US

The US has not yet implemented comprehensive regulations incentivizing or compelling companies to expressly consider and disclose climate change risk exposure across all sectors. 

Improvement of existing US disclosure requirements would include adopting the TCFD’s recommendations in the areas of metrics and targets and strategy, which could help companies pinpoint what information to disclose in SEC filings depending on materiality, and more specific guidance in the existing regulation regarding best practice climate risk analysis and disclosure. This is particularly so in the absence of further guidance from the SEC on climate risk disclosures in the near future. Voluntary initiatives like the TCFD and SASB may become de facto disclosure standards during the short-term.

Practical actions for better climate disclosure in the US

Government

• Recognising the USA’s decision to withdraw from the Paris Agreement, investors and companies should inform regulators of progress they make in implementing the TCFD.

Stock exchanges

• The NYSE and Nasdaq should publish ESG reporting guidance and endorse the TCFD’s voluntary reporting framework, in collaboration with the Sustainable Stock Exchanges Initiative.

Companies

• US Companies should adopt the TCFD’s recommendations as a useful voluntary framework for consistent climate-related disclosures to investors. Sharing of company good practice will assist in overcoming implementation hurdles, with convergence in reporting frameworks needed in the longer term.

Investors

• Investors should engage with companies to encourage adoption of the TCFD’s recommendations. Investors should also evolve their disclosure to beneficiaries and clients, informed by the TCFD’s guidance for asset owners and managers.

Produced in collaboration with Baker McKenzie