Climate change is a regulatory requirement and a key business consideration for the financial sector:
Since 2019, the PRA has asked Banks, Building Societies, and Insurers to have risk management arrangements in place to mitigate climate related financial risks. In addition, both the PRA and the FCA have asked Boards at regulated firms to be responsible for overseeing how their firms manage climate related financial risks. The government, on their side, has also called on the financial sector to play their part in financing the transition to a more sustainable future.
The best way to understand regulatory requirements, and expectations, is by sector:
In October 2022, the Task Force on Climate-related Financial Disclosures (“TCFD”) stated that globally, one in three companies reviewed disclosed climate-related information aligned with the TCFD’s 2020 recommendations. We expect the number of companies reporting against the TCFD’s recommendations to increase significantly over the next few years.
In June 2023, the ISSB issued IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) and IFRS S2 Climate-related Disclosures (IFRS S2). The first two IFRS Sustainability Disclosure Standards are designed to apply for annual periods beginning on or after 1 January 2024. However, jurisdictions must first endorse the standards or otherwise bring them into law for them to become effective, and they may choose a later effective date. The UK has not yet determined this The ISSB has stated they will provide guidance and introduce programmes that support those applying its standards as market infrastructure and capacity is built. TCFD reporting guidance will be subsumed into the ISSB S1 and S2 reporting requirements.
You can find out more about how you can drive climate change risk maturity through TCFD reporting here.
Regulators have expressed growing concerns that some firms may be making exaggerated misleading or unsubstantiated sustainability-related claims about their products, not only in the UK but also in other countries. To address this concern, the FCA has proposed a general ‘anti-greenwashing’ rule for all regulated firms. All sustainability-related claims must be clear, fair, not misleading and should be able to stand closer scrutiny over how these claims are executed.
Firms must carefully reflect on the claims they make over the products offered to customers. The expected Sustainability Disclosure Requirements (SDR) proposed by the FCA will include a new anti-greenwashing rule, which is applicable to all FCA regulated firms. The use of certain sustainability-related terms in product names and marketing materials will be restricted unless the product uses a sustainable investment label, as per the SDR. Therefore, asset and wealth managers, their distributors (including payment service providers) and associated advisers can expect to be busy engaging with the new labelling and disclosures regime, ensuring the requirements are fully understood and ready to be implemented.
With an increased global focus on sustainability-related disclosures in the financial sector, many banks, insurers, asset managers and other financial services firms are finding that they need to improve their reporting mechanisms to enable investors and the public to understand and use their data and information.
Our team provides annual ISAE 3000 and 3410 limited assurance in relation to carbon emissions, ESG, and wider sustainability reporting. Assurance adds a layer of oversight and transparency to disclosures and reporting. This includes reviewing and assessing methodologies, processes and controls used by firms to collate, aggregate, validate and report the scope 1, 2 and 3 emissions data and wider sustainability indicators such as water, waste, supply chain, diversity and inclusion, and career opportunities.
Planning in consultation with the assurance provider in advance of the assurance process is vital for firms to make the process run smoothly and minimise the risks of their data being unable to be assured. This helps identify and inform of any gaps to be addressed in advance of the assurance process beginning.
The assurance and verification phase of sustainability and environmental data is designed to reduce any reputational and greenwashing risk in disclosing misleading or incorrect data and to check on the value and authenticity of the relevant data reported to the public.
Conducting independent assurance benefits organisations by minimising the risk of publishing material errors whilst identifying ways to continue to improve their reporting processes.
Our approach to building an effective ESG strategy is to evaluate risk and opportunity, identify specific regulatory requirements, map firm values, assess reputation risk, and conduct testing to the extent the strategy is embedded after a period of time.
Our model has three defined steps:
The key element for successful ESG strategy development is the “Aims & Impacts Assessment”, that underpins the strategy as a whole. This is followed by a Development Plan of prioritised actions and the associated governance arrangements. An ESG Strategy, when well developed, demonstrates the environmental, social, and governance factors that your business believes to be intrinsically important to your current and future business strategy and operations.
Through supporting clients in developing and implementing ESG strategies, we have built an effective framework for a successful strategy. Our specialist team have produced a guide outlining the key areas of consideration for financial services firms when developing a meaningful strategy, top tips, as well as some common challenges we have seen along ESG strategy journeys that firms should be aware of and safeguard against to help implement their strategy successfully.
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Wherever you are in the process of developing your ESG and climate change strategy, BDO can help you. Our Financial Services ESG team is providing specialist ESG risk and regulatory advice to clients. We are also providing support to firms in respect of climate and ESG-related disclosures on firms’ climate and ESG strategies and risk management arrangements, as well as related disclosures, and the extent to which these satisfy regulatory expectations. Our specialists also provide assurance engagements in accordance with ISAE 3000 and ISAE 3410, reporting your energy usage and carbon emissions in the UK and internationally.
Download our brochure for more details on our services and explore our client case studies, showcasing the ESG support we are providing to financial services firms.
Wherever you are in your ESG journey, our specialist team is ready to help. Get in touch with Richard Weighell, Sasha Molodtsov, Mark Spencer or with our specialist team to find out how we can best support you.
Richard Weighell
Mark Spencer
Sasha Molodtsov