G7 & SEC: Mandatory Climate Risk Disclosure Needed Now
Originally published on NRDC Expert Blog.
By Sarah Dougherty, Tom Zimpleman, & Gabriel Daly
G7 leaders met in the UK last week, and climate was high on the agenda, as it must be. One of the areas of agreement among the leaders of the world’s largest economies might seem new but has been in the works for years: mandatory climate disclosures from companies.
The US has broad disclosure laws, which allow the Securities and Exchange Commission (SEC), as a regulator of stock exchanges and stock sales, to require companies to provide the public with information that can help us make decisions, like about a company’s finances, operations, how it compensates executives, and how it is run. Climate change is an issue on which the SEC needs to require more disclosure — and the Chair of the SEC has indicated he and the Commission intend to require companies to disclose how climate change affects the risks and opportunities they face. The SEC is expected to issue a rule later this year. We think it is about time: NRDC has been pushing for more disclosure on environmental issues since 1971. And, it matters to investors with a recent CFA Institute survey finding 40 percent of investment professionals already incorporating climate risk to inform their investment decisions.
As part of our advocacy for mandatory climate disclosure, NRDC submitted comments to the SEC’s recent request for information. Only mandatory disclosures will allow the SEC to meet its mandate: “to protect investors; maintain fair, orderly, and efficient markets; and facilitate capital formation.” If investors do not know the climate risks — and opportunities — that the companies they are invested in may face, it’s hard to see how investors can be protected and markets can function efficiently.
As we explained in our comments, new rules need to require each company to disclose:
- the full scope of its greenhouse gas (GHG) emissions. This includes GHG emissions from assets that it owns, like factories, buildings, or transportation fleets; GHG emissions from the power is uses to run its factories and buildings; and GHG emissions from using the products it makes (in the case of manufacturers) or the investments it makes (in the case of banks or investment companies).
- the company’s projections about how realistic climate change scenarios will affect the company. Climate change is likely to result in more widespread flooding, wildfires, and more powerful hurricanes. Those events can damage property, disrupt supply chains, and hurt employees. But climate change may also lead to a shift to more sustainable products, alternative energy sources, and new business opportunities. Investors need to know how companies are planning for these possibilities.
- how the company’s operations affect communities vulnerable to climate change.
These disclosures would give investors information that’s useful for their decisions, allowing investors to identify companies (and industries) taking the risks of climate change seriously and planning accordingly. Investors would be better able to allocate capital efficiently to companies that are responsibly planning for the physical risks climate change is already creating — like wildfires and sea-level rise — as well as the transitions risks — changes in policy, consumer preferences, prices, and the like — that our collective response to climate change is likely to impose. And as we know, the costs of climate change will be — and are already — borne disproportionately by low-income communities and communities of color. Disclosures could provide information and insights into how different stakeholders may be impacted by climate change, including vulnerable communities. Additionally, shifting financial incentives away from climate-harming investments is one step towards alleviating those burdens on vulnerable communities.
A voluntary system, which has been in effect for about 15 years, was a good start. But voluntary disclosure has not generated important information nor made it easy to compare between companies. Requiring that companies disclose the risks their businesses face from, and contribute to, climate change will produce information comparable across companies and industries, allowing investors and the public to make better-informed decisions.
In their communique summarizing the G7 meeting, the G7 leaders highlighted their agreement on the importance of climate disclosures:
“We emphasise the need to green the global financial system so that financial decisions take climate considerations into account. We support moving towards mandatory climate-related financial disclosures that provide consistent and decision-useful information for market participants and that are based on the Task Force on Climate-related Financial Disclosures (TCFD) framework, in line with domestic regulatory frameworks.”
Ensuring that investors know the climate risks of the companies they own or may consider purchasing is an obvious first step to greening the global financial system. We are glad the G7 leaders agree and are working to make it happen in the world’s largest economies.
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