Does Climate Disclosure Work to Reduce Greenhouse Gas Emissions? Emerging Evidence Suggests Cautious Optimism.

Abstract

The purpose of this Article is to bring some of the emerging empirical literature evaluating the effects of required greenhouse gas (GHG) disclosure to bear on discussions of disclosure as a mechanism to address climate change. Since disclosure has become such a significant part of global efforts to address climate change, whether it has the effects in fact that are attributed to it in theory is properly subject to interrogation. In this Article, several interrelated questions will be discussed. First, what does the empirical evidence show about the effects of required (GHG) disclosures on emissions? What mechanisms are engaged in producing the reductions in GHG emissions that are seen in some studies? Is there evidence that disclosure of climate data causes institutional investors to re-allocate capital, and that this re-allocation is a significant source of pressure on firms? What, then, can we conclude about the use of disclosure in efforts to address climate change? Newly emerging empirical research shows that mandatory GHG disclosure can cause firms to reduce their GHG emissions and the carbon intensity of their products. The mechanisms by which this effect occurs include changes in managers’ strategies and operational changes in the firm, increased public pressure once data becomes available, and investor re-allocations of capital. There is some evidence that firms’ voluntary GHG disclosures similarly have a “disciplining” effect within the firm, in that emissions go down after firms start to disclose this information. In both cases, and arguably important to the results, the information being disclosed is quantitative and the standards for measurement are well defined. To bring the discussion into focus, Part One will first briefly describe three global, voluntary disclosure frameworks—Taskforce on Climate Related Financial Disclosures (TCFD), Taskforce on Nature Related Financial Disclosures (TNRD), and International Sustainability Standard Board (ISSB)—each of which has either been globally influential (TCFD) or has the capacity to become influential (TNRD and ISSB). Part One will also describe two mandatory climate disclosure regimes: the Corporate Sustainability Reporting Directive (CSRD) in the EU, and the Securities and Exchange Commission’s (SEC) Climate Disclosure Rule in the U.S. Part Two will discuss some emerging empirical evidence on the effects of GHG emissions disclosure as an example of targeted climate transparency. Empirical research on the effects of mandatory GHG emissions disclosure in the UK and U.S. will be used to inform that discussion. Part Three will explore the implications of that empirical evidence for evaluating the likely power of the disclosure initiatives described in Part One in reducing GHG emissions and stabilizing nature loss.