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In accordance with Action 9.2 of the EC’s Action Plan, this report proposes climate-related disclosures to assist the EC in its revision of the current Non-Binding Guidelines or NBGs. The guidance proposed in this report intends to assist companies in developing high quality climate-related disclosures that comply with the NFRD and address the recommendations of the TCFD. The NFRD is the legal starting point and foundation for adopting the TCFD recommendations as input to the EU policy framework. Specific disclosures and guidance are described under each element of the NFRD requirements, including metrics for all in-scope companies, for non-financial companies, and for banks and insurance companies. The proposed guidance included in this report:
1. reference the TCFD recommendations;
2. are supported by standards that companies can turn to for further guidance;
3. address gaps in current reporting practice;
4. enable comparability across jurisdictions;
5. align with the EU’s decarbonisation efforts; and
6. streamline reporting.
The disclosures proposed in this report are intended to be within the remit of the reporting requirements of the NFRD.
Three types of disclosures have been defined, from strongly expected from all reporting companies to only expected from reporting companies most exposed to climate-related risks and opportunities and/or with a higher impact on the climate. These three types are indicated using the phrases “should / should disclose,” “should consider / should consider disclosing,” and “may consider / may consider disclosing,” as follows:
·Type 1 disclosures – those that companies should disclose (high expectation that all reporting companies disclose them)
·Type 2 disclosures – those that companies should consider disclosing (expected of companies with significant exposure to climate-related risks and opportunities)
·Type 3 disclosures – those that companies may consider disclosing (additional or innovative disclosures that provide more enhanced information)