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IFRS, ISSB, TCFD, GHG

The International Financial Reporting Standards Foundation (IFRS)

IFRS

Is establishing the International Sustainability Standards Board (ISSB) to develop a baseline global sustainability reporting standard, using the Task Force on Climate-related Financial Disclosures (TCFD) framework as a foundation, along with the work of an alliance of sustainability standard setters. Starting from January 1st 2024, as ISSB Standards begin to be applied globally, the IFRS Foundation will assume the responsibilities previously held by the TCFD concerning the monitoring of progress towards climate-related disclosures. The application of IFRS 2 will also satisfy the TCFD Recommendations, and IFRS S1 requires companies to consider the Sustainability Accounting Standards Board (SASB) Standards for identifying sustainability-related risks and opportunities in the absence of a specific IFRS Sustainability Disclosure Standard.

IFRS 2 Scope and Objectives 

To achieve this objective, an entity is required to disclose information about: [IFRS 2:25]

 

  • the processes and related policies the entity uses to identify, assess, prioritize and monitor climate-related risks, including information about:
    o  the inputs and parameters the entity uses (for example, information about data sources and the scope of operations covered in the processes);
    o  whether and how the entity uses climate-related scenario analysis to inform its identification of climate-related risks;
    o  how the entity assesses the nature, likelihood and magnitude of the effects of those risks (for example, whether the entity considers qualitative factors, quantitative            thresholds or other criteria);
    o  whether and how the entity prioritizes climate-related risks relative to other types of risk;
    o  how the entity monitors climate-related risks; and
    o  whether and how the entity has changed the processes it uses compared with the previous reporting period.

  • the processes the entity uses to identify, assess, prioritize and monitor climate-related opportunities, including information about whether and how the entity uses climate-related scenario analysis to inform its identification of climate-related opportunities; and

  • the extent to which, and how, the processes for identifying, assessing, prioritizing and monitoring climate-related risks and opportunities are integrated into and inform the entity’s overall risk management process.

Governance

The objective of climate-related financial disclosures on governance is to enable users of general purpose financial reports to understand the governance processes, controls and

procedures an entity uses to monitor, manage and oversee climate-related risks and opportunities. [IFRS 2:5]

To achieve this objective, an entity is required to disclose information about the governance body(s) (which can include a board, committee or equivalent body charged with governance) or individual(s) responsible for oversight of climate-related risks and opportunities. Specifically, the entity is required to identify the body(s) or individual(s). [IFRS 2:6(a)]. An entity is also required to disclose information about management’s role in the governance processes, controls and procedures used to monitor, manage and oversee climate-related risks and opportunities. [IFRS 2:6(b)]

Risk management

The objective of climate-related financial disclosures on risk management is to enable users of general purpose financial reports to understand an entity’s processes to identify, assess, prioritize and monitor climate-related risks and opportunities, including whether and how those processes are integrated into and inform the entity’s overall risk management process.[IFRS 2:24]

  • To achieve this objective, an entity is required to disclose information about: [IFRS 2:25]

    • the processes and related policies the entity uses to identify, assess, prioritize and monitor climate-related risks, including information about:

    • the inputs and parameters the entity uses (for example, information about data sources and the scope of operations covered in the processes);

    • whether and how the entity uses climate-related scenario analysis to inform its identification of climate-related risks;

    • how the entity assesses the nature, likelihood and magnitude of the effects of those risks (for example, whether the entity considers qualitative factors, quantitative thresholds or other criteria);

    • whether and how the entity prioritizes climate-related risks relative to other types of risk;

    • how the entity monitors climate-related risks; and

    • whether and how the entity has changed the processes it uses compared with the previous reporting period.​

Metrics and targets

  • Enable users to understand an entity’s performance in relation to its climate- related risks and opportunities, progress on climate-related targets, it is required by. [IFRS 2:27]

  • Entities are required to disclose: [IFRS 2:28]
    o   Information relevant to the cross-industry metric categories;
    o  Industry-based metrics that are associated with particular business models, activities or other common features that characterize participation in an industry; and
    o  Targets set by the entity, and any targets it is required to meet by law or regulation, to mitigate or adapt to climate-related risks or take advantage of climate-related opportunities, including metrics used by the governance body or management to measure progress towards these targets.

Climate-related metrics and targets

Greenhouse Gases (GHG):

  • Measure GHG in accordance with the Greenhouse Gas Protocol:
    o  A Corporate Accounting and Reporting Standard (2004), unless required by a jurisdictional authority or an exchange on which the entity is listed to use a different method.

  • Disclose the approach used to measure GHG, including:
    o   Measurement approach, inputs, and assumptions used.
    o   Reason for choosing the measurement approach, inputs, and assumptions.
    o  Any changes made to the measurement approach, inputs, and assumptions during the reporting period and reasons for those changes.

  • Disaggregate Scope 1 and Scope 2 GHG between:

  • The consolidated accounting group (e.g., parent and its consolidated subsidiaries).

  • Other investees excluded from the consolidated accounting group (e.g., associates, joint ventures, and unconsolidated subsidiaries).

  • For Scope 2 GHG, disclose location-based Scope 2 greenhouse gas emissions and provide information about contractual instruments necessary to inform users’ understanding of Scope 2 emissions.

  • For Scope 3 GHG, disclose:
    o   Categories included within the entity’s measure of Scope 3 greenhouse gas emissions following the Greenhouse Gas Protocol Corporate Value Chain (Scope 3) Accounting       and Reporting Standard (2011).

  • Additional information about Category 15 greenhouse gas emissions or those associated with investments (financed emissions) if the entity's activities include asset management, commercial banking, or insurance.

  • Climate-Related Transition Risks:

    • The amount and percentage of assets or business activities vulnerable to climate-related transition risks.

  • Climate-Related Physical Risks:

    • The amount and percentage of assets or business activities vulnerable to climate-related physical risks.

  • Climate-Related Opportunities:

    • The amount and percentage of assets or business activities aligned with climate-related opportunities.

  • Capital Deployment:

    • Amount of capital expenditure, financing, or investment deployed towards climate-related risks and opportunities.

  • Internal Carbon Prices:

    • Explanation of whether and how the entity applies a carbon price in decision-making (e.g., investment decisions, transfer pricing, and scenario analysis).

    • The price for each metric ton of greenhouse gas emissions used to assess the costs of emissions.

  • Remuneration:

    • Description of whether and how climate-related considerations are factored into executive remuneration.

    • The percentage of executive management remuneration recognized in the current period linked to climate-related considerations.

 

Climate-Related Targets

  • Disclose the quantitative and qualitative climate-related targets

  • monitor progress towards achieving strategic goals, 

  • targets required by law or regulation,

  • GHG for each target, the entity is required to disclose: [IFRS 2:33]

 

Metric used to set the target;

  • the objective of the target (for example, mitigation, adaptation or conformance with science- based initiatives);

  • the part of the entity to which the target applies (for example, whether the target applies to the entity in its entirety or only a part of the entity, such as a specific business unit or specific geographical region);

  • the period over which the target applies;

  • the base period from which progress is measured;

  • any milestones and interim targets;

  • if the target is quantitative, whether it is an absolute target or an intensity target;

  • how the latest international agreement on climate change, including jurisdictional commitments that arise from that agreement, has informed the target.

Industry-based guidance

  • Industry-based Guidance IFRS 2 suggests ways to apply some of the disclosure requirements in IFRS 2.

  • Guidance does not create additional requirements.

  • Guidance suggests ways to identify and disclose information about climate- related risks and opportunities/
    o   associated with particular business models,
    o   industry related activities or other common features.

  • An entity is required to refer to and consider the applicability of the information set out in the guidance  [IFRS 2:IB1]

  • Industry-based guidance  derived from ISSB.

  • Industry- based, subset is likely to apply to any entity. [IFRS 2:IB2]

 

Effective date and transition

An entity is required to apply IFRS 2 for annual reporting periods beginning on or after 1 January 2024. Earlier application is permitted. If an entity applies IFRS 2 earlier, it is required to disclose that fact and apply IFRS S1 at the same time. [IFRS 2:C1]

 

  • Entity is not required to provide the disclosures specified in IFRS 2 for any period before the beginning of the annual reporting period in which an entity first applies IFRS 2 (the date of initial application).

  • Entity is not required to disclose comparative information in the first annual reporting period in which it applies IFRS 2. [IFRS 2:C3]

  • First annual reporting period in which an entity applies IFRS 2, it is permitted to use one or both of the following reliefs: [IFRS 2:C4];
    o   if, in the annual reporting period immediately preceding the date of initial application of IFRS 2, the entity used a method for measuring its greenhouse gas emissions other than the GHG Protocol: A Corporate Accounting and Reporting Standard (2004), the entity is permitted to continue using that other method; and
    o   an entity is not required to disclose its Scope 3 GHG which includes, if the entity participates in asset management, commercial banking or insurance activities, the additional information about its financed emissions. If an entity uses either of these reliefs, the entity is permitted to continue to use that relief for the purposes of presenting that information as comparative information in subsequent reporting periods. [IFRS 2:C5]

 

Objective and scope

  • An entity to disclose it's climate-related risks and opportunities

  • For primary users in making decisions providing resources to the entity. [IFRS 2:1];

  • For climate- related risks and opportunities reasonably expected to affect the entity’s cash flows,

  • its access to finance

  • cost of capital over the short, medium or long term. [IFRS 2:2]​

GHG

The State of New York

has taken several steps to address the financial risks associated with climate change and to promote Environmental, Social, and Governance (ESG) disclosures among financial institutions. Here are some of the key developments in New York's approach to sustainable finance and ESG regulation:

 

  • Climate Change Initiative by the Department of Financial Services (DFS): On February 9, 2021, the New York DFS issued an industry letter alerting banking institutions subject to the New York Community Reinvestment Act that they may receive credit for financing activities supporting the climate resiliency of low- and moderate-income, and underserved communities.

 

  • Expectations for ESG Disclosures and Risk Management: The New York DFS issued a letter to DFS-regulated banks and non-bank institutions discussing the financial risks of climate change and outlining expectations regarding risk management processes, governance frameworks, and business strategies. The letter, published on October 29, 2020, encouraged financial institutions to address the financial risks from climate change in their risk management processes, governance frameworks, and business strategies. It also suggested designating a board member or committee and members of senior management as accountable for this issue and undertaking an enterprise-wide risk assessment. Although no specific deadlines were imposed, DFS-regulated institutions were advised to consider how to address DFS’s expectations, including its call for enterprise-wide risk assessments on the impact of climate change on various risk factors like credit risk, market risk, liquidity risk, operational risk, reputational risk, and strategy risk.

 

  • Guidance from the New York Stock Exchange (NYSE): The NYSE has provided ESG disclosure guidance, covering various reporting frameworks and offering resources like the Task Force on Climate-related Financial Disclosures (TCFD) Knowledge Hub and a Good Practice Handbook.

 

  • Growing Awareness and International Alignment: The initiatives by the New York DFS reflect a growing awareness of the financial risks posed by climate change and are indicative of efforts to align with international standards on climate risk management. Notably, DFS is the first U.S. regulator of financial institutions to publish expectations for regulated institutions in relation to climate change risk management, showcasing New York's proactive approach to addressing climate change risks within the financial sector.

 

These measures reflect New York's commitment to promoting transparency, risk management, and strategic planning in response to climate change and ESG factors among its financial institutions, aligning with broader national and global trends in sustainable finance regulation.

 

The State of California

has shown a proactive approach toward addressing climate change and promoting sustainability through several laws and initiatives aimed at enhancing transparency and accountability among businesses operating in the state. Here's a detailed overview of the sustainable finance and ESG regulatory landscape in California:

 

  • Climate Corporate Data Accountability Act (S.B. 253): Requires companies to disclose their direct (scope 1), indirect (scope 2), and value chain (scope 3) greenhouse gas (GHG) emissions. Applicable to "Reporting entities" with annual revenues in excess of $1 billion, doing business in California, and formed in the U.S. Disclosures to be reported to an "emissions reporting organization." Compliance begins in 2026 for scopes 1 & 2 emissions, and 2027 for scope 3 emissions, with annual reporting thereafter. Beginning in 2026: limited assurance for scopes 1 & 2 emissions; beginning in 2030: reasonable assurance for scopes 1 & 2 emissions and limited assurance for scope 3 emissions. Penalties for noncompliance include non-filing, late filing, or other failures to meet requirements, not to exceed $500,000 per year. Scope 3 disclosures have specific penalty limitations outlined.

 

  • Climate-Related Financial Risk Act (S.B. 261): Requires companies to disclose climate-related financial risks in line with the Task Force on Climate-related Financial Disclosures (TCFD) recommendations. Applicable to "Covered entities" with annual revenues in excess of $500 million, doing business in California, and formed in the U.S. Disclosures to be prepared and published in a publicly available report on the company’s internet website. Compliance begins in 2026, with reporting every two years thereafter. Compliance alternatives include providing required disclosures to the best of the entity’s ability and explanations for gaps and steps to be taken to fully comply. Penalties for noncompliance include failure to publish a report or inadequate or insufficient reports, not to exceed $50,000 per year.

 

  • Emissions Laws and SEC Disclosures: California's new emissions laws could potentially compel companies to reveal more about their carbon footprint to the U.S. Securities and Exchange Commission (SEC).

 

  • Carbon Footprint Reporting Bill: The state Senate approved a bill requiring large companies to report their carbon footprints, which was awaiting Governor Gavin Newsom's decision as of the last update.

 

  • Voluntary Carbon Market Disclosures Act (VCMDA - AB 1305): Imposes new requirements on companies making climate-related claims and participants in carbon emission offset markets. It covers obligations for companies that purchase and sell offsets within California, and introduces new disclosure requirements related to climate-related claims.

  • Climate Corporate Data Accountability Act (SB 253): Requires disclosure of greenhouse gas emissions in conformance with the Greenhouse Gas Protocol standards and guidance developed by the World Resources Institute and the World Business Council for Sustainable Development, including the disclosure of indirect GHG emissions from the value chain.

 

These laws and initiatives reflect California's ongoing commitment to climate action, sustainable finance, and enhanced ESG disclosures. Through these measures, California aims to ensure that companies acknowledge, manage, and disclose the risks and impacts associated with climate change and broader ESG factors, in alignment with both national and international standards and recommendations.

California
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