The IIF Sustainable Finance Working Group has submitted a response to the Taskforce on Climate-related Financial Disclosures (TCFD), and its Secretariat, on its public consultation on Climate-related Metrics, Targets, and Transition Planning.

The IIF and its members are strongly supportive of many aspects of the proposals made in the consultation, including on topics such as forward-looking metrics. However, while there are many aspects of the consultation which are directionally correct, and likely to add value over time, the financial industry perceives that there are a range of issues and challenges which warrant consideration before any formal amendments to the TCFD Recommendations and Guidance are finalized.

These include the level of maturity of metrics and related methodologies, the divergent relevance of certain metrics to financial institutions’ business models, and the need for clearer implementation timelines and guidelines particularly given the formal or informal role TCFD Recommendations now play in many regulatory frameworks.

Furthermore, there are a range of issues relevant to existing TCFD disclosures beyond the items
addressed in this consultation which require further work before new disclosures are introduced
– including the need for greater consistency and comparability in how individual jurisdictions are actually implementing TCFD recommendations into their rules, and clarity on the intended relationship of the TCFD to the effort to develop a global disclosure framework under the initiative of the IFRS/ISSB.

This letter addresses these two sets of issues in turn, and aims to provide a high-level, crosssectoral, and cross-jurisdictional perspective on how the TCFD can most efficiently take forward the revision of its Recommendations and Guidance, with a view to supporting global alignment of disclosure frameworks.