian transition relief for disclosures of Scope 1 and
Sustainability Disclosure Standards are finalised.45 Scope 2 GHG emissions; and

US • all other listed companies will be required to

apply the rule from fiscal year 2027, with an
In March 2024 the US SEC issued a final rule that exemption from providing disclosures about
requires registrants to provide climate disclosures GHG emissions.
in their annual reports and registration statements,
from fiscal year 2025 for the largest category of In October 2023 the Governor of California
listed entities.46 On 4 April 2024 the US SEC issued signed into law two landmark bills requiring some
an order to stay the rule, pending completion of an companies operating in California:
ongoing judicial review.47 • to report their Scope 1, Scope 2 and Scope 3
The final rule reflects several important differences GHG emissions annually;49 and
from the requirements in the proposed rule.48 • to disclose information about their climate-
For example, companies will not be required to related financial risks in accordance with TCFD
provide information about Scope 3 GHG emissions, recommendations or ISSB Standards, on or
their financial statement disclosure requirements before 1 January 2026.50
will be less extensive and they will have more

44 Financial Reporting & Assurance Standards Canada (FRAS), ‘Media release—Canadian Sustainability Standards Board announces first
Canadian Sustainability Disclosure Standards for public consultation’, FRAS, 2024, https://www.frascanada.ca/en/sustainability/projects/adoption-
csds1-csds2/media-release-cssb-public-consultation.
45 Canadian Securities Administrators, ‘Canadian securities regulators issue statements on proposed sustainability disclosure standards and
ongoing climate consultation’, Canadian Securities Administrators, 2024, https://www.securities-administrators.ca/news/canadian-securities-
regulators-issue-statements-on-proposed-sustainability-disclosure-standards-and-ongoing-climate-consultation.
46 US Securities and Exchange Commission (US SEC), ‘The Enhancement and Standardization of Climate-Related Disclosures for Investors—Final
rule’, US SEC, 2024, https://www.sec.gov/files/rules/final/2024/33-11275.pdf.
47 US SEC, ‘In the Matter of the Enhancement and Standardization of Climate-Related Disclosures for Investors: Order Issuing Stay, US SEC, 2024,
https://www.sec.gov/files/rules/other/2024/33-11280.pdf.
48 US SEC, ‘The Enhancement and Standardization of Climate-Related Disclosures for Investors—Proposed rule,’ US SEC, 2022,
https://www.sec.gov/files/rules/proposed/2022/33-11042.pdf.
49 California Senate Bill No. 261, ‘Greenhouse gases: climate-related financial risk’, 2023, https://leginfo.legislature.ca.gov/faces/billTextClient.
xhtml?bill_id=202320240SB261. In September 2024 California Senate Bill No. 261 was amended by Senate Bill No. 219, https://leginfo.
legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240SB219.
50 California Senate Bill No. 253, ‘Climate Corporate Data Accountability Act’, 2023, https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_
id=202320240SB253. In September 2024 California Senate Bill No. 253 was amended by Senate Bill No. 219, https://leginfo.legislature.ca.gov/
faces/billNavClient.xhtml?bill_id=202320240SB219.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 129

Spotlight on Canada

The sustainability-related disclosure requirements under development are based on ISSB Standards. The Canadian
Securities Administrators (CSA) determines whether and how the standards developed by the Canadian Sustainability
Standards Board (CSSB) will be incorporated into the Canadian regulatory framework.

TCFD recommendations ISSB Standards

2018 2019 2022 2023 2024

In autumn 2018 The Canadian In October 2022 The Office of the The CSSB proposed
the Minister of Minister of Finance the CSA issued a Superintendent of sustainability-
Environment and disclosed in a press release on Financial Institutions related disclosure
Climate Change budget report the status of its (OSFI) released standards for public
and the Minister of the government’s proposed TCFD- guidance on consultation, which
Finance launched intentions to ‘raise aligned disclosure climate-related risk are based on ISSB
an Expert Panel awareness of the requirements for management for Standards.
on Sustainable importance of reporting issuers. financial institutions OSFI updated
Finance to provide tracking, managing The CSA announced that included its Guideline B-15:
recommendations and disclosing it was reviewing expectations for Climate Risk
for the federal material climate- the US SEC’s climate-related Management to align
government to build related risks and proposed climate- financial disclosure. with IFRS S2.
on the work of the opportunities related disclosure The guidance
TCFD. in a consistent on disclosure The Autorité des
requirements and marchés financiers
The Investor and comparable the draft ISSB references an
way’. The report annex that outlines of Quebec issued
Leadership Network Standards. a Guideline on
was launched at also stated that, minimum mandatory
where appropriate climate-related climate-related risk
the G7 meeting in management for
Canada to build and relevant, the financial disclosure
government of expectations. financial institutions
on guidance and that included its
best practices to Canada would These disclosure
encourage adoption expectations expectations for
expand the adoption climate-related
of the TCFD of the TCFD integrate the TCFD
recommendations recommendations. financial disclosure
recommendations to align with
and to help direct by federal Crown
corporations. IFRS S2.
capital flows
towards sustainable
businesses.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 130

4.3.4—Asia-Oceania China
In May 2024 the Ministry of Finance of the People’s
Australia
Republic of China published the Exposure Draft
In September 2024 the Australian Parliament of Chinese Sustainability Disclosure Standards
approved the legislation introduced by the for Business Enterprises – Basic Standard and
Department of the Treasury in Australia requiring Explanation of the Drafting.
companies that present financial reports and meet
The Exposure Draft formulates the unified China
specified size thresholds to provide climate-related
Sustainability Disclosure Standards based on
disclosures in accordance with the Australian
ISSB Standards.
Sustainability Reporting Standards (ASRS)
developed by the Australian Accounting Standards Hong Kong SAR
Board (AASB).51 In April 2024 the Hong Kong Stock Exchange
The requirements apply to financial institutions and revised its environmental, social and governance
to large listed and unlisted companies and will be (ESG) reporting framework to require all issuers to
phased in over a three-year period beginning with disclose climate-related information in their ESG
fiscal year 2025.52 reports in line with the TCFD recommendations
and ISSB Standards (as opposed to the current
In September 2024 the AASB issued ‘comply and explain’ approach), from fiscal
AASB S1 General Requirements for Disclosure year 2025.54
of Sustainability-related Financial Information
In August 2023 the Hong Kong Monetary Authority
and AASB S2 Climate-related Disclosures,
(HKMA) released a circular with high‑level
which are in line with the structure of the
principles to assist authorised institutions in
TCFD recommendations and are based on
planning for a net-zero transition. The HKMA
ISSB Standards.
developed the high-level principles based on the
Bangladesh findings and recommendations of international
bodies, such as the TCFD’s ‘Guidance on metrics,
In December 2023 the Central Bank of Bangladesh
targets, and transition plans’.55
issued a circular based on ISSB Standards
requiring banks and financial institutions to provide In September 2024 the Hong Kong Institute of
disclosures about their sustainability-related risks Certified Public Accountants published Exposure
and opportunities from fiscal year 2024.53 Drafts of Sustainability Disclosure Standards to
be applied in Hong Kong from 1 August 2025.
The Exposure Drafts are fully aligned with IFRS S1
and IFRS S2.56

51 Parliament of the Commonwealth of Australia, Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Bill 2024,
Schedule 4, https://www.aph.gov.au/Parliamentary_Business/Bills_Legislation/Bills_Search_Results/Result?bId=r7176.
52 According to the Explanatory Memorandum to Bill 2024, section 4.180–4.187, larger companies are required to provide the information for annual
periods starting in 2025, with other companies following in 2026 and 2027, https://parlinfo.aph.gov.au/parlInfo/download/legislation/ems/r7176_
ems_dd1e1136-f342-4dbf-8eae-9db60d977f84/upload_pdf/JC012553.pdf;fileType%3Dapplication%2Fpdf.
53 Bangladesh Bank, ‘Guideline on Sustainability and Climate-related Financial Disclosure’, Bangladesh Bank, 2023, https://www.bb.org.bd/
mediaroom/circulars/gbcrd/dec262023sfd06e.pdf.
54 Hong Kong Stock ‘Exchange (HKEX), Exchange Publishes Conclusions on Climate Disclosure Requirements’, HKEX, 2024, https://www.hkex.com.
hk/News/Regulatory-Announcements/2024/240419news?sc_lang=en.
55 Hong Kong Monetary Authority (HKMA), ‘Circular—Planning for net-zero transition’, HKMA, 2023, https://www.hkma.gov.hk/media/eng/doc/key-
information/guidelines-and-circular/2023/20230829e1.pdf; and TCFD, ‘Guidance on metrics, targets, and transition plans’, TCFD, 2021,
https://assets.bbhub.io/company/sites/60/2021/07/2021-Metrics_Targets_Guidance-1.pdf.
56 Hong Kong Institute of Certified Public Accountants (HKICPA), Invitation to comment on Exposure Draft HKFRS S1 General Requirements for
Disclosure of Sustainability-related Financial Information; and Exposure Draft HKFRS S2 Climate-related Disclosures, HKICPA, 2024,
https://www.hkicpa.org.hk/en/Standards-setting/Standards/Open-for-comment-documents/Sustainability-Reporting.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 131

India Japan
In February 2024 the Reserve Bank of India In January 2023 the Financial Services Agency,
published a draft disclosure framework for Japan (JFSA), announced new rules that require
regulated banks on climate-related financial risks.57 listed companies to disclose sustainability
The draft framework would require some financial information—including climate-related
institutions to disclose information about their information—in four categories generally aligned
climate-related financial risks and opportunities. with the TCFD recommendations.58 The disclosure
The proposed disclosure requirements are of information about governance and risk
structured in line with the TCFD recommendations. management is required, whereas the disclosure of
information about strategy and metrics and targets
The draft framework applies to:
is required only if the information is material.
• all scheduled commercial banks (excluding
The rules became effective on 31 January 2023
local area banks, payments banks and regional
and apply to securities registration statements and
rural banks);
annual securities reports for fiscal years ending on
• all tier IV primary (urban) co-operative banks; and after 31 March 2023.
• all India financial institutions; and The Sustainability Standards Board of Japan
• all top and upper layer non-banking (SSBJ) is developing sustainability disclosure
financial companies. standards based on ISSB Standards. JFSA is
determining which companies will be required to
Companies within the scope of the draft framework
apply the SSBJ’s standards.
would be required to report information on
governance, strategy and risk management from In March 2024 the SSBJ published exposure drafts
fiscal year 2025–2026 onwards. Information on of sustainability disclosure standards to be applied
metrics and targets would be required from fiscal in Japan.59 The proposed standards integrate most
year 2027–2028 onwards. For tier IV primary of the requirements in ISSB Standards and include
(urban) co-operative banks, the requirements jurisdiction-specific options a company may apply if
would apply one year later. appropriate. The SSBJ plans to issue the standards
by 31 March 2025.

57 Reserve Bank of India (RBI), ‘Press release—RBI invites comments on the “Draft Disclosure Framework on Climate-related Financial Risks,
2024”’, RBI, 2024, https://www.rbi.org.in/Scripts/BS_PressReleaseDisplay.aspx?prid=57408.
58 Financial Services Agency, Japan (JFSA), ‘Press release—Results of public comments on the proposed amendments to the cabinet office
ordinance on disclosure of corporate details, etc.’, JFSA, 2023, https://www.fsa.go.jp/news/r4/sonota/20230131/20230131.html.
59 SSBJ, ‘The SSBJ issues exposure drafts of sustainability disclosure standards to be applied in Japan’, SSBJ, 2024, https://www.ssb-j.jp/en/
exposure_drafts/y2024/2024-0329.html.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 132

Spotlight on Japan

The sustainability-related disclosure requirements for listed entities are based on the four pillars of the
TCFD recommendations. The Sustainability Standards Board of Japan (SSBJ) is developing sustainability disclosure
standards that are based on ISSB Standards and the Financial Services Agency, Japan (JFSA), is determining which
companies will be required to apply the SSBJ’s standards.

TCFD recommendations ISSB Standards

2018 2019 2021 2023 2024

Voluntary—public support from JFSA, Ministry of Economy, Trade Mandatory—JFSA requires listed companies
and Industry (METI) and Ministry of the Environment (MOE) has in Japan to disclose information in four
encouraged voluntary use of the TCFD recommendations by pillars generally aligned with the TCFD
companies in Japan. recommendations and is determining which
companies will be required to apply the
SSBJ’s standards.

In December 2018 In March 2019 JFSA, METI and JFSA announced The SSBJ published
METI released MOE released a MOE released their new rules requiring exposure drafts
‘Guidance on ‘Practical guide for ‘Basic guidelines on listed companies of sustainability
climate-related scenario analysis climate transition to disclose disclosure standards
financial disclosures’ in line with TCFD finance’, which sustainability to be applied
as a handbook recommendations’. include several information— in Japan. The
for implementing The Japan TCFD references to the including climate- proposed standards
the TCFD Consortium TCFD framework. related information— integrate most of
recommendations for was created as The Tokyo Stock in four categories the requirements in
five industries. an industry-led Exchange (via generally aligned ISSB Standards and
The Japan TCFD organisation for the Corporate with the TCFD include jurisdiction-
Consortium updated supporters to Governance recommendations. specific options a
the guidance in July facilitate dialogue Code) and JFSA The governance and company may apply
2020 and October between investors (as part of its risk management if appropriate.
2022 to promote and companies on strategic priorities) categories are The SSBJ plans to
TCFD-aligned the climate-related encouraged required, whereas issue the standards
disclosure in a financial disclosures companies listed in the strategy and by 31 March 2025.
broader range of recommended the Prime Market indicators and
industries and to by the TCFD. to enhance the targets (that
include updates the Keidanren, the quality and quantity is, metrics and
TCFD made to its Japanese Business of disclosure based targets) categories
material in 2021. Association, joined on the TCFD are subject to
the consortium as recommendations. materiality (effective
one of the founding for fiscal years
members, signalling ending on and after
to Japanese 31 March 2023).
companies the
importance of
climate-related
financial disclosure.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 133

South Korea Malaysia

In May 2024 the Korea Sustainability Standards Sustainability-related disclosure requirements

Board (KSSB) published an exposure draft of the are in place in Malaysia for financial institutions
Korean Sustainability Disclosure Standards.60 (from fiscal year 2024) and for issuers listed in the
main market and in the growth market (from fiscal
The proposed Korean sustainability year 2025).61
disclosure standards comprise two mandatory
The Advisory Committee on Sustainability
disclosure standards and one non-mandatory
Reporting has developed the National
disclosure standard:
Sustainability Reporting Framework using
• KSSB 1 General Requirements for Disclosure ISSB Standards as the basis for reporting
of Sustainability-related Financial Information, requirements for companies in Malaysia.62
which is based on IFRS S1;
Larger issuers listed in the Main Market (market
• KSSB 2 Climate-related Disclosure, which is capitalisation >Malaysian ringgit 2 billion (excluding
based on IFRS S2; and treasury shares)) are required to apply:
• KSSB 101 Additional Disclosure aligned with • IFRS S2 with reliefs—and consequently apply
Policy Objectives, which is a jurisdiction-specific the requirements in IFRS S1 only insofar as
standard that allows companies to selectively they relate to the disclosure of information on
disclose additional sustainability-related climate‑related risks and opportunities—for fiscal
information as required by domestic laws or to year 2025; and
meet the sustainability-related policy objectives.
• IFRS S1 and IFRS S2 from fiscal year 2027.
The Korean government will determine the timeline Other issuers listed in the Main Market, issuers
for the requirements to become effective in the listed in the growth market (ACE Market) and large
legal framework or listing rules, after consultation non-listed companies will follow the same steps
with stakeholders. one and two years later than larger issuers listed in
the Main Market.
Following the launch of the National Sustainability
Reporting Framework, Bursa Malaysia has also
issued a public consultation on the proposed
amendments to align its Listing Requirements.

60 Korea Sustainability Standards Board (KSSB), ‘KSSB published the Exposure Draft of the Sustainability Disclosure Standards’, KSSB, 2024,
https://www.kasb.or.kr/front/board/cmtreadView.do;jsessionid=B5A69842BB73BDCEE62945F958220042?boardMngNo=&boardNo=&cmtreadSe
q=209&seq=&siteCd=.
61 Bursa Malaysia laid the foundation for sustainability reporting for its listed issuers in sustainability reporting requirements it introduced in October
2015. In September 2022 Bursa Malaysia added further requirements such as for companies to disclose information on 11 common themes and
associated indicators that are deemed material for all listed issuers. Reporting on nine themes started in fiscal year 2023 for main market-listed
issuers and in fiscal year 2024 for ACE market-listed issuers. Main market-listed issuers are required to make TCFD-aligned climate disclosures
starting in fiscal year 2025 and ACE market-listed issuers are required to disclose a basic plan for making the transition to a low-carbon economy
starting in fiscal year 2026. The central bank of Malaysia requires financial institutions to provide TCFD-aligned climate disclosures from fiscal
year 2024.
62 Advisory Committee on Sustainability Reporting (ACSR), National Sustainability Reporting Framework, ACSR, 2024, https://www.sc.com.my/api/
documentms/download.ashx?id=46cad705-4a30-4315-b09c-b8d205a46be1.

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Pakistan Philippines
In the second half of 2023 the Accounting In October 2023 the Securities and Exchange
Standards Board of the Institute of Chartered Commission of the Philippines (SEC) requested
Accountants of Pakistan (ICAP), through its comments on Revised Sustainability Reporting
Sustainability Working Group, explored whether to Guidelines for Publicly Listed Companies and
adopt ISSB Standards in Pakistan. ICAP published the SEC Sustainability Reporting Form, which
a report recommending:63 takes into account ISSB Standards.64 Companies
• adoption of ISSB Standards in Pakistan; would be required to report sustainability-related
information via:
• a phased approach to adoption:
• a sustainability reporting narrative in the form of
о Phase I—companies meeting two out of three a narrative sustainability report and the annual
criteria (annual revenue >Pakistan rupees 25 report; and
billion, >1,000 employees and total assets
>Pakistan rupees 12.5 billion) would be • a SuRe Form submitted through the Philippines
required to apply ISSB Standards from fiscal Securities and Exchange Commission Electronic
year 2025; Filing and Submission Tool.

о Phase II—companies meeting two out of three In December 2023 the Philippines Sustainability
criteria (annual revenue >Pakistan rupees Reporting Committee endorsed ISSB Standards
12.5 billion, >500 employees and total assets for use from fiscal year 2025, subject to the
>Pakistan rupees 6.25 billion) would be issuance of regulations or circulars containing
required to apply ISSB Standards from fiscal the jurisdictional roadmap that will be adopted
year 2026; and by Philippine regulators. Earlier application of
ISSB Standards is permitted.65
о Phase III—other listed companies would be
required to apply ISSB Standards from fiscal
year 2027.
The report and recommendations have been
submitted to the ICAP Council and to the
Securities and Exchange Commission of
Pakistan, which have the authority to make
adoption‑related decisions.

63 Institute of Chartered Accountants of Pakistan (ICAP) IFRS Sustainability Disclosure Standards—Study, Consultation and Recommendations for
Implementation in Pakistan, ICAP, 2023, https://www.icap.net.pk/files/sustainabilityreporting/publications/ifrs-sustainability-disclosure-standards-
study-consultation-and-recommendations-for-implementation-in-pakistan.pdf.
64 Securities and Exchange Commission of the Philippines, ‘Request for comments on the draft Memorandum Circular on the Revised Sustainability
Reporting Guidelines for Publicly Listed Companies and the SEC Sustainability Reporting Form (SuRe Form)’, Securities and Exchange
Commission of the Philippines, 2023, https://www.sec.gov.ph/wp-content/uploads/2023/10/2023RFC_SuRe-Guidelines.pdf.
65 Philippines Sustainability Reporting Committee, ‘Endorsement of IFRS S1 General Requirements for the Disclosure of Sustainability-related
Financial Information and IFRS S2 Climate-related Disclosures’, 2023, https://www.pfsrsc.org/wp-content/themes/financialreportca453/pdf/BOA-
Resolution-No-11-Series-of-2024-Adoption-of-IFRS-S1-and-S2.pdf.
Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 135
Singapore Sri Lanka
The Singapore Exchange requires listed issuers In March 2024 the national standard-setter, the
in some industries to provide climate-related Institute of Chartered Accountants of Sri Lanka,
information. issued SLFRS S1 General Requirements for
Disclosure of Sustainability-related Financial
In July 2023 the Accounting and Corporate
Information and SLFRS S2 Climate-related
Regulatory Authority and Singapore Exchange
Disclosures based on ISSB Standards.68
Regulation launched a public consultation on
introducing climate-related disclosure requirements Companies can apply SLFRS S1 and SLFRS S2
in line with the TCFD recommendations and on a voluntary basis for fiscal year 2024. The top
ISSB Standards.66 The consultation proposed 100 publicly listed companies on the main board
expanding the disclosure requirements to all listed will be required to apply SLFRS S1 and SLFRS S2
issuers and large non-listed companies. from fiscal year 2025.
In September 2024 the Singapore Exchange Chinese Taipei
Regulation amended its listing rules to require
From fiscal year 2023 the Financial Supervisory
issuers to provide climate-related disclosures
Commission (FSC) requires banks and insurance
based on ISSB Standards.67
companies to disclose financial information on
Issuers are required to refer to ISSB Standards climate-related risks, taking into account the TCFD
in preparing climate-related disclosures and to recommendations.69
disclose Scope 1 and Scope 2 GHG emissions and
In August 2023 the FSC endorsed ISSB Standards
the measurement approach used, from fiscal year
and released a roadmap for the implementation of
2025, with the expectation that large issuers will be
ISSB Standards in phases:70
required to report on Scope 3 GHG emissions from
fiscal year 2026. • Phase 1—requiring listed companies with more
than NT$10 billion of capital to apply ISSB
Standards from fiscal year 2026;
• Phase 2—requiring listed companies with capital
in the range NT$5–10 billion to apply ISSB
Standards from fiscal year 2027; and
• Phase 3—requiring other listed companies to
apply ISSB Standards from fiscal year 2028.

66 Accounting and Corporate Regulatory Authority and Singapore Exchange Regulation, Consultation Paper—Turning Climate Ambition into Action
in Singapore—Recommendations by the Sustainability Reporting Advisory Committee, Accounting and Corporate Regulatory Authority, 2023,
https://www.acra.gov.sg/docs/default-source/default-document-library/legislation/listing-of-consultation-papers/pubic-consultation-on-srac's-
recommendations/consultation-paper-recommendations-by-srac.pdf.
67 Singapore Exchange, ‘SGX RegCo to start incorporating IFRS Sustainability Disclosure Standards into climate reporting rules’, Singapore
Exchange, 2024, https://www.sgxgroup.com/media-centre/20240923-sgx-regco-start-incorporating-ifrs-sustainability-disclosure.
68 The Institute of Chartered Accountants of Sri Lanka (CA Sri Lanka), ‘Sustainability Disclosure Standards’, CA Sri Lanka, 2024,
https://www.casrilanka.com/casl/index.php?option=com_content&view=article&id=4069&Itemid=341&lang=en.
69 Financial Supervisory Commission (FSC), ‘Press release—The Financial Supervisory Commission promulgated the “Guidelines for Domestic
Banks’ Climate Risk Financial Disclosure”, under which banks shall disclose financial information on climate-related risks starting from 2023’, FSC,
2021, https://www.fsc.gov.tw/en/home.jsp?id=54&parentpath=0,2&mcustomize=multimessage_view.jsp&dataserno=202112230005&dtable=N
ews; FSC, ‘Press release—FSC publishes “Guidelines on Climate-related Financial Disclosures of Insurance Companies” for insurers to begin
disclosure of financial information on climate-related risks starting from 2023’, FSC, 2021, https://www.fsc.gov.tw/en/home.jsp?id=54&parentpath=
0&mcustomize=multimessage_view.jsp&dataserno=202112140009&dtable=News.
70 FSC, ‘Press release—The Financial Supervisory Commission (FSC) releases the roadmap for Taiwan listed companies to align with IFRS
Sustainability Disclosure Standards’, FSC, 2023, https://www.fsc.gov.tw/en/home.jsp?id=54&parentpath=0,2&mcustomize=multimessage_view.js
p&dataserno=202308180001&dtable=News.
Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 136
4.3.5—Europe EU companies are required to apply ESRS, which
are aligned with the TCFD recommendations and
EU ISSB Standards. The first set of ESRS was adopted
In December 2022 the European Parliament in July 2023 by the European Commission, after
and Council approved a sustainability reporting a public consultation.72 In December 2023 the
directive (the Corporate Sustainability Reporting legislation was published in the Official Journal of
Directive or CSRD), which superseded a previous the European Union.
reporting directive.71 The CSRD requires: In February 2024 the European Parliament and
• companies subject to the previous reporting Council agreed to postpone by two years the
directive to report in line with the CSRD from deadline for adopting sector-specific ESRS (from
fiscal year 2024; mid-2024 to mid-2026).73 The deadline was moved
to give companies more time to comply with the
• other large companies to report in line with the
topic standards adopted in July 2023, which apply
CSRD from fiscal year 2025;
to all companies irrespective of their economic
• small and medium-sized public companies to sector. This agreement was among the proposals
report in line with the CSRD from fiscal year included in the 2024 Commission Work Programme
2026; and to reduce administrative burden for companies and
• non-EU companies to report in line with the to cut reporting requirements by 25%.74
CSRD from fiscal year 2028.

71 European Parliament and Council of the European Union, ‘Directive (EU) 2022/2464 of the European Parliament and of the Council of 14
December 2022 amending Regulation (EU) No 537/2014, Directive 2004/109/EC, Directive 2006/43/EC and Directive 2013/34/EU, as regards
corporate sustainability reporting’, Official Journal of the European Union, 16 December 2022, https://eur-lex.europa.eu/legal-content/EN/TXT/
PDF/?uri=CELEX:32022L2464; European Parliament and Council of the European Union, ‘Directive 2014/95/EU of the European Parliament
and of the Council of 22 October 2014 amending Directive 2013/34/EU as regards disclosure of non-financial and diversity information by
certain large undertakings and groups’, Official Journal of the European Union, 15 November 2014, https://eur-lex.europa.eu/legal-content/EN/
TXT/?uri=CELEX:32014L0095.
72 European Commission, ‘The Commission adopts the European Sustainability Reporting Standards’, European Commission, 2023,
https://finance.ec.europa.eu/news/commission-adopts-european-sustainability-reporting-standards-2023-07-31_en; European Commission,
European Sustainability Reporting Standards—First set—Public consultation, European Commission, 2023, https://ec.europa.eu/info/law/better-
regulation/have-your-say/initiatives/13765-European-sustainability-reporting-standards-first-set_en.
73 European Commission, ‘Commission welcomes agreement on postponing adoption deadlines for certain European Sustainability Reporting
Standards’, European Commission, 2024, https://ec.europa.eu/commission/presscorner/detail/en/mex_24_707.
74 European Commission, ‘Delivering today and preparing for tomorrow: The 2024 Commission Work Programme’, European Commission, 2023,
https://ec.europa.eu/commission/presscorner/detail/en/ip_23_4965.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 137

Switzerland Türkiye
Large public companies, banks and insurance In December 2023 the national standard‑setter,
companies are required from fiscal year 2024 Kamu Gözetimi, Muhasebe ve Denetim
to provide disclosures based on the TCFD Standartları Kurumu, announced the adoption
recommendations.75 of ISSB Standards.78 Listed companies that
exceed two of three criteria in two consecutive
In December 2023 the Swiss Stock Exchange
reporting periods (total assets >Turkish lira 500
published a communiqué stating it has
million; annual net sales revenue of >Turkish lira
included ESRS and ISSB Standards in the
1 billion; >250 employees) and banks are required
list of internationally recognised standards for
to apply ISSB Standards from fiscal year 2024.
sustainability reporting under the SIX Exchange
The sustainability-related financial information
Regulation.76 The amendment to the list of
provided by these companies will be subject to
approved standards is effective from fiscal year
mandatory assurance from fiscal year 2025.
2024 and is part of a periodic update of the list by
the SIX Exchange Regulation to take account of UK
international developments.
In May 2024 the UK government published a
In June 2024 the Federal Council proposed to framework for the adoption of ISSB Standards in
extend the application of sustainability-related the UK.
requirements to companies exceeding specific
The UK government aims to endorse ISSB
thresholds from fiscal year 2027. These companies
Standards by the first quarter of 2025, issuing UK
would choose to apply either ESRS or equivalent
Sustainability Reporting Standards.
standards, such as ISSB Standards in combination
with GRI Standards.77 Subject to a positive endorsement decision by the
UK government:
• the Financial Conduct Authority (FCA) will be
able to use the UK Sustainability Reporting
Standards to introduce requirements
for listed companies in the UK to report
sustainability related information; and
• the UK government will decide on disclosure
requirements for companies operating in
the UK that do not fall within the FCA’s
regulatory perimeter.79

75 Federal Council of Switzerland, Ordinance on Climate Disclosures, Federal Council of Switzerland, 2022, https://www.newsd.admin.ch/newsd/
message/attachments/74006.pdf.
76 SIX Exchange Regulation, ‘Updated list of internationally recognized standards for sustainability reporting’, SIX Exchange Regulation, 2023,
https://www.ser-ag.com/dam/downloads/regulation/listing/communiques-six-exchange-regulation/ser202307-en.pdf.
77 Federal Council of Switzerland, Proposed change in the Code of Obligations (transparency about sustainability aspects), Federal Council of
Switzerland, 2024, https://www.admin.ch/gov/de/start/dokumentation/medienmitteilungen/bundesrat.msg-id-101585.html.
78 Kamu Gözetimi, Muhasebe ve Denetim Standartları Kurumu (KGK), ‘COP28 Conference Message from Dr Hasan Özçelik, Chairman of the
Public Oversight Authority’, KGK, 2023, https://www.kgk.gov.tr/Portalv2Uploads/files/Duyurular/v2/Diger/duyuru-05_12_2023%20-%202.pdf.
79 UK Government, ‘Sustainability Disclosure Requirements: Implementation Update 2024’, UK Government, 2024, https://www.gov.uk/government/
publications/sustainability-disclosure-requirements-implementation-update-2024.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 138

Spotlight on the UK

Listed companies and large private companies are required to apply climate-related disclosure rules that are aligned with
the TCFD recommendations and are therefore well positioned to apply ISSB Standards.
UK authorities have set out a pathway towards endorsement and implementation of disclosure requirements for listed
companies and large UK-registered companies referencing ISSB Standards, after they have been endorsed in the UK.

TCFD recommendations ISSB Standards

2019 2020 2021 2022 2023–2024

In its 2019 Green The UK government The FCA extended The UK Parliament The UK government
Finance Strategy, announced its the application of requires listed created a
the UK government intention to make climate-related companies, large mechanism to
created a taskforce TCFD-aligned disclosure private companies assess, adopt
to explore the most disclosures requirements aligned and limited liability and endorse ISSB
effective approach mandatory by 2025, with the TCFD partnerships Standards for use in
to implementing with a significant recommendations with more than the UK by the first
the TCFD portion of mandatory from FY 2022 to: 500 employees quarter of 2025.
recommendations. requirements in (a) issuers of and revenue In November 2023
place by 2023. The standard listed greater than £500 the FCA updated its
UK Taskforce’s shares and global million to provide rules for disclosures
Interim Report and depositary receipts TCFD‑aligned, by asset managers
accompanying representing equity climate-related to their clients and
roadmap set out a shares; and financial disclosures consumers, which
pathway to achieving from FY 2022. build on the TCFD
that goal. (b) asset managers
with >£50 billion recommendations,
The UK Financial in assets under to reference
Conduct Authority management (AUM) ISSB Standards.
(FCA) introduced and asset owners In May 2024 the
new rules for with assets of FCA stated that
companies with a >£25 billion. it will update its
UK premium listing climate‑related
to disclose climate- Organisations with
AUM or assets below disclosure rules
related risks and to reflect ISSB
opportunities in these thresholds
but greater than Standards, after they
line with the TCFD have been endorsed
recommendations on £5 billion are
required to provide in the UK.
a ‘comply or explain’
basis. the disclosures from
FY 2023.

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4.4—Interoperability of ISSB Table 4.4 provides a summary of the climate-
Standards with other standards related disclosure requirements developed by the
ISSB, the EU and the US SEC drawing on the
and initiatives
TCFD recommendations and how they compare
4.4.1—Introduction with the TCFD recommendations.

The ISSB was formed to develop—in the public

interest—a comprehensive global baseline
of high-quality sustainability disclosures to
meet investors’ information needs. Some other
organisations had already developed, or were in
the process of developing, standards before the
ISSB was created. To ensure that investors receive
comparable information, and to limit the burden
and costs for companies, interoperability between
ISSB Standards and other initiatives is important.
The TCFD recommendations have been a driver
of greater consistency among the major climate-
related disclosure regimes that were already
in effect when the TCFD was created. The
recommendations have also enhanced consistency
among the climate-related disclosure requirements
and standards that have been developed more
recently, such as:
• IFRS S1 and IFRS S2;
• ESRS adopted by the European Commission in
July 2023;80 and
• the final climate disclosure rule issued by the
US SEC in March 2024.81

The shared foundation on the

TCFD recommendations helps to ensure that
ISSB Standards are interoperable with ESRS
and the US SEC climate rule.

80 European Commission, ‘Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing Directive 2013/34/EU of the
European Parliament and of the Council as regards sustainability reporting standards’, European Commission, 2023, https://eur-lex.europa.eu/
legal-content/en/TXT/?uri=CELEX:32023R2772. In December 2023 the legislation adopting the European Sustainability Reporting Standards
was published in the Official Journal of the European Union.
81 US Securities and Exchange Commission (US SEC), ‘The Enhancement and Standardization of Climate-related Disclosures for Investors—Final
Rules’, US SEC, 2024, https://www.sec.gov/files/rules/final/2024/33-11275.pdf. On 4 April 2024 the US SEC issued an order to stay the rule,
pending completion of an ongoing judicial review.

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Table 4.4—Comparison between TCFD recommendations, ISSB Standards, ESRS and the US SEC
climate rule

TCFD recommendations ISSB Standards ESRS US SEC climate rule

Scope Climate-related risks Sustainability: Sustainability: Climate-related risks

• general principles • core principles
for disclosing for disclosing
information about information
sustainability- • detailed requirements
related risks and for sustainability-
opportunities related impacts, risks
• topic-specific and opportunities
standard on climate-
related risks and
opportunities
Date of publication June 2017 June 2023 July 2023 March 2024
Focus(a) Investor focus Investor focus Multi-stakeholder focus, Investor focus
including investors
Companies applying Vary by jurisdictions Vary by jurisdictions EU companies (from Most US SEC
the recommendations fiscal year 2024) registrants, including
or the requirements foreign private issuers
(from fiscal year 2025)
Information included in Not prescribed No, but permitted via No, but permitted Yes, for particular
the company’s financial cross-references via incorporation by information
statements? reference
Information included in Not prescribed Yes—flexible location Yes, within the Yes, in its annual report
the company’s annual within general purpose management report or incorporated by
report? financial reports reference from another
filing with the US SEC
Information published Not prescribed Yes Yes Yes, other than GHG
at the same time as the emissions disclosures,
financial statements? which may be filed on a
delayed basis
Are industry-specific No Yes Yes—industry-specific No
disclosures required? standards expected
in the future; in the
meantime companies
can complement their
disclosures using
IFRS industry-based
guidance and GRI
Sector Standards

continued ...

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 TCFD recommendations ISSB Standards ESRS US SEC climate rule

Is disclosure of GHG No—recommended Yes—Scope 1, Scope 2 Yes—Scope 1, Scope 2 Yes—Scope 1 and

emissions required? and Scope 3 and Scope 3 Scope 2 only
(a) T
 CFD-aligned disclosure requirements specify how companies determine materiality for climate-related reporting purposes. In its 2017
status report, the TCFD stated that companies should determine materiality for climate-related issues in a way that is consistent with how
they determine the materiality of other information included in their annual financial filings (that is, financial materiality). The EU has issued
a directive that requires companies to report information from a double materiality perspective whereby companies are required to report
the information necessary to understand their respective developments, financial performance and positions (financial materiality) as well
as the impact of their activities on environmental, social and employee matters, respect for human rights, anti-corruption and bribery matters
(impact materiality).

4.4.2—Interoperability between ISSB The Interoperability Guidance describes how

Standards and ESRS disclosure requirements are aligned between the
standards, including the requirements in IFRS S2
The ISSB and the European Commission, together
that have corresponding disclosure requirements
with EFRAG, have worked together during the
in ESRS. The Interoperability Guidance lists
development of ESRS and ISSB Standards
the information that a company starting with
to ensure their standards are highly aligned,
each set of standards needs to know to enable
with a specific focus on the requirements for
compliance with both sets of standards, ensuring
climate‑related disclosures.
interoperability between them.
In May 2024 the IFRS Foundation and
The Interoperability Guidance also sets out the
EFRAG published the ESRS–ISSB Standards
additional disclosures that a company applying
Interoperability Guidance to illustrate the alignment
IFRS S2 would need to provide to comply with the
between ISSB Standards and ESRS and to show
climate-related disclosure requirements in ESRS.
how a company can apply both sets of standards.
The Interoperability Guidance includes detailed
analysis of how the requirements for climate‑related Regardless of whether it starts with
disclosures are aligned. ESRS or ISSB Standards, a company
can comply with the climate requirements
Key takeaways in both sets of standards by following
directions in the ESRS–ISSB Standards
1 The definition of ‘financial materiality’ in Interoperability Guidance.
ESRS is aligned with the definition of
‘materiality’ in ISSB Standards.
Table 4.5 summarises areas of climate-related
2 The two sets of standards include disclosures for which companies need to consider
commonly defined terms as appropriate. additional information when applying both ISSB
Standards and ESRS to comply with both sets of
3 Almost all the requirements in ISSB standards.
Standards related to climate-related
financial disclosures are included in
ESRS.

4 Additional climate-related disclosure

requirements in ESRS are explained in
the Interoperability Guidance.

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Table 4.5—Areas for which companies applying both ISSB Standards and ESRS need to consider
additional information to comply with both sets of standards

Companies starting with ESRS that also Companies starting with ISSB Standards
want to comply with ISSB Standards that also want to comply with ESRS

Scenario analysis Scenario analysis

GHG emissions—disaggregation GHG emissions—disaggregation

Carbon credits Carbon credits

Quantitative information on
Transition plan assumptions
anticipated financial effects

Climate-related physical and

Industry-based metrics
transition risks

Climate-related opportunities GHG emissions reduction targets

Organisational boundary for

Capital deployment
GHG emissions

A broad range of incremental

Financed emissions
disclosures

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 143

4.4.3—Interoperability between In the past 12 months, the IFRS Foundation
ISSB Standards and GRI Standards and the Global Reporting Initiative (GRI) have
continued to coordinate work programmes and
GRI Standards are well established sustainability
standard-setting activities.
reporting standards focusing on reporting impacts
on the environment and society. Companies that Table 4.6 provides an overview of their activities,
apply GRI Standards are geographically diverse and including the announcement in May 2024
many of these companies are in emerging markets. of agreement to work to consider full direct
ISSB Standards and GRI Standards can be used interoperability between GRI Standards and
together to facilitate reporting on a company’s ISSB Standards.
impacts, risks and opportunities, including risks that
arise from the company’s impacts.

Table 4.6—Collaboration between the IFRS Foundation and GRI

Area Description

Educational In January 2024 GRI and the IFRS Foundation published Interoperability
material considerations for GHG emissions when applying GRI Standards and
ISSB Standards.
The document illustrates the areas of interoperability a company should consider
when measuring and disclosing Scope 1, Scope 2 and Scope 3 GHG emissions
in accordance with both GRI 305 Emissions 2016 (GRI 305) and IFRS S2. The
requirements in GRI 305 and IFRS S2 are highly aligned—for example, both draw
on the GHG Protocol. The alignment means companies that already disclose
Scope 1, Scope 2 and Scope 3 GHG emissions using the GRI Standards are
well positioned to report information about GHG emissions in accordance with
IFRS S2. Other GHG emissions disclosures can also be aligned with IFRS S2,
depending on the choices a company makes in applying GRI 305 and IFRS S2.

Capacity In November 2023 GRI announced the launch of the Sustainability Innovation
building Lab based in Singapore, in coordination with the IFRS Foundation. This lab brings
together global and local partners to advance capabilities for reporting using GRI
Standards and ISSB Standards.

Coordination In March 2022 the IFRS Foundation and GRI announced an agreement to
of work coordinate the work programmes and standard-setting activities of their boards,
programmes the ISSB and the Global Sustainability Standards Board (GSSB). In October 2023
the ISSB received a work programme update from representatives of the GSSB.

Full direct In May 2024 the ISSB and the GSSB committed to jointly identify and align
interoperability common disclosures that provide needed information under the distinct scopes
and purposes of their respective standards, for both thematic and sector-based
standard-setting.

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4.5—Collaboration between the ISSB • the Taskforce on Nature-related Financial
and other organisations Disclosures (TNFD), which has developed
disclosure recommendations and guidance
The ISSB also collaborates with other that encourage and enable companies to
organisations, such as: assess, report and act on their nature‑related
• the International Public Sector Accounting dependencies, impacts, risks and
Standards Board, which is working to advance opportunities. The ISSB agreed to consider
public sector sustainability reporting and intends the TNFD recommendations in its research
to build on IFRS S2 and GRI climate-related on disclosure about a company’s risks and
topic standards to develop the first public sector- opportunities associated with biodiversity,
specific sustainability reporting standard. ecosystems and ecosystem services that forms
part of the ISSB new two-year work plan.
• the Basel Committee on Banking Supervision
and the International Association of • CDP, which is the ISSB’s key global climate
Insurance Supervisors, which are working disclosure partner providing a trusted tool that
on climate-related disclosure frameworks for supports companies on their path to compliance
banks and insurers. In November 2023 the with ISSB Standards. In June 2024 CDP opened
Basel Committee on Banking Supervision its new platform to 75,000 organisations.
proposed qualitative and quantitative disclosure CDP’s 2024 questionnaire is aligned with
requirements based on IFRS S2 to provide a IFRS S2 as the foundational baseline for CDP’s
common disclosure baseline for internationally climate disclosure.
active banks.82 • GHG Protocol, which is responsible for the
• the International Auditing and Assurance GHG Protocol Corporate Standard (2004) that
Standards Board and the International Ethics companies applying IFRS S2 are required to use
Standards Board for Accountants, which are for the measurement of their GHG emissions.
working to enhance standards to support the The ISSB is actively engaged in updates and
assurance of sustainability-related information. decisions made in relation to the GHG Protocol
standards and guidance. A representative of
the ISSB is an observer on the GHG Protocol
Independent Standards Board.

82 Basel Committee on Banking Supervision (BCBS), ‘Disclosure of climate-related financial risks’, BCBS, 2023, https://www.bis.org/bcbs/publ/d560.pdf.

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SECTION 5—NEXT STEPS AND 5.1.2—Guidance
AREAS OF CONTINUED FOCUS OR The TCFD concluded that its efforts to
FURTHER WORK support companies in implementing the
recommendations—through the development
5.1—Update on areas of continued of guidance, case studies and examples of
focus and further work identified by disclosure—helped drive greater adoption of the
TCFD recommendations and better disclosure over
the TCFD
time. The TCFD therefore encouraged the ISSB
In October 2023 the TCFD issued its final status and other appropriate bodies to continue this type
report and concluded its work. In its 2023 status of work.
report the TCFD considered areas that warrant
The TCFD saw the need for additional guidance in
continued focus or further work by the ISSB or
areas such as:
other appropriate bodies. This section summarises
progress on these areas since the TCFD 2023 • physical-risk assessment and adaptation
status report. planning;
• climate-related scenario analysis; and
5.1.1—Interoperability
• Scope 3 GHG emissions.
The TCFD concluded that ensuring ISSB
Standards are interoperable with jurisdictional The ISSB continues to prioritise supporting the
frameworks is critical. In particular, the TCFD implementation of ISSB Standards to help ensure
emphasised the importance of consistent company companies, regulators and other stakeholders are
reporting among jurisdictions and avoiding the well prepared to use ISSB Standards. This support
need for companies to report through more than includes educational activities, educational material
one disclosure framework. (for example, for disclosure about transition
plans) and advancing the IFRS Foundation’s
The IFRS Foundation and the ISSB are working
capacity‑building programme.
to support the adoption of ISSB Standards. The
Jurisdictional Guide intends to bring transparency The IFRS Foundation and its supporting partners
on the level of compliance of the local standards have developed several educational resources
with ISSB Standards. Consistency in company for preparers of sustainability-related financial
and jurisdictional reporting and avoidance of disclosures, such as a course for intermediate
duplicative reporting is best achieved when preparers that the Foundation has developed with
companies use ISSB Standards and jurisdictions the United Nations Sustainable Stock Exchanges
adopt ISSB Standards without modifications, while Initiative and the Fundamentals of Sustainability
potentially building from them for their own broader Accounting (FSA) Credential® designed for
reporting objectives. When this is not the case, all professionals who would benefit from
the ISSB works to ensure the ISSB Standards are understanding the link between sustainability and
interoperable with the work of others. financial performance.

In the case of ESRS and the US SEC climate rule,

their use of the TCFD recommendations facilitates
interoperability with ISSB Standards. Section
4.4—Interoperability of ISSB Standards with other
standards and initiatives discusses progress in
enhancing the interoperability of ISSB Standards
with other standards and initiatives.

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The IFRS Sustainability knowledge hub, which • companies should disclose the resilience of
is a key component of the IFRS Foundation’s their strategies under different climate-related
capacity‑building programme, hosts content scenarios, including a scenario aligned with
developed by the IFRS Foundation and more the latest international agreement on climate
than 100 resources developed by third-party change, including a 2°C or lower scenario (that
organisations. Content is added over time in is, a scenario aligned with the latest international
response to market needs and emerging practices. agreement on climate change);83 and
For example, in 2024 the IFRS Foundation
• investors and other stakeholders use such
developed educational material relating to current
information to inform their expectations
and anticipated financial effects, in the form
regarding the future performance of companies.
of webcasts.
As discussed in Section 1.2—TCFD-aligned
The IFRS Sustainability knowledge hub contains
reporting by public companies, the resilience
the disclosure-specific materials developed by
of companies’ strategies under different
the Transition Plan Taskforce, for which the
climate‑related scenarios remains the least
IFRS Foundation has assumed responsibility
disclosed recommended disclosure for both
in 2024. The IFRS Foundation expects to use
2022 and 2023, with 11% of companies reviewed
these materials to develop educational materials,
disclosing this information in 2023.
ensuring that they do not change the requirements
in IFRS S2, by tailoring them to ensure global As discussed in Section 2.2—Reconciliation
applicability and to deliver full compatibility with the between TCFD recommendations and requirements
global baseline and IFRS S2’s focus on disclosures in ISSB Standards, IFRS S2 is broadly consistent
of the climate-related risks and opportunities with TCFD recommended disclosure c) about
affecting a company’s prospects, to meet the describing the resilience of a company’s strategy.
needs of investors and the global markets. However, IFRS S2 does not specify particular
scenarios for a company to use in its climate‑related
5.1.3—Disclosing resilience of strategy under scenario analysis. IFRS S2 requires a company
different climate-related scenarios to select scenarios that are relevant to its
circumstances in order to provide useful information
Regarding the TCFD recommended disclosures
to users of general purpose financial reports and
on the resilience of a company’s strategy under
to explain which climate-related scenarios it has
different climate-related scenarios the TCFD
used, including whether they are related to transition
emphasised that:
or physical risks and whether the company used,
• a company’s disclosure of how its strategy might among its scenarios, a climate-related scenario
change to address potential climate-related risks aligned with the latest international agreement on
and opportunities is key information to better climate change.
understand the potential implications of climate
change for the company;

83 The TCFD used the phrase ‘a 2°C or lower scenario’ in its report based on the Paris Agreement and viewed the phrase ‘a scenario aligned with
the latest international agreement on climate change’ as consistent with its intent in using ‘a 2°C or lower scenario’.

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The ISSB recognised a need to provide guidance by work under way in 2023—such as that by
for climate-related scenario analysis, especially the TNFD to develop a risk management and
for companies with fewer skills, capabilities or disclosure framework on nature-related risks and
resources. The application guidance accompanying by the Science Based Targets Network to develop
IFRS S2 is designed to support a company corporate science-based targets for nature—and
in determining an approach to climate-related recognised that such areas warrant continued
scenario analysis that is commensurate with its attention.
circumstances, drawing on the range of practice
In December 2023 the IFRS Foundation published
outlined in documents published by the TCFD,
Educational material—Nature and social aspects
including Technical Supplement: The Use of
of climate-related risks and opportunities as part
Scenario Analysis in Disclosure of Climate‑related
of its efforts to support companies in applying
Risks and Opportunities and Guidance on
IFRS S1 and IFRS S2. The educational material
Scenario Analysis for Non-Financial Companies.84
illustrates how nature and social aspects can be
The application guidance in IFRS S2 requires a
relevant climate-related risks and opportunities
company to use an approach to climate-related
using three examples that illustrate disclosures
scenario analysis that enables it to consider all
when applying IFRS S2.
reasonable and supportable information that
is available to the company at the reporting IFRS S1 already requires a company to disclose
date without undue cost or effort, taking into material information about the sustainability-
consideration: related risks and opportunities reasonably
expected to affect its prospects and to provide
• the company’s exposure to climate-related risks
information about connections between various
and opportunities; and
sustainability‑related risks and opportunities.
• the skills, capabilities and resources available
In 2024 the ISSB agreed on its future work plan.
to the company to enable it to carry out the
That work plan includes work to enhance the
climate‑related scenario analysis.
SASB Standards, which provide information
Additional resources about scenario analysis are on a range of sustainability-related risks and
available in the IFRS Sustainability knowledge hub. opportunities. The work plan also includes
projects to research disclosure about risks and
5.1.4—Decision-useful disclosure on other opportunities associated with:
sustainability topics
• biodiversity, ecosystems and ecosystem
The TCFD recognised that several other services; and
sustainability-related issues—such as biodiversity,
• human capital.
water and social issues—might warrant further
consideration by the appropriate bodies in terms This research is considering additional specific
of promoting decision-useful disclosure. These disclosure requirements that would complement
issues might also have links with climate-related the requirements in IFRS S1.
issues that are important for investors and others to
consider—for example, in the context of companies’
transition plans. The TCFD was encouraged

84 TCFD, Technical Supplement: The Use of Scenario Analysis in Disclosure of Climate-related Risks and Opportunities, TCFD, 2017,
https://assets.bbhub.io/company/sites/60/2021/03/FINAL-TCFD-Technical-Supplement-062917.pdf, and TCFD, Guidance on Scenario Analysis
for Non-Financial Companies, TCFD, 2020, https://assets.bbhub.io/company/sites/60/2020/09/2020-TCFD_Guidance-Scenario-Analysis-
Guidance.pdf.

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5.1.5—Climate-related disclosure by improve investors’ ability to appropriately assess
sovereigns and price their climate-related risks and effectively
allocate capital.
The TCFD expected that the issuance of ISSB
Standards in June 2023 and various jurisdictions’ In June 2023 the IPSASB announced it would
efforts to require climate-related financial begin developing the first sustainability reporting
disclosures would lead to further progress. standard for the public sector on climate-related
disclosures.85 The project overview states that the
The TCFD was encouraged, for example, by the
standard would be based on IFRS S2.86
International Public Sector Accounting Standards
Board’s (IPSASB) plans to develop a climate‑related In June 2024 the IPSASB announced that the
disclosure standard for the public sector. World Bank is supporting the development of
the climate-related disclosures standard for the
IPSASB climate-related disclosure standard public sector.87
In May 2022 the IPSASB published a consultation In October 2024 the IPSASB published a draft
paper seeking feedback on developing public standard for consultation, building on IFRS S2.
sector sustainability reporting guidance, which it
proposed to align with the ISSB’s work and the 5.2—Next steps
TCFD recommendations.
The introduction of sustainability-related disclosure
In June 2023 the IPSASB announced its decision requirements into regulatory frameworks through
to develop a climate-related disclosure standard the adoption or other use of ISSB Standards
for the public sector. The IPSASB said that there supports the provision of more comparable and
was ‘strong global stakeholder support for the reliable information about sustainability-related
proposals in its consultation paper’, with substantial risks and opportunities for global capital markets.
support for developing guidance on climate-related
disclosures first. The progress towards use of ISSB Standards
by companies and adoption of ISSB Standards
The TCFD was encouraged by the IPSASB’s by jurisdictions is expected to be beneficial to
efforts and was of the view that developing a the increased specificity about the information
consistent climate-related financial disclosure to be provided, the links to information in the
framework for sovereigns—consistent with the financial statements and the trend towards
TCFD recommendations and ISSB Standards, disclosure being required to be provided rather
as appropriate—was important for both preparers than being recommended or subject to ‘comply or
and users of climate-related financial disclosures. explain’ approaches.
Consistent and comparable reporting by
sovereigns would support companies in preparing
comprehensive TCFD-aligned disclosures and
transition plans that appropriately reflect their
operating environment. Such reporting would also

85 International Public Sector Accounting Standards Board (IPSASB), ‘IPSASB begins development of climate-related disclosures standard for the
public sector’, IPSASB, 2023, https://www.ipsasb.org/news-events/2023-06/ipsasb-begins-development-climate-related-disclosures-standard-
public-sector.
86 IPSASB, Climate-related Disclosures—Project Brief and Outline, IPSASB, 2023, https://ifacweb.blob.core.windows.net/publicfiles/2023-06/
Final%20Draft%20Climate-related%20Disclosures%20Project%20Brief%20-%20Clean.pdf.
87 IPSASB, ‘IPSASB developing the first public sector sustainability reporting standard with support from the World Bank’, IPSASB, 2024,
https://www.ipsasb.org/news-events/2024-06/ipsasb-developing-first-public-sector-sustainability-reporting-standard-support-world-bank.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 149

As more jurisdictions progress in the introduction The IFRS Foundation has published the Inaugural
of sustainability-related financial disclosures and Jurisdictional Guide for the adoption or other
more companies start to implement regulatory use of ISSB Standards to support jurisdictions in
requirements, it remains paramount that investors’, balancing jurisdictional considerations (including
lenders’ and other creditors’ information needs their approach to scaling and phasing in of
are met. requirements) and to promote less variation in how
ISSB Standards are adopted or otherwise used
Fragmentation in regulatory requirements caused
to reduce fragmentation in sustainability-related
by jurisdictional modifications to ISSB Standards,
disclosure requirements.
in particular modifications that result in removing
or excluding requirements in ISSB Standards, The degree to which the jurisdictional disclosure
could conflict with the objective of delivering requirements are aligned with ISSB Standards is
timely and comparable sustainability-related an aspect to monitor to assess progress towards
financial information to capital markets. This globally comparable information for capital markets.
fragmentation adds complexity to those using the
External high-quality assurance plays a vital role
information and adds costs and complexities to
in enhancing trust and confidence in the integrity
preparers of information subject to inconsistent
and reliability of sustainability-related financial
regulatory requirements.
information. Enhancing the quality of disclosures
by introducing assurance requirements is also an
area to monitor in the future.

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APPENDIX 1—COMPANY SELECTION • identifying public companies—those with
AND AI REVIEW METHODOLOGY publicly traded debt or equity—in the eight
industries and their sub-industries outlined in
Table A.1. These sub-industries are based on
A1.1—Companies included in the
the Global Industry Classification Standard
review (GICS®) subsectors and industries.88
The IFRS Foundation used AI technology to • identifying public companies in specific
examine financial filings, annual reports, integrated indexes to provide coverage of large, medium
reports, sustainability reports and other relevant and small market capitalisation companies.
documents from public companies in five regions The specific indexes used were S&P Global
spanning eight industries. All industries covered 1200, S&P Global MidCap and S&P Global
correspond to the industries in the TCFD 2023 SmallCap.
status report.
• removing subsidiaries to prevent duplicate
These industries include: observations. Companies sharing the same
• banking; industry and ultimate parent for capital structure
considerations were identified, with preference
• insurance;
given to the company with the highest annual
• energy; revenue (for non-financial industries) or total
• materials and buildings; assets (for financial industries). This approach
aimed to minimise the inclusion of subsidiaries’
• transportation; annual reports.
• agriculture, food and forest products; • removing companies without available
• technology and media; and annual reports for the fiscal years 2022
and 2023 to ensure uniformity in the
• consumer goods.
dataset and consistent reporting for the two
In selecting the population of companies consecutive years.
for the AI review (see Section 1.2—TCFD-
• removing companies lacking reports
aligned reporting by public companies), the
in English.
IFRS Foundation aimed to maintain consistency
with the sample selection process used in This methodology resulted in a final dataset
the TCFD 2023 status report. Specifically, the comprising 3,814 unique companies and
methodology employed for this report involved: corresponding to 25,127 reports in 2022 and
26,637 reports in 2023. The company distribution
by industry is summarised in Table A.1.

88 In March 2023 the Global Industry Classification Standard’s industry classifications were changed. These changes were considered in this year’s
report when grouping companies into industries. See S&P Dow Jones Indices, ‘S&P Dow Jones Indices and MSCI announce revisions to the
Global Industry Classification Standard (GICS®) structure in 2023’, S&P Global, 2022,
https://www.msci.com/documents/1296102/29559863/GICS_Press_Release_31_March_2022.pdf/f0ac4118-d6c3-4456-3c7b-
2b0174099e4e?t=1648760411652.

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Table A.1—Industry and sub-industry of companies selected for review for fiscal years 2022
and 2023

Industries Sub-industries

Banking • Regional banks • Investment and asset

534 companies • Large, diversified banks management firms

Insurance • Multi-line insurance • Life and health insurance

150 companies • Property and casualty • Reinsurance
insurance

Energy • Oil and gas • Utilities

444 companies • Coal

Materials and buildings • Chemicals • Metals and mining

1,398 companies • Construction materials • Real estate management
and development
• Capital goods

Transportation • Air freight • Rail transportation

242 companies • Passenger air transportation • Trucking services
• Maritime transportation • Automobiles

Agriculture, food and forest products • Beverages • Packaged foods and meats
288 companies • Agriculture • Paper and forest products

Technology and media • Technology hardware and • Interactive media and services
364 companies equipment

Consumer goods • Consumer retailing • Textiles and apparel

394 companies

Total: 3,814 companies

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A1.2—Documents reviewed
Key terms
The IFRS Foundation focused on companies’
financial filings, annual reports, integrated reports, Sustainability report
sustainability reports and other relevant reports A report that provides information about a
for fiscal years 2022 and 2023. These documents company’s effect on society, often addressing
were identified using the Bloomberg Terminal. environmental, social and governance issues.
Corporate social responsibility and
Key terms environmental, social and governance reports
are examples of sustainability reports.
Financial filing
An annual reporting package in which a Other relevant reports
company is required to deliver its audited Reports that describe how climate change
financial results under the corporate, might affect a company’s business, strategies
compliance or securities laws of the or financial planning, including those focused
jurisdiction or jurisdictions in which it operates. on the TCFD recommendations.
Although reporting requirements vary
internationally, financial filings generally contain
financial statements and other information A1.3—Methodology to review
such as governance statements and companies’ publicly available reports
management commentary.
AI technology was used to analyse publicly
10-Ks, 20-Fs, annual reports and registration available reports for the population of companies
documents are examples of general purpose included in the review.89
financial reports.
The objective of the AI review was to automatically
Annual report detect information in financial filings and other
A report that describes a company’s activities company reports that aligned with one or more of
for the preceding year. the 11 TCFD recommended disclosures (referred
to as TCFD-aligned disclosures). Designing
Integrated report an automated AI system to review company
A concise communication about how a reports for detecting TCFD-aligned disclosures
company’s strategy, governance, performance is challenging due to variations in language and
and prospects lead to the creation of value over semantics among jurisdictions, sectors and even
the short, medium and long term. companies within the same sector. To mitigate
these challenges, the AI technology used language
models capable of mathematically representing
entire sentences and paragraphs and capturing
contextual meaning.

89 The IFRS Foundation acknowledges the support of Bloomberg Philanthropies in connection with this report. Neither the IFRS Foundation,
Bloomberg Philanthropies nor their affiliates provide any guarantee or representation as to the correctness or completeness of any part of this
work; nor shall any such party be responsible for or have any liability to any person whatsoever with respect thereto.

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The AI technology used a language model trained documents. Due to the considerable volume
to identify TCFD-aligned information based on of text segments, a ‘prefilter’ was used to
a deep learning natural language processing pinpoint text segments and tables containing
model known as Robustly Optimized Bidirectional specific keywords and phrases that could
Encoder Representations from Transformers suggest the potential presence of TCFD-aligned
Pretraining Approach (RoBERTa).90 RoBERTa information.91 This pre‑filter significantly reduced
encodes text and represents it mathematically the computational cost of analysing thousands
based on context, allowing it to infer the meaning of reports. The text segments identified by the
of words based on their context. For example, pre-filter were then fed into the trained language
RoBERTa can distinguish between the word model, which evaluated their alignment with the
‘cement’ in phrases like ‘GHG emissions per ton 11 recommended disclosures.
cement’ and ‘cement our approach’ by considering
their respective contexts, thus enhancing
A1.5—Performance validation
classification accuracy. The performance of the AI model was evaluated by
A language model built using the RoBERTa comparing its predictions with human-annotated
architecture was trained with a proprietary labels on a set of text passages. This evaluation
dataset comprising climate-related texts and set was processed through the model only once to
passages identified as aligning with the 11 TCFD ensure that the model’s predictions were unbiased.
recommended disclosures (referred to as If the model’s classification of a passage matched
labelled data). Subject-matter experts developed the label, it was considered correctly classified.
descriptions and definitions for each of the Two key metrics—recall and precision—were used
11 recommended disclosures and trained human to gauge model performance. ‘Recall’ measures
annotators to classify text passages accordingly. the proportion of true positives captured by the
After ensuring satisfactory performance, annotators model—that is, how many of the TCFD-aligned
reviewed a large sample of text passages and passages in the test pool the model was able
labelled them accordingly, with oversight from to identify correctly as TCFD-aligned. ‘Precision’
subject-matter experts. measures the proportion of positive model
predictions that are true positives—that is, how
A1.4—Review of company reports many of the predicted TCFD-aligned passages are
In the review process, a separate AI model actually TCFD-aligned.
integrated with computer vision techniques
extracted text segments from the available
documents. This model facilitated the identification
of paragraphs and enabled some types of
information, such as data within tables, to be
treated as text. The AI model detected millions
of text segments and tables in the available

90 Y. Liu, M. Ott, N. Goyal, J. Du, M. Joshi, D. Chen, O. Levy, M. Lewis, L. Zettlemoyer and V. Stoyanov, ‘RoBERTa: A Robustly Optimized BERT
Pretraining Approach’ arXiv, July 2019, 10.48550/arXiv.1907.11692.
91 For instance, ‘Board of Directors also oversees climate-related issues’ was one phrase used to identify a potential disclosure of Governance a).
Many phrases were included to ensure all relevant content was detected. The prefilter was designed with support from subject-matter experts.

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The F1 score, which is the harmonic mean of A1.7—Limitations of the analyses
precision and recall, serves as an indicator of
The results of this report are subject to some
model performance and is commonly used in
limitations. Readers should note that:
machine learning evaluations. The F1 scores
of the model and the human reviewers for the • although the model was adjusted to maximise
11 recommended disclosures are presented in its performance, the AI classifications are not
Figure A2-2 of the TCFD 2023 status report.92 perfectly accurate. As such, the documented
A trade-off between precision and recall is often levels of disclosure and trends are not perfectly
inevitable. Adjusting the model to be more stringent accurate.
in classifying a passage as a relevant disclosure • the AI review was not designed to assess the
can enhance precision but might reduce recall. quality of companies’ climate-related financial
For this report, the model was adjusted to ensure disclosures but instead to assess the alignment
that precision matched recall, thus avoiding bias. of company disclosures with the TCFD
However, for Strategy a) qualitative ‘manual’ recommendations. Thus, the quality of reporting
reviews found that the pre-filter failed to identify cannot be inferred from the documented results.
some types of disclosures. To mitigate bias and
maintain a balance between precision and recall, • the AI review includes only companies with
the model was tuned to require high recall, which reports in English because the AI technology
lowered the F1 score for Strategy a) to 0.58. cannot process reports in languages other than
English. Thus, the documented results cannot
A1.6—Outcome be generalised to non-English reports.

The AI technology was applied to the excerpts • the results of this year’s report might not be
from the reports of the reviewed companies. directly comparable to the results in the TCFD
If a company had a text paragraph in any of its 2023 status report as this year’s sample
reports for a given fiscal year that was classified of reviewed companies is bigger than the
as aligning with one of the 11 recommended expanded set of companies analysed in the
disclosures, the company was classified as TCFD 2023 status report. In addition, this year’s
reporting in line with that specific recommended report used a different definition of regions.
disclosure for that year. The results for
company‑level documents were aggregated for the
main analyses.

92 TCFD, Task Force on Climate-related Financial Disclosures: 2023 Status Report, TCFD, 2023, https://www.fsb.org/wp-content/uploads/P121023-2.pdf.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 155

APPENDIX 2—GLOSSARY AND LIST OF ACRONYMS
This glossary contains short definitions of terms used in this document.

Term Description

adoption The range of approaches that a competent regulatory authority in a jurisdiction may take to
or other adopt, apply or otherwise be informed by ISSB Standards when introducing sustainability-related
use of ISSB disclosure requirements in the jurisdiction’s legal and regulatory framework. This range includes
Standards approaches that involve the adoption or other use of IFRS S1 and IFRS S2 directly, as well as the
introduction of local sustainability-related disclosure requirements (or standards) designed to deliver
functionally aligned outcomes to those resulting from the application of IFRS S1 and IFRS S2.

annual report A report that describes a company’s activities for the preceding year.

climate-related Climate-related risks refer to the potential negative effects of climate change on a company. These
risks and risks are categorised as climate-related physical risks and climate-related transition risks.
opportunities
Climate-related opportunities refer to the potential positive effects arising from climate change for a
company. Efforts to mitigate and adapt to climate change can produce climate-related opportunities
for the company.

digital financial A report in a computer-readable, structured data format.

report

ESG Environmental, social and governance.

ESRS European Sustainability Reporting Standards.

FSB Financial Stability Board.

financial filing An annual reporting package in which a company is required to deliver its audited financial results
under the corporate, compliance or securities laws of the jurisdictions in which it operates. Although
reporting requirements vary internationally, financial filings generally contain financial statements
and other information such as governance statements and management commentary.

financial A particular form of general purpose financial reports that provide information about a company’s
statements assets, liabilities, equity, income and expenses.

general Reports that provide financial information about a company that is useful to existing and potential
purpose investors, lenders, and other creditors in making decisions relating to providing resources to the
financial company. Those decisions involve decisions about:
reports
(a) buying, selling or holding equity and debt instruments;
(b) providing or selling loans and other forms of credit; or
(c) e
 xercising rights to vote on, or otherwise influence, the company’s management’s actions that
affect the use of the company’s economic resources.
General purpose financial reports include—but are not restricted to—a company’s general purpose
financial statements and sustainability-related financial disclosures.

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 156

Term Description

greenhouse The disclosure of GHG emissions is classified into Scope 1, Scope 2 and Scope 3. Scope 1
gas (GHG) emissions are emissions that a company makes directly. Scope 2 emissions are indirect emissions
emissions from the generation of purchased energy consumed by the company. Scope 3 emissions are all
other indirect emissions that occur in the company’s value chain.

GICS® Global Industry Classification System®.

GRI Global Reporting Initiative.

IAASB International Auditing and Assurance Standards Board.

ISSB IFRS Sustainability Disclosure Standards issued by the International Sustainability

Standards Standards Board.

investors Primary users of general purpose financial reports—that is, existing and potential investors, lenders
and other creditors.

integrated A concise communication about how a company’s strategy, governance, performance and prospects
report lead to the creation of value over the short, medium and long term.

latest An agreement by states, as members of the United Nations Framework Convention on Climate
international Change, to combat climate change. The agreements set norms and targets for a reduction in
agreement on greenhouse gases.
climate change

scenario A process for identifying and assessing a potential range of outcomes of future events under
analysis conditions of uncertainty.

SICS® Sustainable Industry Classification System®.

sustainability A report that provides information about a company’s effect on society, often addressing
report environmental, social and governance issues.

TCFD Task Force on Climate‑related Financial Disclosures. The TCFD completed its work and disbanded
in October 2023.

TNFD Taskforce on Nature-related Financial Disclosures.

US SEC US Securities and Exchange Commission.

users of Primary users of general purpose financial reports—that is, existing and potential investors, lenders
general and other creditors.
purpose
financial
reports

Progress on Corporate Climate-related Disclosures—2024 Report | November 2024 | 157

APPENDIX 3—REFERENCES
Accounting and Corporate Regulatory Authority and Singapore Exchange Regulation, Consultation
Paper—Turning Climate Ambition into Action in Singapore—Recommendations by the Sustainability
Reporting Advisory Committee, Accounting and Corporate Regulatory Authority, 2023,
https://www.acra.gov.sg/docs/default-source/default-document-library/legislation/listing-of-consultation-
papers/pubic-consultation-on-srac's-recommendations/consultation-paper-recommendations-by-srac.pdf.
Advisory Committee on Sustainability Reporting (ACSR), Public Consultation Paper no. 12024—Proposed
National Sustainability Reporting Framework, ACSR, 2024,
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California Senate Bill No. 253, Climate Corporate Data Accountability Act, 2023,
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European Commission, European Sustainability Reporting Standards—First set—Public consultation,
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Financial Market Commission, Press release—CMF issues regulation incorporating sustainability
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Financial Reporting & Assurance Standards Canada (FRAS), Media release—Canadian Sustainability
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Financial Supervisory Commission, Press release—FSC publishes ‘Guidelines on Climate-related
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Financial Supervisory Commission, Press release—The Financial Supervisory Commission promulgated
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Financial Supervisory Commission, Press release—The Financial Supervisory Commission (FSC)
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Institute of Certified Public Accountants of Uganda (ICPAU), Adoption of sustainability Disclosure
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International Climate Initiative (IKI), Official launch of the TCFD Mexico Consortium, IKI, 2021,
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International Public Sector Accounting Standards Board (IPSASB), Climate-related Disclosures—Project
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International Public Sector Accounting Standards Board, IPSASB begins development of climate-related
disclosures standard for the public sector, IPSASB, 2023, https://www.ipsasb.org/news-events/2023-06/
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International Public Sector Accounting Standards Board, IPSASB developing the first public sector
sustainability reporting standard with support from the World Bank, IPSASB, 2024,
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Kamu Gözetimi, Muhasebe ve Denetim Standartları Kurumu (KGK), COP28 Conference Message
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Korea Sustainability Standards Board (KSSB), KSSB published the Exposure Draft of the Sustainability
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42BB73BDCEE62945F958220042?boardMngNo=&boardNo=&cmtreadSeq=209&seq=&siteCd=.
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Philippines Sustainability Reporting Committee, ‘Endorsement of IFRS S1 General Requirements for the
Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures’, 2023,
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Parliament of the Commonwealth of Australia, Treasury Laws Amendment (Financial Market Infrastructure
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Climate-related Financial Risks, 2024’, RBI, 2024,
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Securities and Exchange Commission of the Philippines, Request for comments on the draft Memorandum
Circular on the Revised Sustainability Reporting Guidelines for Publicly Listed Companies and the SEC
Sustainability Reporting Form (SuRe Form), Securities and Exchange Commission of the Philippines,
2023, https://www.sec.gov.ph/wp-content/uploads/2023/10/2023RFC_SuRe-Guidelines.pdf.
S&P Dow Jones Indices, S&P Dow Jones Indices and MSCI announce revisions to the Global Industry
Classification Standard (GICS®) structure in 2023, S&P Global, 2022,
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Singapore Exchange, Consultation paper on sustainability reporting: Enhancing consistency and
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SIX Exchange Regulation, Updated list of internationally recognized standards for sustainability reporting,
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SSBJ, The SSBJ issues exposure drafts of sustainability disclosure standards to be applied in Japan,
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TCFD, Final Report—Recommendations of the Task Force on Climate-related Financial Disclosures,
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Supplement-062917.pdf.

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The IFRS Foundation and EFRAG, ESRS–ISSB Standards: Interoperability Guidance, May 2024,
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