Climate Change Risk Disclosure Practices Report
1
Center for Law, Environment, Adaptation and Resources (CLEAR)
Climate Change Risk Disclosure Current Practices and
Possible Changes Briefing Paper
Why Climate Change Disclosure is Necessary
Economic losses due to climate change, such as losses associated with sea level rise,
extreme weather, and climactic conditions like drought, are becoming impossible to ignore as the
effects of floods, tornadoes, hurricanes, wildfires, drought and tsunami are increasing.1 The
impact of climate change, resilience or lack thereof to its consequences, and anticipation of
policy and regulatory action signals that action must be taken to minimize and/or capitalize on
these events. This is, in turn, driving the discourse on disclosing climate risk.2
The lack of a standardized approach to climate change risk disclosure has resulted in a
proliferation of disclosure and assurance regimes, leaving businesses, regulators, and investors
with limited scope for comparing and assessing performance or identifying best practices.3 The
variety of approaches that can be taken means that investors and other stakeholders have
difficulty comparing information across companies and sectors.4 As a result, a few states have
implemented mandatory reporting regulations for risk disclosure in certain circumstances.
What Risks Are Generally Reported
1
Environmental Finance Publications, Corporate Climate Risk Disclosure: An executive guide to monitoring and disclosing
climate risk 6 (Felicia Jackson ed., 2012), http://www.lrqa.com/Images/MKCorporateClimateRiskDisclosure_tcm152240148.pdf.
2
Id.
3
Id. at 62.
4
Id. at 78.
Climate Change Risk Disclosure Practices Report
The Securities and Exchange Commission (“SEC”) defines effective climate risk
disclosure in filings as “systematic analysis of potential risks and opportunities” related to
climate change which are judged to be material.5 Climate related risks and opportunities can be
classified in several broad categories including: physical risks, emissions, financing and
underwriting risks and opportunities, regulatory risks and opportunities, litigation risks,
reputational risks, and indirect risks and opportunities associated with climate change. 6
Despite the number of different approaches and risks, in general, provisions that affect
climate change-related disclosure fall into two main categories: (1) risk/governance reporting
provisions that explicitly or implicitly require organizations to make disclosures in annual
securities, company, or financial filings about management or governance of risks and strategies
relating to climate change;7 and (2) greenhouse gas (GHG)/energy measurement and reporting
provisions that prescribe rules and/or reference standards and/or methodologies that directly or
indirectly affect the way in which GHGs and energy consumption are monitored, measured,
reported and/or traded.8
Federal Approaches to Risk Disclosure
Securities and Exchange Commission Disclosures
The U.S. securities laws are based upon the principle that sound investments, efficient
markets, and a stable national economy depend upon disclosure of significant information on
firms’ financial conditions.9 In February, 2010, the SEC issued guidance clarifying that existing
5
Jim Coburn et al., Disclosing Climate Risks & Opportunities in SEC Filings: A Guide for Corporate Executives, Attorneys &
Directors 36 (Ceres 2011), http://www.ceres.org/resources/reports/disclosing-climate-risks-2011.
6
Id. at 36-37.
7
Id. at 76.
8
Id.
9
Id. at 12.
2
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SEC rules may require companies to disclose material climate-related information under
Regulation S-K.10 Existing S-K regulations under the Securities Act11 require disclosure of the
most significant factors that make an investment in the registrant speculative or risky because
they are reasonably likely to have a “material effect” on the company’s financial condition or
operating performance.12 The guidance recognizes that the disclosure requirements place
particular importance on a registrant’s materiality determinations and that the “effectiveness of
disclosures decreases with the accumulation of unnecessary detail or duplicative or
uninformative disclosure that obscures material information.”13
The Supreme Court has explained that “[a] fact is material [in SEC disclosures] if there is
a substantial likelihood that the disclosure of the omitted fact would have been viewed by a
reasonable investor as having significantly altered the ‘total mix’ of information made
available,” and that determining whether information is material requires “delicate assessments
of the inference that a ‘reasonable investor would draw from a given set of facts, and the
significance of those inferences to him.”14 The Court additionally instructed that doubts about
whether information is material should be “resolved in favor of those the statute is designed to
protect,” and has emphasized that “disclosure, and not paternalistic withholding of accurate
information, is the policy chosen and expressed by Congress.”15 Thus, the materiality standard is
inherently fact specific and cannot be reduced to a simple formula, depending instead upon a
careful review of a firm’s particular circumstances.16 As a result, according to the Commission
10
Commission Guidance Regarding Disclosure Related to Climate Change, 75 Fed. Reg. 6294 (Feb. 8, 2010).
17 C.F.R. § 230.408 (2013).
12
Environmental Finance Publications, supra note 1, at 80.
13
Commission Guidance Regarding Disclosure Related to Climate Change, supra note 10, at 6294.
14
TSC Industries, Inc. v. Northway, Inc., 426 U.S. 438, 450 (1976).
15
Id. at 448; Basic, Inc. v. Levinson, 485 U.S. 224, 234 (2010).
16
Jim Coburn et al., supra note 5, at 12.
11
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Guidance Regarding Disclosure Related to Climate Change, disclosure could be required under
the Securities Act for any of the following parts of Regulation S-K:
17

Item 101 of Regulation S-K requires companies to disclose material effects from
compliance with federal, state, and local environmental laws.17 This means disclosure of
the costs a company has for its program of compliance with environmental laws that
apply in addition to disclosure of material effects that compliance with those laws is
expected to have on company business (in particular, on capital expenditures, earnings,
and competitive position).18

Item 103 of Regulation S-K requires disclosure of material pending legal proceedings
against the company arising from federal, state, and local environmental laws.19 These
disclosure requirements apply not only to legal proceedings already initiated, but also to
those a company knows are contemplated by governmental authorities. 20 No disclosure is
required, however, if a claim for damages is less than 10% of company assets or if the
monetary sanction from a governmental authority-imitated proceeding will not exceed
100,000.21

Item 303 of Regulation S-K requires disclosure known as the Management’s Discussion
and Analysis of Financial Condition and Results of Operations, or MD&A.22 This
constitutes analysis and disclosure of material effects of known trends or uncertainties of
company operation and financial conditions. This disclosure should highlight issues that
are reasonably likely to cause reported financial information not to be necessarily
indicative of future operating performance or of future financial condition. As part of
this a company must make its decision about whether climate change, or global warming,
constitutes a known trend.23 In the case of a known uncertainty, such as pending
legislation or regulation, the analysis of whether disclosure is required in MD&A consists
of two steps.24 First, management must evaluate whether the pending legislation or
regulation is reasonably likely to be enacted. Unless management determines that it is not
reasonably likely to be enacted, it must proceed on the assumption that the legislation or
regulation will be enacted. Second, management must determine whether the legislation
or regulation, if enacted, is reasonably likely to have a material effect on the registrant, its
financial condition or results of operations.25

Item 503(c) of Regulation S-K requires a registrant to provide, where appropriate, under
the heading “Risk Factors,” a discussion of the most significant factors that make an
investment in the registrant speculative or a risk.26 It specifies that risk factor disclosure
should clearly state the risk and specify how the particular risk affects the particular
Commission Guidance Regarding Disclosure Related to Climate Change, supra note 10, at 6293.
Id.
19
Id.
20
Id.
21
Id. at 6294.
22
Id.
23
Id.
24
Id. at 6295.
25
Id.
26
Id. at 6294.
18
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registrant.27 Registrants should not present risks that could apply to any issuer or any
offering.28
Additionally, it should be noted that the Australian Stock Exchange (“ASX”) has
implemented mandatory climate change reporting.29 Entities listed on the exchange now must
disclose whether they have material exposure to economic, environmental, or social
sustainability risks.30 If they do report risks, the exchange requires them to disclose how they
plan to manage them.31
Environmental Protection Agency Disclosures
The Environmental Protection Agency (“EPA”) has authority derived from the federal
Clean Air Act to regulate CO2 as a pollutant.32 The EPA’s reporting rule, issued on September
22, 2009, requires 31 source categories of GHG emitters to report the emissions of six categories
of GHGs covered by the United Nations Framework on Climate Change. 33 The purpose of the
reporting rule is to collect “accurate and timely information on GHG emissions,” which will be
essential for informing many future climate change policy decisions. 34 The rule requires
reporting, based on the type of industry or level of emissions, of three major categories of
sources to report, including: 1) facilities that directly emit GHGs; 2) fossil fuel providers; and 3)
27
28
29
Id.
Id.
Climate Disclosure Standards Board, ASX Publishes New Corporate Governance Guidelines, Climate Disclosure
Standards Board: News (Mar. 31, 2014), http://www.cdsb.net/news/331/asx-publishes-new-corporate-governanceguidelines.
30
Id.
31
Id.
32
Massachusetts v. EPA, 549 U.S. 497, 528-29 (2007) (holding carbon dioxide to be a pollutant under the federal
Clean Air Act); but see WildEarth Guardians v. EPA, 751 F.3d 649 (D.C. Cir. 2014); Washington Environmental
Council v. Bellon, 732 F.3d 1131 (9th Cir. 2013) (illustrating EPA’s broad discretion in creating regulations to fight
climate change).
33
74 Fed. Reg. 56,264 (Oct. 30, 2009)
34
Id. at 56,265.
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manufacturers of vehicles and engines.35 It does not require the disclosure of material risks, such
as that seen in the SEC filings.
State and Industry Approaches to Risk Disclosure
Although some information relating to GHG emissions and climate change is disclosed in
SEC filings, much more information is publicly available outside of disclosure documents filed
with the SEC as a result of voluntary disclosure initiatives or other state regulatory requirements.
While New York has pushed for climate change risk disclosure through its own enforcement
mechanisms tied to filings with the SEC, trade and investor groups have focused on seeking
greater guidance from the SEC and on preparation of “best practices” guidelines through ASTM
International.36 California, on the other hand, is on the path to creating new laws requiring
comprehensive climate change risk disclosure rather than waiting for federal comprehensive
guidance.37
New York has long been a front-runner in climate change risk disclosure. In September
2007, the New York Attorney General initiated an investigation into alleged incomplete
disclosures by Xcel Energy and four other energy companies under the authority of the Martin
Act.38 As part of an eventual settlement, Xcel agreed to disclose the following information and
analysis in its SEC 10-k filings for the next four years: (a) an analysis of financial risks from
present and probable future regulation of GHG emissions; (b) an analysis of financial risks from
GHG-related litigation; (c) an analysis of financial risks from the physical impacts of climate
change (including increased sea levels and extreme weather conditions related to climate
35
Id. at 56264.
James R. Williams and Christine M. Morgan, Financial Disclosure of Climate Change Risks: Recent Developments and a
View of the Future 19 (2010), http://www.jonesday.com/files/Publication/6bedbcd2-91d4-4794-b199609907766464/Presentation/PublicationAttachment/2fb8910f-2c3f-4024-b5ec-63dd33f2fd84/ClimateChangeRisks.pdf.
37
Id.
38
Id. at 21.
36
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change); and (d) a strategic analysis of climate change risk and emissions management, including
the company’s current position on climate change, current and anticipated emissions
management, and corporate governance actions concerning climate change.39 This direct
regulation of Xcel’s climate change disclosure policies is remarkable due to the fact that Xcel
provides no services within the borders of New York and the main activity prompting the action
by the Attorney General occurred in Colorado.40 Nevertheless, the Attorney General claimed
jurisdiction under the Martin Act based on the fact that the New York State Common Retirement
Fund was a significant holder in Xcel common stock.41 Significantly, it should be noted that the
Retirement Fund holds the common stock of over 2,000 American companies, each of which,
under this theory, is potentially subject to Martin Act jurisdiction.42 Additionally, since a large
number of companies list stock on the New York Stock Exchange and on the New York-based
NASDAQ exchange, a substantial number of American companies could possibly be subject to
scrutiny by New York under the Martin Act.43 Although this settlement was a voluntary decision
to disclose, which set no legal precedent requiring heavy GHG producers to disclose climate
change risk, it did show that thousands of companies nationwide are potentially at risk of
enforcement, even though the scope of current requirements of climate change risk at the federal
level is not fully developed.44
Further, New York implemented a program in the middle of 2013 requiring insurers to fill
out a survey detailing their climate change adaptation and mitigation strategies. 45 The requested
39
Id. at 22.
Id.
41
Id.
42
Id.
43
Id.; see also N.Y. Gen. Bus. Law §352 (2007) (forbidding misrepresentation in connection with the issuance of sale of
securities in New York).
44
Id. at 22.
40
45
See NEW YORK DEPARTMENT OF FINANCIAL SERVICES, 2012 GUIDELINES AND SURVEY QUESTIONS: CLIMATE
RISK SURVEY GUIDANCE (2012).
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information included mechanisms to address climate change impacts, but no quantitative data or
future predictions were required.46
California is another leader in climate change risk disclosure. Regulation of GHGs by
major sources is required by the California Global Warming Solutions Act,47 which requires the
California Air Resources Board (“CARB”) to adopt a regulation requiring the Mandatory
Reporting of Greenhouse gas emissions (“MRR”).48 As part of this program, under certain
qualifications, the qualified entities must report:

emissions of GHGs from stationary combustion, process, and fugitive sources at the
facility for each listed GHG;49

a demonstration of every reasonable effort to obtain a fuel analytical data capture rate of
100% for each report year;50

data used to assess the accuracy of emissions from each emissions source, categorized by
process;51 and

quality assurance and quality control information including information regarding any
measurement gaps.52
California updated the scope of CARB in 2014.53 The update outlines specific goals for
individual sectors, and sets assignment due dates for mid-range and long-term milestones of
46
See id.
A.B. 32, http://www.leginfo.ca.gov/pub/05-06/bill/asm/ab_0001-0050/ab_32_bill_20060927_chaptered.pdf.
48
Cal. Health & Safety Code § D. 25.5, Pt. 2 (2006).
49
Cal. Code Regs tit. 17, § 95103(a)(2) (2013).
50
Id. at § 95103(a)(8).
51
Id. at § 95103(a)(9).
52
Id. at § 95104(b).
53
See CALIFORNIA AIR RESOURCE BOARD, FIRST CHANGE TO THE CLIMATE CHANGE SCOPING PLAN: BUILDING THE
FRAMEWORK PURSUANT TO AB 32 (2014).
47
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reduction.54 Additionally, the scope of California’s climate change efforts has accommodated the
findings of the new IPCC report on climate changed.55 This will involve an 80% reduction of
GHG emissions below the 1990 level to avoid the worse effects of climate change. 56
A number of additional states have enacted legislation that requires similar mandatory
reporting of GHGs. All eighteen of the states which require mandatory reporting have joined the
Climate Registry, which has set up a general reporting protocol which outlines required reporting
calculation methodologies for the majority of GHG sources.57 These protocols largely just
require reporting of emissions and data use, similar to that required in the California MRR, rather
than an assessment of material risks such as that seen in SEC filings. In 2014, the registry added
additional emissions factors that must be reported, including coal coke, dry wood, landfill gases
and other biomass gases.58 Additionally, many of the calculated heat contents and CO2 emission
factors for materials were updated.59
In 2012, after the wake of recent increases in catastrophic weather events, the New York
State Department of Financial Services announced a joint initiative with the California
Department of Insurance and the Washington State Office of the Insurance Commissioner to
survey insurance carriers regarding climate change risks and the actions insurers are taking to
address those risks.60 As part of this initiative, insurers that write in excess of $300 million in
54
Id. at 6-9.
Id. at 5.
56
Id.
57
The Climate Registry, General Reporting Protocol v. 2.0 2 (2013),
http://www.theclimateregistry.org/downloads/2013/03/TCR_GRP_Version_2.0.pdf.
58
THE CLIMATE REGISTRY, Table 12.1 U.S. Default Factors for Calculating CO2 Emissions from Fossil Fuel and
Biomass Combustion, 1 (2014).
59
Id.
60
Sharlene Leurig and Dr. Andrew Dlugolecki, Insurer Climate Risk Disclosure Survey: 2012 Findings and
Recommendations 4 (Ceres 2013) [hereinafter 2012 Survey]
55
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direct written premiums doing business in their states must disclose their climate-related risks.61
As virtually every large American insurer operates in at least one of these states, the survey
responses help give a good picture of how well prepared the industry is, as a whole, for the new
risks associated with climate change.62
Unfortunately, the results of the 2012 survey show that, in general, almost all
participating companies show significant weakness in their preparedness to address the effects
climate change may have on their business.63 Only 23 out of the 184 companies were found to
have a specific, comprehensive strategy to cope with climate change; 13 of those are foreign
owned.64 At best, it appears that most insurers view climate change as a risk that will inherently
be captured in their Enterprise Risk Management strategies and at worst as an environmental
issue immaterial to their business.65 Few insurers describe efforts to engage stakeholders such as
regulators, policymakers, customers, employees, asset managers or vendors on climate change,
which limits the influence of insurers in shaping the public view of climate change risk.66
Additionally, there appears to be a clear positive correlation between company size and the
quality of insurer disclosure, as smaller companies tend to be far less prepared than larger
companies in setting emissions targets or citing climate change related concerns.67
In July 2014, a subsequent survey was conducted regarding the insurance industry’s
response to climate change the survey once again showed poor results.68 The survey generated
61
Id.
Id. at 5.
63
Id. at 6.
64
Id. at 22.
65
Id. at 23.
66
Id. at 53.
67
Id. at 26.
68
Sharlene Leurig and Dr. Andrew Dlugolecki, Insurer Climate Risk Disclosure Survey: 2014 Findings and
Recommendations 4 (Ceres 2014). [hereinafter 2014 Survey]
62
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330 insurer responses, compared to 184 insurer responses in the 2012 report. Only 3 percent of
insurers surveys achieved the highest ranking and only 10 percent have issued public climate risk
management statements.69 The survey also found that Property and Casualty insurers tend to
account for climate change more than Life & Annuity and Health insurers.70
The implications of these findings are profound, as the insurance industry is a key driver
of the national and global economies and, if climate change undermines the financial viability of
the insurance industry, it will have a devastating impact on the economy as well. As part of this
survey, insurers disclosed risks such as: reputational risks, security risks, sustainability risks,
energy efficiency risks, GHG emissions risks, extreme weather and physical risks, and emerging
risks.71 The respondents are given a score, which is kept private, based on their responses.72
Voluntary disclosure mechanisms
In March, 2010, ASTM International, one of the world’s largest voluntary standards
development organizations, released a standard guide suggesting a process for the identification,
evaluation, and disclosure of financial impacts attributable to climate change.73 The guide is
intended for use on a voluntary basis by companies and agencies as a supplement to, rather than
a replacement for, any applicable regulatory pronouncements, such as the interpretive guidance
issued by the SEC. This voluntary reporting framework maintains that disclosure should be
made when an entity believes its environmental liability for an individual circumstance or in the
69
Id. at 5-6.
Id. at 6.
71
2012 Survey, supra note 60, at 65.
72
Id. at 17.
73
E2718-10 Standard Guide for Financial Disclosures Attributed to Climate Change (ASTM 2011).
70
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aggregate is material.74 Once financial impacts are determined to be material, the Guide directs
reporting entities to make a variety of disclosures, including:

information about the analysis performed by the reporting entity, which would include a
discussion about both risks and opportunities considered and a discussion about
management’s position on and strategic activities related to climate change, as well as
identification of who within the reporting entity’s corporate governance structure is
responsible for addressing these issues;75

relevant regulatory requirements and their resulting financial impacts;76

the likelihood, magnitude, and timing of the financial impacts, including disclosure of the
techniques used for data measurement;77 and

estimated insurance or other recoveries or, if not available, an affirmative statement of
that fact.78
If a reporting entity believes that financial impacts attributable to climate change are so uncertain
and speculative that no quantitative financial analysis can be performed, the Guide suggests that
the reporting entity include a description of the types of financial impacts it foresees and its
reasoning for determining that further quantitative analysis and disclosure is not currently
feasible.79 The Guide notes that while uncertainty cannot be eliminated, it is likely that at least
some financial impacts can be assessed and quantified.80
74
Id. at § 6.2.
Id. at § 6.2.2.1.
76
Id. at § 6.2.2.3.
77
Id. at § 6.2.2.4.
78
Id. at § 6.2.2.5.
79
Id. at § 6.2.2.6.
80
Id.
75
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Another leading voluntary framework today for climate related disclosures is provided by
the Climate Disclosure Standards Board (“CDSB”). This framework includes climate risk
reporting, which is defined as a “qualitative assessment of the organization’s exposure to current
and anticipated (long-term and short-term) significant risks associated with climate change. 81
The CDSB’s mission is to promote and advance more standardized disclosure of its Climate
Change Reporting Framework, which was issued in 2010.82
The CDSB has been continuously working to improve their reporting guidelines. They
have begun to collaborate with other major reporting organizations to improve uniformity and
connectivity between standards.83 CERES, who extensively reported on SEC’s climate change
reporting standard, has recommended the CDSB reporting framework to present better
information to investors than the SEC standard.84
The CDSB appointed the Carbon Disclosure Project (“CDP”) as its secretariat,
responsible for conducting the day-to-day activities of the board in advancing its mission.85 In
the absence of a single unifying framework, the CDP has become a useful tool for finding out
exactly what reporting takes place among the mix of frameworks.86 The CDP found that the
patchwork of legislation, standards, industry and program protocols, and guidelines that have
developed to assist corporations to report on climate change share some fundamental
characteristics.87 In particular they found widespread agreement about the types of information
81
Environmental Finance Publications, supra note 1, at 63.
Id.
83
Climate Disclosure Standards Board, Corporate Reporting Dialogue Launched, Responding to Calls for
Alignment in Corporate Reporting, Climate Disclosure Standards Board: News (Jun. 17, 2014),
http://www.cdsb.net/news/369/corporate-reporting-dialogue-launched-responding-calls-alignment-corporatereporting.
84
Id.
85
Environmental Finance Publications, supra note 1, at 78.
86
Id. at 63.
87
Id. at 77.
82
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that a company should report in relation to climate change, including: (1) an analysis of the
impact that climate change has or is expected to have on the financial and operating condition of
companies and their ability to satisfy strategic objectives; (2) the way in which companies
manage risks and opportunities associated with climate change; and (3) GHG emissions.88 They
have been very busy releasing papers on climate change resilience in Europe, American
business’s use of carbon pricing, and private sector climate change risk. 89
Emerging Trends/Recent Changes in Disclosure Practices
Climate change and other sustainability issues will have a serious impact on the very
foundations of businesses, including: the availability of inputs; reputation; efficiency; and
customer and investor demand.90 A better understanding of the risks and opportunities associated
with GHG emissions and climate change would bring real benefits to business by enabling the
development of strategies that can create value for organizations and their stakeholders.91
Responses to the mandatory insurance survey as required by California, New York, and
Washington show some common emerging strategies for risk management and disclosure. These
include catastrophe modeling, reinsurance, higher deductibles or broader exclusions in risk-prone
areas (particularly coastal zones), and a careful control of aggregate exposure, including
rebalancing property with other lines of business.92 Many insurers now model using warm sea
surface temperature assumptions, consistent with current decadal warming cycles and with
higher mean atmospheric and ocean temperatures driven by carbon forcing. 93 Of additional
88
89
Id. at 77-78.
Carbon Disclosure Project, Climate Change Disclosure Reports, Carbon Disclosure Project: Climate Change
(2014), https://www.cdp.net/en-US/Results/Pages/All-Investor-Reports.aspx.
90
Environmental Finance Publications, supra note 1, at 67..
91
Id. at 68.
Jim Coburn et al., supra note 5, at 41.
93
Id.
92
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interest is the growing tendency of insurers across business segments to prioritize physical risk
management over carbon regulation risk management in their investments.94
Based on responses received by the CDP from its annual survey of companies, it appears
there is also an increasing appetite to change the annual reporting model to include metrics that
reflect a company’s exposure to all risks, including climate change. An emerging approach is
“Integrated Reporting” which is showing the relationship between an organization’s strategy,
governance, and financial performance and the social, environmental and economic context
within which it operates.95 Research into recent corporate sustainability reporting also shows that
companies are starting to respond to the demand for material information by using and including
in disclosures “materiality matrices” as a means of showing how management has identified
what is most important to the company.96
In addition to growing trends, the International Integrated Reporting Council is leading
the development of a global framework for corporate reporting that demonstrates the
linkages between an organization’s strategy, governance and financial performance, and the
social, environmental and economic context within which it operates.97 They released initial
version of the Framework in December, 2013.98 The Framework uses a principles-based
approach, with the intent to “strike an appropriate balance between flexibility and prescription
that recognizes the wide variation in individual circumstances of different organizations while
94
Id. at 9.
Carbon Disclosure Project, The Future of Reporting: CDP FTSE 350 Climate Change Report 2012 11 (2012),
https://www.cdproject.net/CDPResults/CDP-FTSE-350-Climate-Change-Report-2012.pdf.
96
Environmental Finance Publications, supra note 1, at 80.
97
International Integrated Reporting Council, Consultation Draft of the International <IR> Framework 1 (2013),
http://www.theiirc.org/wp-content/uploads/Consultation-Draft/Consultation-Draft-of-the-InternationalIRFramework.pdf.
98
Id.
95
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enabling a sufficient degree of comparability across organizations to meet relevant information
needs.”99
The Sustainability Accounting Standards Board (“SASB”), a U.S.-based, non-profit
organization, intends to establish industry-based sustainability standards for the recognition and
disclosure of material environmental, social and governance impacts by companies traded on
U.S. stock exchanges.100 The SASB sees itself as the non-financial counter-part to the Financial
Accounting Standards Board in the U.S. and plans to issue a complete set of standards covering
10 sectors and 102 industries by 2015.101
Any shift seems to be centered on private industry gradually accepting climate change
risks into their investment portfolios.102 Businesses are slowly seeing climate change to not only
be a future risk, but also opportunity of which they can take advantage. 103 One of the main areas
of concern, however, is uncertain future regulatory results.104 Additionally, this report has
uncovered many technical changes to reporting requirements, such as sources to be included in
greenhouse gas modeling and the amount of emissions per unit energy of a material (as
mentioned above).
99
International Integrated Reporting Council, International <IR> Framework 4 ( Dec. 2013),
http://www.theiirc.org/wp-content/uploads/2013/12/13-12-08-THE-INTERNATIONAL-IR-FRAMEWORK-2-1.pdf
100
Sustainability Accounting Standards Board, http://www.sasb.org/.
101
Id.
102
Climate Disclosure Project, State by State: The business response to climate change across America, CDP:
Driving Sustainable Economics, 3 (2014).
103
Id.
104
Id.