July 29, 2019 – 427 FACTSHEET. Regulation on climate risk in Europe is likely to have a rippling effect across markets globally. There has been key legislation in the past few months, with more action on the agenda. Staying up-to-date on these developments will provide early indications of regulatory action to come. This factsheet on regulatory developments in the EU provides key background to the EU’s sustainable finance agenda, outlines key actions and highlights upcoming dates to remember.
Since establishing the High-Level Expert Group on Sustainable Finance (HLEG) in 2016, the European Union (EU) has positioned itself as a leader in sustainable finance. It has made rapid progress on integrating climate change into its financial sector, simultaneously addressing it from several angles, including risk disclosure, green bond labels, a taxonomy for adaptation and mitigation, and risk management oversight directives. As global financial actors operate, and are regulated, in Europe, EU regulations are likely to propel a development in best practices for addressing climate risk that reaches beyond the EU. Likewise, regulators and financial actors across the world are watching carefully as EU regulation may influence their own action. This factsheet, Financial Climate Risk Regulation in the European Union, summarizes the EU’s stance on the financial risk of climate change, notes key regulatory players and highlights recent and upcoming regulatory action applicable to financial markets.
The EC completed several milestones from its Action Plan in June 2019, including publishing updated nonbinding guidelines for incorporating climate risk into the non-financial reporting directive and releasing the Technical Expert Group report on a taxonomy for activities that contribute to climate adaptation and mitigation.
In April 2019, the European Parliament and Council agreed on text for regulation on disclosures relating to sustainability risks and investments, explicitly stating that climate change demands urgent action.
The European Insurance and Occupational Pensions Authority and the European Securities and Markets Authority have provided technical advice on proposed changes to oversight requirements, suggesting that sustainability be explicitly integrated into risk management, operations, investment strategies and governance.
The European Banking Authority will spend two years assessing environmental, social and governance risks and their management in the banking sector. The assessment will be used to develop a draft amendment requiring “large institutions” to disclose their risk and the disclosures will be required three years after the regulation is implemented.
July 29, 2019 – 427 FACTSHEET. In 2015 France laid the groundwork for legislating climate risk disclosure with Article 173 of its Energy Transition Law, mandating that publicly traded companies and asset managers report on their physical and transition risks from climate change. Building on its track record as an early mover, France’s financial regulators are now actively involved in national and international endeavors to frame climate risk as a financial risk and determine the most effective response. Staying up-to-date on these developments will provide early indications of regulatory action to come. This factsheet on regulatory developments in France provides background on France’s sustainable finance agenda, outlines key actions and highlights upcoming dates to remember.
France’s Art. 173 helped build support for the Taskforceon Climate-related Financial Disclosures recommendations, prompted firms to begin disclosing climate-related risks early and set an example for other nations considering regulation on climate risk disclosure. Since this landmark legislation, French financial regulators have become engaged on addressing financial risks from climate change and the Banque de France was a co-founder and provides the Secretariat for the Network of Central Banks and Supervisors for Greening the Financial System (NGFS), which is focused on propelling the transition to a low-carbon and sustainable economy. By providing the Secretariat for the NGSF, the Banque de France identifies itself as a key player in international efforts to address climate risk. This factsheet, Financial Climate Risk Regulation in France, summarizes France’s stance on the financial risk of climate change, notes key regulatory players and highlights recent and upcoming regulatory action applicable to financial markets.
Banque de France was the first central bank to release an assessment of its climate risks in line with the TCFD and Art. 173, aiming to set an example of best practice for the French financial sector.
ACPR’s fall 2018 survey of the French insurance sector found that disclosures in Art. 173 reports varied between firms and lacked reporting on long-term climate strategies and yearly progress. ACPR made suggestions for insurers to improve their climate risk management based on this review.
In summer 2018, ACPR surveyed its banking sector on banks’ climate risk management, identifying “advanced institutions,” larger banks with ample resources that have integrated climate into risk management, and “wait-and-see” institutions, which are largely domestic, retail-oriented banks still focused on a corporate responsibility approach to climate change.
France’s stock market regulator, AMF, released a report asserting that climate change has been identified as a financial risk, it is still not sufficiently assessed by the market, and the regulator’s role is to inform and raise awareness on the topic.
July 29, 2019 – 427 FACTSHEET. The Bank of England’s views on climate risk provide an indication of how the broader financial sector will likely approach the issue. The Bank propels this conversation by framing issues and convening stakeholders around the challenges and uncertainties of climate risk. With the integration of climate change into its insurance stress tests, the Prudential Regulatory Authority (PRA) has shown that the Bank’s declarations are starting to influence regulatory requirements. Staying up-to-date on these developments will provide early indications of regulatory action to come. This factsheet on regulatory developments in the United Kingdom (UK) provides background on the Bank of England’s approach to climate risk, outlines key actions and highlights upcoming dates to remember.
The Bank of England has been on the forefront of acknowledging climate change as a material financial risk since before it was commonly discussed in the financial sector. Its Governor Mark Carney coined the term the “tragedy of the horizon” in 2015 referring to the economic risks of climate change. Since then, the Bank has become known for emphasizing climate change as an urgent threat to financial stability and financial regulation in the UK is beginning to reflect this stance. Paying close attention to developing perspectives at the Bank will help prepare financial actors for future regulatory changes to come. This factsheet, Financial Climate Risk Regulation in the United Kingdom, summarizes the UK’s stance on the financial risk of climate change, notes key declarations and highlights recent and upcoming action applicable to financial markets.
The PRA included scenarios for physical and transition climate risks in its “Scenario Specification, Guidelines and Instructions” for life insurance and general insurance stress tests released in June 2019.
In April 2019, Carney announced that banks and insurers will be “expected to embed fully the consideration of climate risks into governance frameworks, including at board level.” This was followed by a supervisory statement outlining these expectations and asking firms to have preliminary plans by Oct. 15 2019.
In May 2019, the PRA’s working group of insurance industry experts released a framework for assessing the impacts of physical climate change in the insurance sector and is seeking feedback by Nov. 22 2019.
The PRA and Financial Conduct Authority (FCA) developed a Climate Financial Risk Forum, including banks, insurers, asset managers and other financial stakeholders, that will promote capacity building and knowledge sharing for responding to financial climate risks.
JULY 8, 2019 – LONDON, UK – Four Twenty Seven receives Wealth & Finance Magazine’s Alternative Investment Award for Best in Climate-Related Economic Risk Reporting 2019.
Wealth & Finance Magazine recognized Four Twenty Seven among the winners of their 2019 Alternative Investment Awards. For six years these awards have acknowledged firms and individuals that positively shape the industry’s growth. “Historically considered an undervalued industry, the alternative investment has grown over the past few years. Behind this prominent growth and success, are the leading lights whose innovation, dedication and inventive ways has delivered some award-worthy results,” Wealth & Finance writes.
The Best in Climate-Related Economic Risk Reporting award highlights Four Twenty Seven’s climate risk scores for listed instruments and on-demand scoring of real assets, that assess financial firm’s exposure to physical climate risk and inform risk reporting. Our analysis leverages best-in-class climate data at the most granular level and scores assets on their exposure to physical climate impacts based on their precise geographic location. Investors use this data to drive investment strategies, forward-looking risk management and TCFD/risk disclosures.
Four Twenty Seven's monthly newsletter highlights recent developments on climate risk and resilience. This month we feature developments in scenario analysis for physical risks, highlight the European Union's guidance on climate risk disclosure and share the latest on financial climate risk and the need for resilience.
In Focus: Scenario Analysis for Physical Risk
Bank of England Publishes First Climate Risk Stress Test
The guidance lays out potential impacts by providing sector-specific percentages of potential loss under three scenarios by sector and by region. These quantitative financial impact assumptions are not a projection but a starting point for the insurance industry to explore potential impacts of climate change on their portfolios.
The Bank of England leveraged Four Twenty Seven's analytics on climate risk exposure in equity and real estate markets to inform its assumptions about which sectors will experience the largest impacts. We explain how data on risk exposure in equities can be leveraged for this type of analysis in our new blog series on scenario analysis.
Blog Series: Scenario Analysis for Physical Climate Risk
Our new blog series provides our reflections on how corporations and financial institutions can integrate physical climate risk into scenario analysis. Scenario analysis for physical risk is fundamentally different from transition risk. Corporations and investors increasingly recognize the need to integrate physical risk into scenario analysis but are looking for guidance and best practices on how to proceed.
Our first blog focuses on the foundations, demonstrating how characteristics of climate science affect how climate data can be used to inform scenario analysis. We argue that because physical risks over the next 10-20 years are largely independent from policy decisions and emission pathways, investors would be better served by scenario analysis that focuses on the inherent uncertainty of projected impacts, independent from assumptions on GHG emission scenarios.
The next blog focuses on Equity Markets, with concrete examples of how available data can inform financial stakeholders ready to start putting scenario analysis into action. We look at data on climate risk exposure by sector to explore how climate risk analytics can inform early developments of stress test assumptions, as done by the Bank of England.
The EU also released the Technical Expert Group (TEG) report on a taxonomy for activities that contribute to climate adaptation and mitigation. The taxonomy aims to help investors and policymakers understand which economic activities contribute to the transition to a low-carbon economy, through both mitigation and resilience. It outlines qualitative screening criteria to identify adaptation of economic activities and adaptation by economic activities, providing activity-specific examples for a range of sectors. The proposed taxonomy is still under legislative review.
Second TCFD Status Report
While more firms are releasing TCFD disclosures, investors call for an increase in informative disclosure of the financial impact of climate risks. The Task Force on Climate-related Financial Disclosures (TCFD) released its second progress report earlier this month, emphasizing that the quality of risk disclosures must continue to improve as firms build their understanding and capacity to address climate risks. 91% of surveyed firms said they plan to at least partially implement the TCFD recommendations, but only 67% plan to complete implementation within the next three years. This progress must be accompanied by continued knowledge sharing and research on financial risk pathways for climate impacts, meaningful exposure data and best practices for reporting.
Even as TCFD reporting increases, quantitative assessment of physical risk exposure lags behind. Explore physical climate risk reporting by French firms in our analysis of physical risk in Article 173 reports and stay tuned for Four Twenty Seven's forthcoming analysis on physical risk disclosure in TCFD reports.
Catastrophic Midwest Flooding Has Rippling Impacts
At the end of May only 58% and 29% of the U.S. corn and soy crops had been planted respectively. After persistent flooding beginning in Mid-March, inundated fields delayed planting. This means that some farmers will miss the planting window, which closes in June due to the heat and dryness of later summer months.
Those crops that do get planted will have to overcome soggy soil conditions and will remain at the peril of the summer's weather. It's already clear that this will be a below average crop yield, which translates into more expensive corn in cattle feed and higher prices in grocery stores.
From floods and heat waves to fires and hurricanes, federal recovery efforts for extreme events have cost almost half a trillion dollars since 2005. As disasters become more common and costs increase, there is an urgent need to invest in resilience proactively rather than spending billions on recovery. Last fall's Disaster Recovery Reform Act made an
"There is a silver lining to our climate challenges — economic growth. Americans are very good at innovating and building and we can leverage our need to be more resilient by growing the economy with good resilient and sustainable jobs," Sawislak wrote.
Join the Four Twenty Seven team at these events:
June 19 – Columbia University and PRI Private Round Table, New York, NY: Founder & CEO, Emilie Mazzacurati, will discuss scenario analysis for physical climate risk at this workshop.
The TCFD Status Report published early June 2019 reiterates the need for corporations and financial institutions to perform scenario analysis in a context of uncertainty over climate risk. It notes that while about 56% of companies use scenario analysis, only 33% perform scenario analysis for physical risk. Even fewer firms (43% of those using scenario analysis) disclose their assumptions and findings. The report contains useful case studies, but most focus on transition risk.
Yet a growing number of corporations and financial institutions recognize the need to integrate physical risk into scenario analysis and to develop resilience strategies that address imminent challenges from climate impacts. For example, the most recent IPCC report illustrating the impact of 1.5˚C increase in global temperatures on mean temperatures, extreme temperatures, extreme precipitation and sea levels shows that there will be significant implications for economies even with a 1.5˚C increase in global temperatures. This is still a best case scenario compared to impacts of 2˚C or 2.5˚C warming.
Scenario analysis for physical risk is fundamentally different from transition risk in its challenges and assumptions. This blog series provides our current reflections on how corporations and financial institutions can integrate physical climate risk into scenario analysis. This first blog presents the Foundations, focusing on important characteristics of climate science that affect how climate data can be used to inform scenario analysis for economic and financial risk. The next blog focuses on Equity Markets, with concrete examples of how available data can inform financial stakeholders ready to start putting scenario analysis into action. A forthcoming post will discuss scenario analysis at the asset level for real asset investments and corporate facilities.
The Science: Uncertainties and Relevant Time Frames
Rapid developments in atmospheric and climate science over the past 30 years enable us to understand how these physical hazards will evolve over time due to climate change. Sophisticated global climate models project expected changes in key physical phenomena affected by greenhouse gas (GHG) concentration: heat, humidity, precipitation, ocean temperature, ocean acidification, etc. Like any other models, climate models have limitations in their accuracy and ability to correctly simulate complex and interrelated phenomena. However, it is worth noting that since 1973 models have been consistently successful in projecting within the range of warming that we have experienced in the past twenty years. More details on climate data and uncertainties from global climate models can be found in our report, Using Climate Data.
The Bad News: Impacts Are Locked In
Global climate models project different possible outcomes using scenarios called Representative Concentration Pathways (RCPs). RCP scenarios capture differing GHG emissions trajectories based on a representation of plausible global policy outcomes, without specifying the details of the underlying policies that could generate this outcome. These scenarios show that GHG emissions generated over the coming decades will influence the severity of impacts in the long-term, but also that we are already committed to some impacts through 2100 and beyond.
This is particularly noticeable over the “short term.” When looking at the next 10 to 20 years, projections for temperature and other physical hazards do not present significant differences under different emissions scenarios (Fig 1). This is due to the massive inertia of the Earth’s systems, and the life expectancy of the stock of greenhouse gases already in the atmosphere. To put it simply, significantly reducing GHG emissions is akin to applying the brakes on a rapidly moving truck. It won’t stop instantaneously. Even if we were to stop emitting GHG altogether, climate change would persist. In the words of the Intergovernmental Panel On Climate Change (IPCC), climate change “represents a substantial multi-century commitment created by the past, present, and future emissions of CO2.”
This is by no mean an invitation to give up on reducing GHG emissions. Quite the opposite. Emission reductions are critical to curbing long term impacts and avoiding irreversible effects to our environment (Fig. 2). But for organizations looking at climate data and scenario analysis for risk management and strategy, with a focus on the coming decade(s), this is a critical fact to understand.
Aside from RCP-driven scenarios, there is, of course, a broad range of possible increases in temperature (and other climate hazards) even when looking at the 2030-2040 time frame. These plausible differences are not so much policy-driven as science-driven, demonstrating the different possible responses from the Earth’s systems to the existing stock of GHG.
These differences have significant implications for businesses and investors. For example, a model of sea level rise developed in 2018 incorporates accelerated rates of melting and recent advancements in modelling ice-cliff dynamics to capture extreme risk of coastal flooding. The model shows the Atlantic rising by 1.2m (3.9ft) by 2060 on the Florida coastline, which would equate to widespread flooding of coastal properties with potential domino effects on real estate prices across the state (Fig 3). The ‘intermediate’ scenario, however, most often used for planning, predicts only a 55cm (1.8ft) rise in water levels. While reducing GHG emissions does reduce the risk of more extreme sea level rise millennia into the future, year after year, scientists find that the Antarctic is warming faster than anybody predicted, and there is increasing concern that the process of ice sheet melt may be too far advanced to be stopped.
Thus, performing scenario analysis where the key variable is GHG emission reduction targets may not be an accurate representation of the range of possible outcomes for the near future. Rather, looking at high and low warming projections across a large set of models to understand the range of potential outcomes (independent of the underlying RCP scenario) is a better way to understand potential risk. In other words, physical risks over the next 10-20 years are largely independent from policy decisions and emission pathways, and a rapid, orderly, effective transition to a low-carbon economy could still come with massive physical impacts as these processes are already under way, fueled by the past 150 years of GHG emissions.
The Worse News: Tipping Points
Another challenge is that climate scientists are not currently able to model certain possible impacts from climate change, commonly known as “tipping points.” Tipping points is a catch-all term for a wide range of phenomena that may accelerate feedbacks due to climate change, though the timing or probability of their manifestation is currently not well understood. The phenomena are known as tipping points because past a certain threshold, they may not be reversible, even with a dramatic reduction in GHG emissions. Tipping points of most concern to the scientific community are presented in this report from the Environmental Defense Fund.
Some tipping points catalyze “feedback loops” which can worsen and dramatically accelerate climate change beyond human control. Such is the case, for example, with melting ice sheets, which would not only lead to catastrophic sea level rise, but would also further heat up the planet as the poles’ albedo (reflectivity) is reduced after the ice disappears. Thawing permafrost could lead to massive amounts of methane, a particularly powerful GHG, to be released from the frozen tundra into the atmosphere (in addition to many direct impacts for local communities, infrastructure and ecosystems in the region).
Tipping points further reinforce uncertainty about severity and timing of these extreme impacts and the limitations of using RCP scenarios to understand the range of outcomes for physical risk.
These indirect or second-order hazards are as relevant as first-order impacts to understand the implications of physical climate change on economic outcomes, but they’re not captured by RCP scenarios and many require stand-alone models that cannot easily be integrated into one clean set of scenarios.
Scenario analysis is often approached from the perspective of transition risk, where policy developments and GHG emission targets are the key drivers of risk pathways over the next 10 to 30 years. Physical risk, however, requires a different approach. Impacts over the coming decades are largely locked-in and are only marginally influenced by GHG emission pathways. In contrast, uncertainty looms large regarding how severe these physical hazards will be, and exploring a range of possible outcomes for physical risk, including looking at tail-risks, provides important insights for risk management and financial analysis. In summary, the current state of scientific knowledge and the nature of the Earth’s atmospheric systems call for the developments of scenarios that are decoupled from transition/policy scenarios and instead focused on key scientific drivers of uncertainty and risks that may be experienced regardless of policy decisions over the short to medium term (2020-2040).
While efforts to develop easy-to-use tools for physical risk analysis are nascent, organizations can still extract important insights from climate data and leverage estimates of risk exposure across portfolios. Our next blog in this series provides examples of how financial institutions can leverage data on physical risk exposure in equities to inform some early scenario analysis in equity markets.
Four Twenty Seven’s data products and portfolio analytics support risk reporting and enable investors and businesses to understand their exposure to physical climate risks across asset classes.
Four Twenty Seven's monthly newsletter highlights recent developments on climate risk and resilience. This month we explore the second year of Art. 173 reports, highlight regulators' action on climate risk and share new findings on financial climate risk in Asia.
In Focus: Lessons Learned from Art. 173 Reporting - An Update
Physical Risk Analysis is Stronger in Art. 173's Second Year
The second year of reporting under Article 173 in France saw increased analysis of physical climate risk, but there is still substantial room for improvement. We reviewed disclosures from 49 asset owners in France, finding that almost half of the respondents conducted more substantial physical risk analysis compared to last year. Insurance companies AXA and Generali provided the most detailed analysis for property portfolios, adding to their previous methodology. FRR and Comgest provided the most thorough assessment of physical climate risk in their investment portfolios and BPCE Group was the only bank with a complete analysis of physical risk.
Many firms still cite lack of data and tools as a barrier to adopting thorough analysis of physical risks. Those firms that are on the forefront of climate risk reporting disclose asset-level risk exposure and are beginning to explore how to assess value at risk and scenario analysis for physical climate risks, which are emerging as key research topics.
While French firms are refining their climate risk disclosures, other companies across Europe are beginning to report on climate risk. 30 out of the top 80 companies in Europe made statements in support of TCFD and/or released disclosures, according to the Climate Disclosures Standard Board's review, First steps on climate-related financial disclosures in Europe. Only seven of these firms addressed physical risks.
ClimINVEST reviews developments in physical climate risk assessment in the financial sectors of France, the Netherlands and Norway, finding that common needs across these countries include in-house capacity building, improved risk assessment tools, increased understanding of the impacts of extreme events & guidance on corporate engagement. The report also reviews the landscape of physical risk data providers, including Four Twenty Seven.
How do these developments in TCFD reporting affect the greater landscape of financial risk disclosure and management? In its winter issue the Climate Change Business Journal interviewed Founder & CEO, Emilie Mazzacurati, about the history of the TCFD, it’s uptake to-date and how the recommendations influence other developments on risk disclosure. Emilie says, “The market is in exploratory mode: this is an emerging issue, and the collective understanding of impacts on corporations and financial markets is fast evolving. What is clear, however, is that this is a very material issue, and that is here to stay.”
Central Banks and Regulators Take Action
A Call for Action: Climate Change as a Source of Financial Risk
example by assessing risks in central bank portfolios, promote the growth of publicly available data and encourage continued research and knowledge sharing on climate risks. The report makes two final recommendations for policy-makers: encourage continued uptake of climate risk disclosures, in line with the TCFD and develop a taxonomy of activities that support the transition to a resilient low-carbon economy and those that are highly exposed to climate and environmental risks.
Integrating Physical Climate Risks into Insurance Stress Tests
The draft outlines three scenarios, including a sudden disorderly transition, a long-term orderly transition and a "hot house" scenario without transition and lists metrics of physical risk hazards and transition risk for each scenario. Feedback from industry participants is requested by May 31.
Survey of French Banks and Insurers on Climate Risk
While banks and insurers have made significant progress on assessing transitition risk, progress in undertanding physical and liability risks is much slower. In response to these findings ACPR will establish two working groups with the financial sector, one on governance of climate-change related risks and another on risk metrics and scenario analysis.
Climate Change: Awareness to Action
The Australian Prudential Regulation Authority (APRA) surveyed 38 regulated entities including authorized deposit-taking institutions, superannuation firms and insurers on their risk perceptions, governance, strategy, risk management, metrics and targets and disclosures. Firms identified several opportunities associate with climate risk response: positioning themselves as
industry leaders, developing new products and promoting community resilience. Over 50% of respondents are conducting financial analysis of key risks. Many cite data limitations, resource constraints, regulatory uncertainty and lack of defined terms and methods as barriers to conducting scenario analysis.
Climate Change and the Federal Reserve
"In short, climate change is becoming relevant for a range of macroeconomic issues, including potential output growth, capital formation, productivity, and the long-run level of the real interest rate," writes Glenn D. Rudebusch of the Federal Reserve Bank of San Francisco. His economic research letter highlights the ways that climate risks are pertinent for monetary policy, encouraging continued research on the financial impacts of climate change hazards.
Asian Investors Exposed to Water-Related Climate Risk
Are Asia's Pension Funds ready for Climate Change?
They found that public pension funds, sovereign wealth funds and central banks tend to have portfolios concentrated in their domestic markets, which are also highly exposed to climate risks. The export economies of India and China are particularly vulnerable to water stress, and businesses must prepare for the shift in economic policy towards more resilient industries. In light of high exposure to climate impacts that are already locked in, financial actors should promote adaptation finance, assess their portfolios' physical risk exposure and engage with companies and industry initiatives.
Yale 2019 Symposium on Sustainable Finance Call For Papers
The Yale Initiative on Sustainable Finance is seeking papers for its 2019 Symposium on "The State of Play in ESG Investing.” They will consider empirical research papers, literature reviews or position papers from scholars, practitioners and industry experts. Selected authors will be asked to present at the symposium in November. Specific focal topics within the broad theme of ESG investing include: environmental and social impact metrics; portfolio-level ESG assessment and metrics; ESG in financial disclosures; future reporting frameworks for ESG information; private equity and ESG; and social- and green-impact bonds. Abstracts are due by May 17.
Join the Four Twenty Seven team at these events:
April 30 - May 1 – Ceres Conference 2019, San Francisco, CA: Meet with Founder & CEO, Emilie Mazzacurati on Wednesday.
April 30 – NAREIM Sustainability & Investment Management, Chicago, IL: Chief Operating Officer, Colin Shaw, will present on climate risk data for real estate at this gathering of the National Association of Real Estate Investment Managers.
May 1 – Addenda Capital Investor Day, Toronto, Canada: Colin Shaw will present on physical climate risk.
May 9 – Addenda Capital Investor Day, Montreal, Canada: Emilie Mazzacurati will present on physical climate risk.
April 30, 2019 – 427 ANALYSIS. The second year of reporting under Article 173 in France saw increased uptake of disclosures of physical risk. Our review of 2018 disclosures from 49 asset owners in France shows that almost half of the respondents conducted more substantial analysis of their exposure to physical impacts of climate change compared to last year. We find insurance companies Axa and Generali provided the most detailed analysis for property portfolios, while FRR and Comgest provided the most thorough assessment of physical climate risk in their investment portfolios and BPCE Group was the only bank with a complete analysis of physical risk.
Art. 173: A Second Year of Mandated Climate Risk Reporting
2018 was the second reporting year under Art. 173 of the French Law on Energy Transition and Green Growth, which was passed in August 2015. It requires major institutional investors and asset managers to explain how they take Environmental, Social and Governance (ESG) criteria, including climate change, into account in their risk management and investment policies.
Art. 173 covers publicly traded companies, banks and credit providers, asset managers and institutional investors (insurers, pension or mutual funds and sovereign wealth funds). In addition, asset managers managing funds above 500 M€ and institutional investors with balance sheets above 500 M€ are subject to extended climate change-related reporting obligations, including reporting on both physical impacts of climate change and transition risks (impact of the transition to a low-carbon economy).
We carried out a desktop analysis of the 2018 reports (applying to 2017 portfolios) to understand how financial institutions responded to the requirements laid out by Art. 173 and how their reporting has evolved since last year. We reviewed 49 asset owners in France, including public pension funds, asset managers and insurance companies, with an aggregate €5.5 trillion euro ($6.8tn) under management. Our analysis included all public entities covered by the Art. 173, as well as private insurers with over €2bn in assets under management. Insurance companies play a particularly important role as asset owners in France, where individual savings are massively invested in life insurance savings products. French pension funds, on the other hand, are relatively small due to France’s pay-as-you-go retirement system.
Art. 173 Reporting Trends in Year Two
We were able to find Art. 173 reports for 36 out of 49 organizations. It is possible that, in spite of our best efforts, we failed to locate reports. However, Art. 173 has a ‘comply or explain’ provision which also makes it acceptable for companies to not publish reports if they can justify that climate change is not a material risk, or to solely file their reports with the regulator rather than releasing them.
We found twenty five Art. 173 reports from insurance companies, five from pension funds, two from asset managers and four reports issued by banking institutions. We also found a press statement from HSBC that mentioned an Art. 173 report but we were unable to find the report itself and did not include it in the analysis.
Did Firms Change Their Disclosure Strategy?
Overall, 23 companies (47%) have made significant improvements in their disclosure since last year. These companies have either kept the same methodological framework and refined it or have published substantially more comprehensive reports than last year. Among them, two firms, Groupe Macsf and Carac, have published a report for the first time. Only four companies (8%) have provided reports which were less complete than last year, including one company for which we found a report last year, but not this year. 45% of the firms published reports which were very similar to last year.
How Did Firms Report This Year?
Table 1 presents a detailed breakdown of how insurance companies and asset managers have taken physical climate risks into account in 2018 reports.
12 organizations (25%) only discussed their carbon footprint or their exposure to energy transition risk, without including physical risk disclosures. A small group of organizations (10%) mentioned physical risk as a topic they were exploring without being able to provide a complete analysis for the moment, many citing the lack of tools and models as a major impediment to reporting physical risks.
11 institutions (23%) used a thorough methodology to analyze their exposure to physical risks, compared to only seven companies last year. Several firms released noticeably improved disclosure this year. Out of those firms that did asses their exposure to physical climate risk, nine (19%) carried out a bottom-up analysis of physical risks by assessing the asset-level risk exposure of at least some of their portfolio. Two institutions (4%) performed a “top-down” analysis, carrying out a multi-asset class, sector-level analysis of physical climate risk.
Finally, eight firms (17%) were classified in the “work in progress” category. These companies studied physical climate risk at the company-level among many other criteria as part of a broader analysis of the sustainability of their portfolio. Many of these companies acknowledge that they have not yet been able to develop a complete methodology for assessing physical risks.
Axa is one of France’s leading multinational insurance firms holding 905B€ of assets. While Axa’s 2018 Art. 173 disclosure is very similar to last year, with a bottom-up approach and an internal analysis, the study has increased in accuracy and scope. Like last year, the methodology considers European natural disasters as well as the geographical location of individual assets and the destruction rate of building materials.
In addition to the traditional report about Art. 173 which lays out the principles and commitments of the firm regarding the ESG criteria, Axa released its first report aligning with the Taskforce on Climate-related Financial Disclosures (TCFD) recommendations. Axa’s analysis covered $34 billion worth of assets, compared to $15 billion last year, encompassing commercial real estate debt, infrastructures debt, and property debt. Unlike last year, the assessment was not limited to the financial impact of windstorms but also included the potential impact of floods on the infrastructure in its portfolio. Like last year, the analysis considers 100% of the infrastructure portfolio but this year it also covers 88% of the real estate portfolio in 14 countries, compared to 41% last year.
Figure 4 demonstrates the physical risk exposure to windstorms and floods for the analyzed infrastructure. On the left, the graph displays the annual average destruction rate, which is linked to the average loss generated every year (3.3M€ on average). The map on the right shows the destruction rates due to a 100-year event, with an estimated loss of 27.2 M€. In 2019, Axa plans to expand its internal model to evaluate the financial losses resulting from floods in more European countries.
Axa used a value at risk methodology to assess the potential costs and revenues associated with climate change for each company in its equity and corporate bond portfolios, but this assessment largely focused on transition risks.
Generali France is a French insurance company with 521B€ worth of assets. Generali also provided a more detailed evaluation of the potential impact of physical risks on its property assets than last year. It analyzed 268 assets, compared to 112 last year. Unlike last year, the analysis was not limited to the Paris area, but was expanded to all real estate assets held by the company. 89% of the assets are located in Paris, 7% outside Paris and 4% in the overseas department. They carried out a broader analysis of physical risks by adding earthquakes and avalanches to the study, in addition to flood and drought. The assessment rates assets from “high” to “very low” risk, finding that 5.4% of assets or 18 sites are classified as “high risk” for flood, 2% of assets (11 buildings) are classified as “medium risk” to drought and four of these 11 buildings are concentrated in the same building zone near Paris.
Comgest is an international asset management group with 25.7 B€ worth of assets. The firm released physical risk disclosure reports for its three largest funds: global, European, and emerging market. Four Twenty Seven conducted the physical risk analysis for Comgest, splitting physical risks into three categories: operations risk, market risk, and supply chain risk. The analysis also included a comparison of portfolio risk scores to relevant benchmark indices to highlight the holdings’ relative risk exposure. This asset-level assessment included exposure to storm, drought, extreme rainfall, floods, sea level rise, and heat stress. The analysis resulted in an aggregate score reflecting the portfolio’s exposure to physical climate risks, based on the sectors in the portfolio and the geographic distribution of companies’ assets.
Regionally, the portfolio companies in Asia are most exposed to physical climate risks. Half of the sites are located in Japan and China, which makes the portfolio vulnerable to cyclones and extreme rainfall. The rest of the portfolio is located in the United States and Europe, which have relatively low exposure to physical risks. The risk of rising sea level is relatively low for the portfolio, with only 15% of the sites being exposed.
Overall, 2018 showed an increase in the inclusion of physical climate risks assessment by French financial institutions. However, reporting on physical climate risk remains a challenging task for investors. Many organizations lack the tools, models and data to perform a comprehensive assessment of their portfolios, and for many firms, physical risks appear to still be a lower priority than transition risks. Those firms that are on the forefront of climate risk reporting disclose asset-level risk exposure and are beginning to explore how to assess value at risk and scenario analysis for physical climate risks. 2019 reporting is ongoing and has already brought some new high profile reporters, including the French Central Bank, Banque de France. The positive trends in 2018’s Art. 173 reports, along with continued uptake of TCFD recommendations, ongoing pressure from central banks and regulators, and increasing losses from extreme weather events, suggest that we will see continued growth in physical climate risk disclosures during the third year of Art. 173 reporting.
This analysis was written with support from Roman Dhulst and Natalie Ambrosio.
Climate risk disclosure is essential to building market transparency and a resilient financial system. France led the way in mandating climate risk disclosure in 2015 and continues to play a key role in catalyzing the financial sector’s understanding and disclosure of climate risk. As part of its seven part series highlighting approaches to green finance in “pioneering countries,” Germanwatch published a piece by Four Twenty Seven on France’s role in promoting climate risk disclosure. Read the article below, or find the German version here.
Climate Risk Disclosure: France Paves the Way
Already in 2015, France adopted a law on climate risk disclosure paving the way for protecting economic systems from the consequences of climate change. But others need to follow.
Financial institutions and governments around the world are acknowledging the importance of climate change on the sustainable finance agenda. The World Economic Forum identified climate change-related risks as the top three most likely global risks for 2019, followed by data fraud and cyber attacks, and as four out of the top five most impactful risks, after weapons of mass destruction. This underscores the importance of building economies resilient to climate change impacts.
In 2015, just before the 21st Conference of the Parties (COP21) and the Paris Agreement, France became the first country to pass a law requiring publicly listed companies, institutional investors and asset managers to report their climate-related risks, including both transition risks (associated with the transition to a low carbon economy) and physical risks (associated with extreme weather events or chronic stresses affecting businesses and economic assets).
While today’s conversations about the Paris Agreement and sustainable finance require a transition to a low carbon economy, governments have realized that they also require discussion of the economic risks of physical climate impacts that will occur whether or not Paris climate targets are met. Reaching the adaptation goals of the Paris Agreement requires catalyzing investment in climate resilience. Increasing transparency on companies’ and investors’ exposure to physical climate risk is an essential first step towards identifying opportunities to invest in adaptation and build resilience.
The Approach: Comply or Explain
The French Energy Transition Law and its Art. 173 laid the regulatory groundwork for integrating climate risk transparency into the national sustainable finance approach. The regulation uses a comply or explain approach, providing flexibility for how firms disclose their risks and allowing firms to opt-out from reporting, with an explanation. This fosters discussions among investors, insurers and businesses to find the most informative and feasible risk analysis and reporting methodology across sectors.
The Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) released its final recommendations for climate-related disclosures in June 2017. These voluntary recommendations provided additional direction on how to disclose climate risks, but still do not provide concrete metrics. French organizations, such as Finance for Tomorrow and I4CE, the Institute for Climate Economics, help to catalyze continued research on this topic and keep climate on the sustainable finance agenda.
International initiatives also help facilitate ongoing thought leadership: for example the report Advancing TCFD Guidance on Physical Climate Risks and Opportunities prepared by the European Bank for Reconstruction and Development and the Global Center for Excellence on Climate Adaptation, based on working groups of financial sector experts. While data providers, such as Four Twenty Seven, help to fill data gaps by providing asset-level data on climate risk exposure, there will continue to be ongoing conversations about how best to incorporate this information into actionable disclosures.
Other countries follow the example of France
Art. 173 has helped to center the Paris marketplace in the landscape of green finance. Action on climate risk disclosure continues to increase both within France and internationally. Influential financial actors are beginning to report their own risk exposure, encouraging the market to follow suit. The French Central Bank (Banque de France) for example, released a comprehensive analyses of physical and transition risk in its portfolios in compliance with Art. 173 and TCFD, aiming to set an example for emerging best practices for disclosure. The Dutch Central Bank assessed the exposure of its financial sector to water stress and other environmental risks. Countries such as Spain and Sweden have voiced their support of the TCFD and their consideration of legislation similar to Art. 173, and in July 2018 the Italian insurance supervisor IVASS released a comprehensive reporting requirement for Environmental Social Governance (ESG) risks, including climate change.
In early 2018, the European Commission published an Action Plan: Financing Sustainable Growth, outlining ten actions with timelines by the end of 2019. This led to the development of a Technical Expert Group, which has four workstreams underway: developing a sustainable finance taxonomy, integrating climate change into non-financial reporting requirements, creating a green bond standard and creating carbon indices standards.
Art. 173 mandates an assessment of reporting progress made during the first two years of its application. This review may lead to more explicit guidance on reporting methodologies, potentially expanding the directive to apply to more actors. This, alongside increasing regulatory and investor pressure, will propel the continued improvement of physical climate risk disclosure. As uptake of climate risk and opportunity disclosure increases and is integrated into financial decision-making, France, along with other nations, will make important progress on building more sustainable economies.
How have the Task Force on Climate-related Financial Disclosure’s (TCFD) recommendations changed the landscape of climate risk reporting and where is the market headed? The Climate Change Business Journal interviewed Founder & CEO, Emilie Mazzacurati, about the history of the TCFD, it’s uptake to-date and how the recommendations influence other developments on risk disclosure. Emilie explains her view that “early TCFD reports…are focused on showing good faith efforts more than providing hard data on climate risk exposure.” This is due to the preliminary need to explore datasets on climate risk, familiarize stakeholders with the subject and overcome challenges associated with being among the first to disclose risks.