Unlocking Value and Managing Risk: The Evolving Landscape of Climate Risk Disclosure in Financial Markets

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Introduction: The Rising Importance of Climate Risk Disclosure
In recent years, climate risk disclosure has emerged as a crucial requirement in the global financial landscape. As climate change accelerates, its impacts-including severe weather events, policy changes, and shifting consumer demands-pose significant threats and opportunities for businesses and investors. Transparent disclosure of these risks is now essential for informed decision-making, efficient capital allocation, and regulatory compliance. This article explores the current state of climate risk disclosure in financial markets, outlines practical steps for implementation, and highlights challenges and solutions for stakeholders seeking to navigate this evolving terrain.
Understanding Climate Risk in Financial Markets
Climate-related risks generally fall into two categories: physical risks and transition risks . Physical risks stem from direct impacts of climate change, such as hurricanes, floods, or wildfires, which can damage assets and disrupt operations. Transition risks arise as the world shifts toward a low-carbon economy, affecting asset values due to regulatory actions, changing technologies, or evolving consumer preferences [1] .
The financial impacts of these risks are increasingly evident. For example, in 2024 alone, the U.S. experienced 27 weather disasters each costing over $1 billion, totaling $182.7 billion in damages-a record that underscores the materiality of climate risks for insurers, investors, and corporations [5] .
Global Standards and Frameworks: TCFD and Beyond
The Task Force on Climate-related Financial Disclosures (TCFD) has set the global benchmark for effective climate risk reporting. Established by the Financial Stability Board, the TCFD framework guides organizations to disclose governance, strategy, risk management, and metrics related to climate change. These disclosures help investors and regulators assess how prepared companies are for climate-related shocks and transitions [2] .
Key elements of the TCFD framework include:
- Governance : How boards and management oversee climate risks and opportunities, with roles and responsibilities clearly defined [4] .
- Strategy : Identification and analysis of material climate-related risks and opportunities, including scenario analysis to evaluate impacts on business operations and value chains.
- Risk Management : Processes for identifying, assessing, and managing climate risks throughout the organization.
- Metrics & Targets : Quantitative indicators and targets for tracking progress, such as greenhouse gas (GHG) emissions across Scopes 1, 2, and, where feasible, Scope 3.
Global adoption of TCFD-aligned reporting is expanding, but implementation varies by region and sector. The International Sustainability Standards Board (ISSB) and the European Union have introduced their own standards, based on TCFD recommendations, further shaping the regulatory landscape [3] .
Regulatory Developments in the United States
In the U.S., the Securities and Exchange Commission (SEC) has been at the forefront of advancing climate risk disclosure requirements. In 2025, the SEC finalized a narrower climate-related risk disclosure rule, but subsequently decided to halt its defense of the rule amid ongoing legal challenges [1] . This regulatory uncertainty has complicated efforts by businesses and investors to comply with clear, consistent standards.
Despite these challenges, some states-most notably California-have enacted their own climate disclosure laws. These state-level initiatives often require reporting on GHG emissions and climate risk management strategies, setting a new bar for companies operating in those jurisdictions. However, the lack of federal standardization means companies must monitor multiple, sometimes conflicting, requirements [3] .
Benefits of Enhanced Climate Risk Disclosure
Effective climate risk disclosure offers several tangible benefits for financial market participants:
- Improved risk assessment : Investors can better evaluate the resilience of companies to climate-related shocks and transitions [2] .
- Informed capital allocation : Clear disclosures help direct capital toward more sustainable and resilient assets and strategies.
- Strategic planning : Companies can proactively adapt business models and operations to emerging risks and opportunities, supporting long-term value creation.
- Stakeholder trust : Transparent reporting builds credibility with regulators, customers, and the broader public.
For example, a 2025 report analyzing over 1,700 U.S. insurance companies found substantial progress in climate risk identification and governance, but also highlighted persistent gaps in the metrics and targets needed for effective accountability [5] .
Step-by-Step Guidance for Implementing Climate Risk Disclosure
Organizations seeking to enhance their climate risk disclosure should consider the following practical steps:
- Assess Material Risks : Begin by identifying and evaluating climate-related risks and opportunities specific to your sector and business model. Use scenario analysis to estimate potential impacts over different time horizons.
- Establish Governance Structures : Ensure board-level oversight and clearly define management roles for climate risk. Develop cross-functional committees to integrate climate considerations into decision-making [4] .
- Align with Recognized Frameworks : Structure disclosures according to TCFD or ISSB guidance. This ensures consistency with investor expectations and regulatory trends [2] .
- Develop Metrics and Targets : Quantify climate risks and set measurable goals for emissions reduction, resilience, and adaptation. For Scope 3 emissions, use qualifying language if full data is not currently available; monitor regulatory changes for evolving requirements [3] .
- Report Transparently and Regularly : Publish disclosures in annual reports or sustainability statements. Engage stakeholders and update disclosures as new information or regulations emerge.
For organizations new to the process, consider consulting sustainability experts or engaging with industry associations for tailored guidance. The Task Force on Climate-related Financial Disclosures website provides practical resources and historical guidance on implementation [2] .
Challenges and Solutions in Climate Risk Disclosure
Despite increasing awareness, several obstacles remain:
- Data Gaps : Many companies still lack reliable data, especially for complex metrics like Scope 3 emissions. To address this, organizations can start with material Scope 1 and 2 disclosures and gradually expand as data availability improves [3] .
- Fragmented Regulations : Differing disclosure requirements across jurisdictions create complexity. Companies should closely monitor relevant regulations and adapt their disclosures to meet the strictest applicable standard.
- Resource Constraints : Small and mid-sized firms may lack the expertise or resources to implement best practices. Industry groups and third-party consultants can help bridge this gap.
Some firms have successfully leveraged scenario analysis and external assurance providers to strengthen their disclosures and build investor confidence. Others have partnered with academic institutions or joined industry alliances to share best practices and build capacity.

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How to Access Resources and Stay Compliant
To stay ahead of regulatory changes and stakeholder expectations, organizations can take these steps:
- Monitor updates from the Securities and Exchange Commission (SEC) by visiting the official SEC website and searching for “climate risk disclosure rules”.
- Review guidance and tools from the Task Force on Climate-related Financial Disclosures by searching for “TCFD guidance” on their official website.
- Stay informed about state-level requirements, especially in California, by tracking legislative developments through the California Air Resources Board and other official state channels.
- Engage with industry associations, such as Ceres or the Principles for Responsible Investment (PRI), for updates and best practice resources.
- For insurance sector disclosures, consult the National Association of Insurance Commissioners (NAIC) Climate Risk Disclosure Survey and related resources.
If you are unsure how to begin, consider searching for “climate risk consulting firms” or “TCFD implementation support” to identify qualified advisors. You may also contact your industry trade group for sector-specific guidance and training opportunities.
Key Takeaways and Next Steps
Climate risk disclosure is now a central pillar of financial market integrity. While regulatory uncertainty persists, aligning with established frameworks like TCFD and proactively building robust governance, data, and reporting processes will position organizations for long-term resilience and investor trust. Begin by assessing your material climate risks, seek expert guidance where needed, and remain agile as the regulatory landscape continues to evolve.
References
- [1] Harvard Law School Environmental & Energy Law Program (2025). Financial Regulation, Climate Change, and Climate-related Risk Disclosure Tracker.
- [2] Task Force on Climate-Related Financial Disclosures (2023). TCFD Official Guidance and Resources.
- [3] Columbia Law School Sabin Center for Climate Change Law (2025). Uncertainty on Climate Risk Disclosure as SEC Abdicates Responsibility.
- [4] International Council of Shopping Centers (2022). Introduction to Climate Risk Disclosure.
- [5] Ceres (2025). Major U.S. Insurers Make Progress on Climate Disclosures, but Significant Gaps Remain.