May 20, 2020

By David Photiadis (Director), Emile Lavergne (Consultant), and Puninda Thind (Consultant), The Delphi Group


On May 11, the Prime Minister of Canada announced support for large employers during the pandemic under the Large Employer Emergency Financing Facility (LEEFF). At the time of writing, details of the program were not immediately available, but the announcement explicitly stated that “recipient companies would be required to commit to publish annual climate-related disclosure reports consistent with the Financial Stability Board [FSB]’s Task Force on Climate-related Financial Disclosures [TCFD], including how their future operations will support environmental sustainability and national climate goals.”

In other words, to be approved for LEEFF funds, companies will have to disclose information on the material financial impacts of climate-related risks and opportunities in line with TCFD’s 2017 recommendations. The TCFD was established by the FSB in 2015 to enable investors, lenders, and insurers to better understand their exposure to climate risk. Voluntary disclosures consistent with TCFD provide information on how companies and clients are managing climate-related risks and opportunities.

Canada’s own Mark Carney, former Governor of the Bank of Canada and Governor of the Bank of England, and current United Nations (UN) Special Envoy on Climate Action and Finance, chaired the FSB during the period that the TCFD developed its recommendations. Michael Bloomberg, co-founder of Bloomberg L.P. and former UN Special Envoy on Climate Action and Finance, led the TCFD’s work. To date, over 1,000 organizations, representing over $12 trillion in market capitalization, have signalled their support of the recommendations.

The TCFD process may seem daunting, and it can be complex. To help you navigate the process, here are our five top tips:


1. Use the TCFD as a Framework to Tell Your Sustainability Story in a Common Language

TCFD disclosures are one way the private sector, regulators, and other key stakeholders can move towards “speaking the same language” when it comes to climate-related risks and opportunities. The climate disclosure landscape is beginning to coalesce around the vocabulary used by the TCFD for climate-related information. For example, reporting frameworks like CDP, UN Principles for Responsible Investing (PRI), Sustainability Accounting Standards Board (SASB), and Global Reporting Initiative (GRI) are mapping their climate-related disclosures to align with TCFD recommendations.

You can use the TCFD recommendations (a) as a conversation starter with your investors and internal management around business strategy and financial planning, (b) to connect the dots between governance, business strategy, risk management and operational performance on climate-related issues, and (c) as a jumping-off point to examine how your business will be resilient in the face of climate-related uncertainties.


2. Just Get Started, Then Improve Over Time

85% of investors say they have seen an increase in climate-related financial disclosures since 2017. Disclosure that is consistent with TCFD recommendations is an iterative process that companies will improve and perfect over time. Getting started signals your intention to be transparent and provide stakeholders with relevant information. It also allows you to build internal capacity for enhancing governance and management of climate-related issues. For a first disclosure, the key is to demonstrate to stakeholders that your company is asking the tough questions.


3. Every Industry is Different

Every company is exposed to climate-related risk to some extent, but the financial impacts of climate-related risks and the opportunities differ by sector. The TCFD provides supplemental guidance for financial institutions (banks, insurers, asset owners, asset managers) and non-financial sectors (energy, transportation, materials and buildings, and agriculture, food and forestry).

Disclosure aligned with TCFD recommendations requires a thorough understanding of the specific climate risks and opportunities that are relevant to your company and industry, whether your organization is in the energy sector, mining,  financial services,  or even if you are a municipality.  Focus on macro climate trends and how your company is responding.


4. Both the “What” and the “How” of Disclosure Matter

A best-in-class TCFD disclosure includes relevant climate-related information and is clearly structured across four categories: governance, strategy, risk management and metrics and targets. The TCFD recommends that disclosures be included in annual financial filings.

For now, implementation of the recommendations varies in practice. Some TCFD disclosures are published in stand-alone reports, others are integrated into sustainability reporting. Best practice is still emerging and is unlikely to be set for the next few reporting cycles. The key is to align as closely to the recommended structure and disclose in a way that makes sense for your organization and is transparent for stakeholders. And remember, this is just as much about climate-related risk management as it is about identifying climate-related opportunities for your organization. Take the long view by setting metrics and targets. If you are undertaking climate scenario analysis for the first time, start with known scenarios and a qualitative assessment, adding more rigour and financial quantification over time.


5. TCFD Disclosure is One Part of a Larger Toolbox for Managing Climate Risks and Opportunities

Preparing a TCFD disclosure requires engaging numerous internal stakeholders across different parts of the business. The TCFD provides a strong structure for your organization to think about the work you have done and plan to do related to climate change. It also lends itself well to iterative conversations and long-term thinking around strategy and financial planning related to climate change.

TCFD disclosure is likely just one component of the work your organization has or will undertake in the face of climate-related risks and opportunities. It is one step on your larger journey, providing you with the tools to think about and discuss long-term changes that will impact your organization.



David Photiadis is a Director and Emile Lavergne and Puninda Thind are Consultants with The Delphi Group. For more information on TCFD disclosure and/or to grow your organization’s climate leadership, feel free to reach out to any one of them directly: Dave ( | Emile ( | Puninda (