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Last updatedIDJurisdictionRegulatory domainInstrument analysisStage in the regulatory processSpecificityEnforcementSubcategoryRegulatory potential of instrumentsRegulatory statusNameShort summarySummarySource URLApplicable toRegulatory BodyName of Regulatory BodyInstrument typeYear publishedYear enactedReferences to standardsStandards referenced
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12/05/2023AR-001AR - ArgentinaClaims and financial product standardsInstrument identifiedPreparatory phaseUnknownUnknown21Record not regulatedUnknownAnnounces the development of a green taxonomyA rules-based solution that defines what is sustainable or carbon neutral might be possible under the development of a green taxonomy. According to the Technical Board of Sustainable Finance of Argentina (MTFS, in the original acronym) latest report (2022), a green taxonomy is under an initial stage of analysis and discussion.MTFS: https://www.argentina.gob.ar/economia/asuntosinternacionales/mesafs

MTFS 2022 report: https://www.argentina.gob.ar/sites/default/files/mtfs_l_informe_final_2022.pdf		UnknownUnknownUnknownUnknownNot applicableNot applicableDoes not reference standards
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17/05/2023AR-002AR - ArgentinaClaims and financial product standardsInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedCivil and Commercial CodeRegulates misleading advertisementsThere is room for expanding the current regulatory understanding by including net-zero claims as a part of a specific category (e.g. under the greenwashing umbrella), which requires special monitoring. In particular, the Civil and Commercial Code could account for such a regulation, as it already mandates that information about products and services must be precise and accurate (Article 1100) and prohibits misleading or abusive advertisements (Article 1101).Greenwashing in Argentina: https://www.ojambf.com/en/greenwashing-greenwashing-in-argentina/

Civil and Commercial Code: http://servicios.infoleg.gob.ar/infolegInternet/anexos/235000-239999/235975/norma.htm#20		Any person exposed to commercial practicesLegislativeThe Senate and Chamber of Deputies of ArgentinaLaw20142014Does not reference standards
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17/05/2023AR-003AR - ArgentinaClaims and financial product standardsInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedTrademark LawRegulates deceptive trademarksThere is room for expanding the current regulatory understanding by including net-zero claims as a part of a specific category (e.g. under the greenwashing umbrella), which requires special monitoring. In particular, the Trademark Law (Law 22326) could account for such a regulation, as it already bans the registration of deceptive trademarks that are likely to mislead as to the nature, properties, merit, quality, manufacturing techniques, function, origin, price or other characteristics of the products or services (Article 3, d).Greenwashing in Argentina: https://www.ojambf.com/en/greenwashing-greenwashing-in-argentina/

Law 22326: http://servicios.infoleg.gob.ar/infolegInternet/anexos/15000-19999/18803/texact.htm		CompaniesExecutiveThe Presidency of ArgentinaLaw19801980Does not reference standards
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17/05/2023AR-004AR - ArgentinaClaims and financial product standardsInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedConsumer Protection LawRegulates advertisements and commercial informationThere is room for expanding the current regulatory understanding by including net-zero claims as a part of a specific category (e.g. under the greenwashing umbrella), which requires special monitoring. In particular, the Consumer Protection Law could account for such a regulation, as it already mandates that information about products and services must be precise and accurate (Article 4).Greenwashing in Argentina: https://www.ojambf.com/en/greenwashing-greenwashing-in-argentina/

Law 24240: http://servicios.infoleg.gob.ar/infolegInternet/anexos/0-4999/638/texact.htm		Consumers of goods and servicesLegislativeThe Senate and Chamber of Deputies of ArgentinaLaw19931993Does not reference standards
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01/08/2023AR-005AR - ArgentinaDisclosureInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedResolución General 797/2019 - RESGC-2019-797-APN-DIR#CNVMandates the disclosure of ESG-related risks by large listed companiesResolution number 797/2019 by the Securities and Exchange Commission (Comisión Nacional de Valores - CNV, in the original language) establishes a new version of the Corporate Governance Code in Argentina (Código de Gobierno Societario, in the original language) (Resolución General 797/2019, Art. 1º). The Code already accounted for an Annual Report, with financial information (Corporate Governance Code, page 7). From 2019 onwards, the Annual Report includes the publication of a strategic plan and a risk analysis management and monitoring, which can take into consideration environmental, social and corporate governance factors (Corporate Governance Code, pages 13 and 36). Climate risks are not specifically described, which is why the instrument is classified as "broad-based". The Annual Report is mandatory on a "comply or not, explain" basis (not "comply or explain") (Corporate Governance Code, pages 8-9) for large companies that trade in the market (Resolución General 797/2019, Art. 1º and Corporate Governance Code, page 6), which is monitored by the Securities and Exchange Commission (Corporate Governance Code, page 10).Resolución General 797/2019 - RESGC-2019-797-APN-DIR#CNV: https://www.boletinoficial.gob.ar/detalleAviso/primera/209844/20190619

Corporate Governance Code: https://www.argentina.gob.ar/sites/default/files/vf._corporate_governance_code.pdf		Large listed companiesFinancial regulatory authoritySecurities and Exchange Comission (CNV)Resolution20192019Does not reference standards
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11/08/2023AR-006AR - ArgentinaProcurementInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedNational Regime for Public PurchasesAllows for broad-based sustainability criteria to be considered in public purchasesThe National Regime for Public Purchases (Decree 1030/2016) supports sustainable public procurement (Decree 1030/2016, Initial considerations). It does not include net zero emissions as one of its procurement goals. Nonetheless, the Regime allows for sustainability criteria to be included as a criterion in bids (Decree 1030/2016, Annex, Articles 36 and 37). Moreover, as the governing body for procurement in Argentina (Decree 1030/2016, Annex, Article 115), the Oficina Nacional de Contrataciones (ONC) has been progressively developing an understanding of how sustainability can be effectively included in the purchases - which is described as one of its institutional mandates (Decree 1030/2016, Annex, Article 115, 1). Some of these actions are available in the tracker.Decree 1030/2016: http://servicios.infoleg.gob.ar/infolegInternet/anexos/265000-269999/265506/norma.htmNational governmentExecutivePresidencyDecree20162016Does not reference standards
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11/08/2023AR-007AR - ArgentinaProcurementInstrument identifiedApprovedBroad-basedDoes not mandate action50Record not regulatedDecree 31/2023Allows the Ministry of Environment and Sustainable Development to formulate regulations for sustainable procurementIn 2023, the Ministry of Environment and Sustainable Development was assigned to implement sustainable consumption practices in the national government (Decree 31/2023, Articles 3 and 4). The Ministry can formulate new regulations to achieve this goal (Decree 31/2023, Article 5), which opens up more opportunities for the integration of carbon and net zero considerations in Argentina's public procurement practices.Decree 31/2023: https://www.argentina.gob.ar/normativa/nacional/decreto-31-2023-378588/textoGovernmentExecutivePresidencyDecree20232023Does not reference standards
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11/08/2023AR-008AR - ArgentinaProcurementInstrument identifiedApprovedBroad-basedDoes not mandate action50Record not regulatedAcuerdos MarcoFramework for sustainable purchasesThe Oficina Nacional de Contrataciones (ONC) has been progressively developing an understanding of how sustainability can be effectively included in the purchases - which is described as one of its institutional mandates (Decree 1030/2016, Annex, Article 115, 1). The "Acuerdos Marco" or agreed framework is one of these actions. 11 goods/services are under one of the frameworks (available at "Sustainable Public Procurement"). They allow for purchases with sustainable criteria "in bulk", making it easier and cheaper for governmental bodies to procure them (available at "Sustainable Public Procurement"). They do not specifically consider net zero or decarbonization goals.Decree 1030/2016: http://servicios.infoleg.gob.ar/infolegInternet/anexos/265000-269999/265506/norma.htm

Sustainable public procurement: https://www.argentina.gob.ar/jefatura/innovacion-publica/oficina-nacional-de-contrataciones-onc/compras-publicas-sustentables		National governmentExecutiveNational Contracting Office (ONC)Recommendation20162016Encourages actors to follow the standardsISO 14001
ISO 14064
ISO 14046
ISO 14067
ISO 26000
ISO 374
ISO 364
ISO 23409
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11/08/2023AR-009AR - ArgentinaProcurementInstrument identifiedApprovedBroad-basedDoes not mandate action50Record not regulatedManual for Sustainable Public ProcurementDisseminates best practices in sustainable procurementThe Oficina Nacional de Contrataciones (ONC) has been progressively developing an understanding of how sustainability can be effectively included in the purchases - which is described as one of its institutional mandates (Decree 1030/2016, Annex, Article 115, 1). The Manual for Sustainable Public Procurement is one of these actions. Although voluntary, it disseminates best practices. It currently does not consider net zero or decarbonization specifically.Decree 1030/2016: http://servicios.infoleg.gob.ar/infolegInternet/anexos/265000-269999/265506/norma.htm Manual for Sustainable Public Procurement: https://www.argentina.gob.ar/sites/default/files/manual_compras_publicas_sustentables_2017.pdfNational governmentExecutiveNational Contracting Office (ONC)Manual20172017Encourages actors to follow the standardsISO 14040
ISO 14044
ISO 14024
ISO 16073
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11/08/2023AR-010AR - ArgentinaTransition plansInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedNational Plan of Adaptation and Mitigation of Climate ChangePresents actions to be taken by Argentina to reach its NDCThe National Plan of Adaptation and Mitigation of Climate Change (Plan Nacional de Adaptación y Mitigación al Cambio Climático, in the original language) was created following the approval of Law 27520/19 (page 28). The purpose of the Plan is to present the actions to be taken by Argentina to reach its NDC (page 28). The Plan describes several actions that are to be taken (check, for instance, pages 55-57), but does not in itself demand action.National Plan for Adaptation and Mitigation of Climate Change:
https://www.argentina.gob.ar/sites/default/files/manual_-_adaptacion_y_mitigacion_al_cambio_climatico_1285pag_1.pdf		All governmental levelsExecutiveMinistry for the Environment and Sustainable DevelopmentPlan20222022The standard is cited in the textISO 21401
ISO 62406
ISO 10274
ISO 11605
ISO 11900
NAG-313
NAG-314
ISO 62410
ISO 62404
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11/08/2023AR-011AR - ArgentinaTransition plansInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedLaw 27520/19Defines the principles for the climate transition and adaptation in ArgentinaThe Law of Minimum Budgets for Adaptation and Mitigation to Global Climate Change (Law no. 27520) of 2019 aims to promote goals, actions and policies for climate adaptation and mitigation in Argentina (Article 2). One of the principles of the law recognizes the cross-cutting characteristic of climate change, which demands private and public actions from all sectors (Article 4.b). However, the law itself does not demand any action from the private sector.
The law describes the actions to be taken for a transition in Argentina, which includes the development of a National Plan (Article 23) (discussed in another tracked entry), and sectoral activities like the creation of fiscal incentives for low-carbon activities, mitigation actions in the agricultural and livestock sector, natured-based carbon capture, and updates to built environmental standards (Article 24.e-i).
The Law also establishes the National Cabinet for Climate Change (Gabinete Nacional de Cambio Climático) (Chapter II), which has the role to develop policies (including sectoral) for the transition (Article 7).		Law 27520/19: https://www.argentina.gob.ar/normativa/nacional/ley-27520-333515/textoAll governmental levelsLegislativeCongressLaw20192019Does not reference standards
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01/08/2023AU-012AU - AustraliaClaims and financial product standardsInstrument identifiedDraft phaseCarbon-specificUnknown21Record not regulatedAustralian Sustainable Finance Institute Taxonomy ProjectDrafts a taxonomy for financial productsThe "Australian Sustainable Finance Institute Taxonomy Project" is a joint initiative of companies and the Australian government to develop an Australian taxonomy of sustainable investments (page 4). The role of government and the enforcement type of the final taxonomy is still under consideration (page 33), which is why the enforcement status is "unknown". Nonetheless, supporting climate change mitigation is the primary purpose of the proposed taxonomy in its current stage (pages 5, 6, 19, and 42). The taxonomy is expected to be further developed in 2023 (page 39).Designing Australia’s sustainable finance taxonomy: https://static1.squarespace.com/static/6182172c8c1fdb1d7425fd0d/t/64221052e1667558180e4ae9/1679954013353/Framing+Paper+Update+March-compressed.pdfUnknownUnknownUnknownUnknown2022Not applicableThe standard is cited in the textTNFD
TCFD
ISSB
ASEAN Taxonomy
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11/08/2023AU-013AU - AustraliaClaims and financial product standardsInstrument identifiedPreparatory phaseUnknownDoes not mandate action20Record not regulatedGreenwashing by businesses in AustraliaAnnounces updated guidance material to reduce greenwashingThe Australian Consumer Law (ACL) applies to all Australian businesses and is administered by the Australian Competition and Consumer Commission (ACCC) (About the ACL). The ACCC has analysed net-zero claims and other forms of greenwashing in a recent study (Greenwashing by businesses in Australia, pages 3 and 5), which upon further examination by the ACCC can result in a breach of the ACL (Greenwashing by businesses in Australia, page 4). They have identified concerns over companies' claims to be "carbon positive" or "net zero" (Greenwashing by businesses in Australia, pages 5 and 6), for instance, and have pledged to update guidance materials and engage with selected businesses to improve compliance with the ACL (Greenwashing by businesses in Australia, page 9). The specifics of the guidelines are not known. One guideline that could be updated is the 2011 "Green Marketing and the Australian Consumer Law", which broadly considers carbon neutrality, but could be more specific and, thus, effective (page 14).About the ACL: https://consumer.gov.au/index.php/australian-consumer-law

Greenwashing by businesses in Australia: https://www.accc.gov.au/system/files/Greenwashing%20by%20businesses%20in%20Australia.pdf

Green Marketing and the Australian Consumer Law: https://www.accc.gov.au/system/files/Green%20marketing%20and%20the%20ACL.pdf		All businesses in AustraliaCompetition and consumer protection authorityAustralian Competition and Consumer Commission (ACCC)Guideline20232023Does not reference standards
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16/08/2023AU-014AU - AustraliaClaims and financial product standardsInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedClimate Active CertificationVoluntary label for carbon-neutral claimsThe Climate Action Initiative is a partnership between the federal government and the private sector (About us, 2023). The goal of the initiative is to incentivize businesses to make carbon-neutral claims, backed by a voluntary climate label (About us, 2023 and Governing Corporate Claims, page 19).
The certification is available for organizations, products, services, buildings, or precincts and is evaluated against the Climate Active Carbon Neutral Standard (Certification 2021), from 2022 (Tools and resources, 2022).		About us, 2023: https://www.climateactive.org.au/what-climate-active/about-us

Governing Corporate Claims: https://www.carbon-mechanisms.de/fileadmin/media/dokumente/Publikationen/Policy_Paper_03_2022_Claims.pdf		Organizations, products, services, buildings or precincts in AustraliaClimate initiativeClimate Action InitiativeStandard20102010Is aligned with standardsISO 14064
ISO 14040
ISO 14065
GHG Protocol
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11/08/2023AU-015AU - AustraliaClaims and financial product standardsInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedAustralian Consumer LawRegulates misleading advertisementsThe Australian Consumer Law (ACL) applies to all Australian businesses and is administered by the Australian Competition and Consumer Commission (ACCC) (About the ACL). The ACL states that businesses must not give false or misleading information, which is classified as an unfair practice (Australian Consumer Law, Schedule 2, Sections 18 and 29). Although net-zero claims are not specifically regulated, the ACCC has analysed net-zero claims and other forms of greenwashing in a recent study (Greenwashing by businesses in Australia, pages 3 and 5), which upon further examination by the ACCC can result in a breach of the ACL (Greenwashing by businesses in Australia, page 4). This study is discussed in a separate tracker entry.About the ACL: https://consumer.gov.au/index.php/australian-consumer-law

Australian Consumer Law: https://www.legislation.gov.au/Details/C2023C00043/Html/Volume_4#_Toc128658998

Greenwashing by businesses in Australia: https://www.accc.gov.au/system/files/Greenwashing%20by%20businesses%20in%20Australia.pdf		All businesses in AustraliaCompetition and consumer protection authorityAustralian Competition and Consumer Commission (ACCC)Law20102011Does not reference standards
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01/08/2023AU-016AU - AustraliaDisclosureInstrument identifiedDraft phaseCarbon-specificMandates action21Record not regulatedClimate-related financial disclosure - Consultation paperDrafts a TCFD-aligned disclosure regulationThe Australian Government (Treasury) opened a consultation to design and implement standardised climate-related financial disclosure regulation. The plan states that the policy would be implemented in a phased approach, starting with large, listed entities in 2024. The disclosures would require alignment with the TCFD and might encompass ISSB (Climate-related financial disclosure consultation, pages 6 and 9). It document should be open for further consultation in 2023 (check the "Description" link).Climate-related financial disclosure consultation: https://treasury.gov.au/sites/default/files/2022-12/c2022-314397_0.pdf

Description: https://treasury.gov.au/consultation/c2022-314397		Large listed entitiesExecutiveTreasuryRegulation2022Not applicableIs aligned with standardsISSB
TCFD
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03/05/2023AU-017AU - AustraliaDisclosureInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedRegulatory Guide 228Includes climate change (transitional and physical) as a risk that can be disclosed in a prospectusThe Corporations Act is administered by the Australian Securities and Investments Commission (ASIC) and sets out a framework to regulate disclosure documents that help investors make informed decisions. There are various types of financial disclosure documents (Corporations Act, item 709). The Regulatory Guide 228 deals with the most common type of disclosure document - a prospectus. According to the guide, a prospectus must disclose the risks associated with a company’s business model, which can include climate change risks (transitional and physical risks) (RG 228.77, Table 7). Therefore, although institutions might include climate change risks in their disclosure of information, doing so is not mandatory.The Corporations Act: https://www.legislation.gov.au/Details/C2018C00031/Html/Volume_3

RG 248: https://download.asic.gov.au/media/5230057/rg228-published-12-august-2019.pdf

Additional information on climate disclosure by Australian companies: https://asic.gov.au/media/4871341/rep593-published-20-september-2018.pdf		Issuers of securitiesFinancial regulatory authorityAustralian Securities and Investments Commission (ASIC)Regulatory Guidance20192019Does not reference standards
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03/05/2023AU-018AU - AustraliaDisclosureInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedPrudential Practice Guide (PPG) 229Provides TCFD-aligned guidanceThe Australian Prudential Regulation Authority (APRA) is an independent statutory authority that supervises institutions across banking, insurance and pension funds. As such, it produces regulations on risk management and governance (page 4). The PPG 229 provides guidance on how the institutions under APRA's regulations can be prudent concerning climate risks and, therefore, comply with regulations (page 5). Climate risk management in the PPG is in line with the TCFD (page 5). The PPG is not enforceable (page 4), but new regulations might arise from this guidance.PPG 229: https://www.apra.gov.au/sites/default/files/2021-11/Final%20Prudential%20Practice%20Guide%20CPG%20229%20Climate%20Change%20Financial%20Risks.pdfFinancial institutionsFinancial regulatory authorityAustralian Prudential Regulation Authority (APRA)Guideline20212021Is aligned with standardsTCFD
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02/05/2023AU-019AU - AustraliaDisclosureInstrument identifiedApprovedBroad-basedDoes not mandate action50Record not regulatedRegulatory Guide 247Includes climate as a material risk that (if material) must be discussed in reports by listed companiesThe Corporations Act is administered by the Australian Securities and Investments Commission (ASIC) and requires various entities to prepare annual directors' reports (item 292(1)). ASIC's Regulatory Guide 247 is directed to listed entities and specifies a section of the directors' report, the Operating and Financial Review (OFRs). According to the Guide, OFRs must include a discussion of environmental (including climate) risks if they are material (items RG 247.64 and RG 247.66). While the definitions of environmental risks are broad enough to encompass climate risks, they are not specifically defined or required. Moreover, although institutions might include climate change risks in their disclosure of information, doing so is not mandatory.The Corporations Act: https://www.legislation.gov.au/Details/C2018C00031/Html/Volume_2

RG 247: https://download.asic.gov.au/media/5230063/rg247-published-12-august-2019.pdf

Additional information on climate disclosure by Australian companies: https://asic.gov.au/media/4871341/rep593-published-20-september-2018.pdf		Listed entitiesFinancial regulatory authorityAustralian Securities and Investments Commission (ASIC)Regulatory Guidance20192019Encourages actors to follow the standardsTCFD
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05/07/2023AU-020AU - AustraliaProcurementInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedSustainable Procurement GuideIncludes reduction of GHG emissions as an option that can be taken into consideration when valuing a purchaseThe Sustainable Procurement Guide provides guidance on how to consider sustainability in the procurement process (Sustainable Procurement Guide, page 7). One of the factors that can be included when calculating value for money is greenhouse gas emissions (page 8). The Guide, however, is not mandatory.Sustainable Procurement Guide: https://www.dcceew.gov.au/sites/default/files/documents/sustainable-procurement-guide.pdfAll Commonwealth procurementsExecutiveDepartment of Agriculture, Water and the EnvironmentGuideline20212021The standard is cited in the textISO 20400
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05/07/2023AU-021AU - AustraliaProcurementInstrument identifiedApprovedBroad-basedDoes not mandate action50Record not regulatedCommonwealth Procurement RulesIncludes climate-based criteria as an option that can be taken into consideration when valuing a purchaseAs stated in the Commonwealth Procurement Rules, environmental sustainability (climate change impact included) must be considered when considering value for money "where there is opportunity for sustainability" (pages 11-12). This opportunity is to be assessed by governmental bodies using the Sustainable Procurement Guide (page 12). Because environmental sustainability is to be "considered" only when there is "opportunity" (without a definition of such opportunities), we classify this aspect of the Commonwealth Procurement Rules as non-mandatory. Among sustainability factors, climate-specific considerations are a new option (included in July 2022) that officials can consider when evaluating a purchase's sustainability (page 12). The climate consideration is general enough to fit mitigation goals through net zero or decarbonization requirements, but these are not clearly defined. For this reason, we classifiy the Rules as broad-based.Commonwealth Procurement Rules: https://www.finance.gov.au/sites/default/files/2022-06/CPRs%20-%201%20July%202022.pdfAll Commonwealth procurementsExecutiveDepartment of FinanceRules20222022The standard is cited in the textISO 20400
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25/05/2023AU-022AU - AustraliaTransition plansInstrument identifiedDraft phaseCarbon-specificMandates action21Record not regulatedClimate-related financial disclosure - Consultation paperDrafts a TCFD-aligned disclosure regulation, which includes transition plansThe Australian Government (Treasury) opened a consultation to design and implement standardised climate-related financial disclosure regulation. The plan states that the policy would be implemented in a phased approach, starting with large, listed entities in 2024. The disclosures would require alignment with the TCFD and might encompass ISSB (Climate-related financial disclosure consultation, pages 6 and 9). It document should be open for further consultation in 2023 (check the "Description" link). Transition plans are among the documents that can be required by the new instrument (Climate-related financial disclosure consultation, pages 14-15).Climate-related financial disclosure consultation: https://treasury.gov.au/sites/default/files/2022-12/c2022-314397_0.pdf

Description: https://treasury.gov.au/consultation/c2022-314397		Large listed entitiesExecutiveTreasuryRegulation2022Not applicableIs aligned with standardsISSB
TCFD
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16/08/2023AU-023AU - AustraliaTransition plansInstrument identifiedDraft phaseCarbon-specificDoes not mandate action20Record not regulatedSetting, tracking and achieving Australia’s
emissions reduction targets		Consults on improvements to Australia's methodology for measuring progress towards its NDCThe Climate Change Authority released the methodology for evaluating Australia's progress towards net zero in 2022 (First annual progress report, 2022, pages 63-65), discussed in another tracker entry. The methodology itself does not mandate any action to be taken but is carbon-specific. The Authority is consulting on the methodology (Setting, tracking and achieving Australia’s emissions reduction targets, pages 11-17), but this should not change its status as non-mandatory and carbon-specific.
The consultation might have effects on other instruments (Setting, tracking and achieving Australia’s emissions reduction targets, page 5), which should be followed in the "Consultation webpage".		First annual progress report, 2022: https://www.climatechangeauthority.gov.au/sites/default/files/2022-12/First%20Annual%20Progress%20Report%20FINAL%20pdf.pdf

Setting, tracking and achieving Australia's emissions reduction targets: https://storage.googleapis.com/files-au-climate/cca/p/prj269666b7ef74faa9fbef5/public_assets/Issues%20Paper%202023%20-%20Setting,%20measuring%20and%20achieving%20Australia's%20emissions%20reduction%20targets.pdf

Consultation webpage: https://consult.climatechangeauthority.gov.au/australias-emissions-reduction-targets		Australian governmentExecutiveClimate Change AuthorityPaper2023Not applicableDoes not reference standards
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03/05/2023AU-024AU - AustraliaTransition plansInstrument identifiedDraft phaseCarbon-specificDoes not mandate action20Record not regulatedAPS Net Zero 2030Defines the policy for achieving net zero in the public sectorAPS Net Zero 2030 is the Government’s policy for the Australian Public Service (APS) to reduce its greenhouse gas emissions to net zero by 2030, and transparently report on its emissions from the latter half of 2023. The APS will achieve net zero by actively reducing emissions from government operations and through the use of offsets. This policy is being delivered consistent with Australia’s international commitments and will contribute to the achievement of Australia’s Paris Agreement targets. The 2030 target will initially apply to most non-corporate Commonwealth (governmental) entities. The Government expects to make further decisions to define the policy for the 2030 target before the end of 2023, informed by additional consultation and up-to-date emissions data collected from across the APS. For the 2030 target and for public reporting, the initial focus will be scope 1 emissions and scope 2 emissions. Though as of today the instrument does not mandate actions to other institutions outside government, it is worth checking if the instrument will produce regulatory instruments in the future.APS Net Zero 2030: https://www.finance.gov.au/government/aps-net-zero-emissions-2030Governmental entitiesExecutiveMinistry of FinancePolicy2023Not applicableDoes not reference standards
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16/08/2023AU-025AU - AustraliaTransition plansInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedFirst annual progress reportSets the standard for evaluation of Australia's transitionIn 2022, the Climate Change Authority released the methodology for evaluating Australia's progress towards its NDC targets (First annual progress report, 2022, pages 63-65). The methodology itself does not mandate any action to be taken but is carbon-specific. Importantly, it aims to measure GHG emissions in relation to reduction targets and evaluate the implementation and effectiveness of related policies (First annual progress report, 2022, pages 65-68), being, in practice, a standard for evaluating Australia's implementation of its transition plan.First annual progress report, 2022: https://www.climatechangeauthority.gov.au/sites/default/files/2022-12/First%20Annual%20Progress%20Report%20FINAL%20pdf.pdfAustralian governmentExecutiveClimate Change AuthorityReport20222022Does not reference standards
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25/05/2023AU-026AU - AustraliaTransition plansInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedPrudential Practice Guide (PPG) 229Provides TCFD-aligned guidance, including on setting a transition targetThe Australian Prudential Regulation Authority (APRA) is an independent statutory authority that supervises institutions across banking, insurance and pension funds. As such, it produces regulations on risk management and governance (page 4). The PPG 229 provides guidance on how the institutions under APRA's regulations can be prudent concerning climate risks and, therefore, comply with regulations (page 5, items 3-4). The PPG includes guidance on the outline of transition plans ("climate-related target", page 14, item 30). The PPG is not enforceable (page 4), but new regulations might arise from this guidance.PPG 229: https://www.apra.gov.au/sites/default/files/2021-11/Final%20Prudential%20Practice%20Guide%20CPG%20229%20Climate%20Change%20Financial%20Risks.pdfFinancial institutionsFinancial regulatory authorityAustralian Prudential Regulation Authority (APRA)Guideline20212021Is aligned with standardsTCFD
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16/08/2023BR-027BR - BrazilClaims and financial product standardsInstrument identifiedPreparatory phaseUnknownUnknown21Record not regulatedGreen label for Amazonian productsAnnounces the creation of a green label for Amazonian products that reduce emissionsThe 2023 Action Plan for the Prevention and Control of Deforestation in the Legal Amazon (PPCDAm) announces the goal of developing a "green label" for Amazonian products (page 85). The label would consider carbon emissions among other environmental factors as criteria (page 85). It is part of the broader goal of fomenting sustainable activities in the Brazilian Amazon (page 84). The Plan states that the label would be developed by the Ministry of Development, Industry, Commerce and Services in partnership with the Ministry of Environment and Climate Change (page 85).PPCDAm, 2023: https://www.gov.br/mma/pt-br/ppcdam_2023_sumario-rev.pdfUnknownUnknownUnknownUnknown2023Not applicableDoes not reference standards
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16/08/2023BR-028BR - BrazilClaims and financial product standardsInstrument identifiedDraft phaseCarbon-specificMandates action21Record not regulatedEnvironmental and Social TaxonomyProposes a taxonomy aimed at directing financial flows towards positive environmental and social activities and labelling financial productsIn 2022, the Legislative proposed a law (Projeto de Lei - PL, in the original language) for the creation of the "Environmental and Social Taxonomy" (PL 2838/2022, Recital). In its justification, the proposed law highlights the goal of protecting consumers from greenwashing (PL 2838/2022, page 7) and the necessity of directing financial resources to reach the Paris goals (PL 2838/2022, pages 8 and 9).
The scope of the Taxonomy covers (i) fiscal benefits, which would be concentrated towards activities identified as "positive" and reduced until extinguished for "negative" activities (PL 2838/2022, Article 1º, § 1º, a and Article 11), (ii) identification of the economical activities carried out by issuers of securities (PL 2838/2022, Article 1º, § 1º, b), and (iii) labelling of financial products (PL 2838/2022, Article 1º, § 1º, c).
Climate-related risks are highlighted as necessary criteria to be considered in the labelling of financial products (PL 2838/2022, Article 1º, § 4º). We, therefore, classify the draft form of the law as mandatory and carbon-related.
The "green" criteria cover the evaluation of GHG emissions and the induction of illegal deforestation (PL 2838/2022, Article 3º, IV and IX). The taxonomy proposes a 7-tier classification system, encompassing from most positive to most negative activities to the environment (PL 2838/2022, Article 6º).
The development and status of the proposed law can be followed through the Congress website (see the PL 2838/2022 webpage). The Taxonomy is also cited as a key action (12.2.2) in the Action Plan for the Prevention and Control of Deforestation in the Legal Amazon (PPCDAm), which adds strenght to the proposed instrument (PPCDAm, 2023 page 93).		PL 2838/2022: https://www.camara.leg.br/proposicoesWeb/prop_mostrarintegra?codteor=2216987&filename=PL%202838/2022

PL 2838/2022 webpage: https://www.camara.leg.br/proposicoesWeb/fichadetramitacao?idProposicao=2339036

PPCDAm, 2023: https://www.gov.br/mma/pt-br/ppcdam_2023_sumario-rev.pdf		Economical activities in BrazilLegislativeCongressDraft Law2022Not applicableDoes not reference standards
30
01/08/2023BR-029BR - BrazilClaims and financial product standardsInstrument identifiedPreparatory phaseUnknownUnknown21Record not regulatedOrdinance CVM/PTE 10/2023Announces the preparation of a sustainable taxonomy and actions to curb greenwashing practicesThe Securities and Exchange Commission (Comissão de Valores Imobiliários - CVM, in the original name and acronym) regulates the securities market in the country. Ordinance (Portaria, in the original language) CVM/PTE 10/2023 established the Commission's sustainable finance policy (Art. 1). The policy aims to promote sustainable finance in the Brazilian securities market (Annex, section 1.1) by, among other actions, targetting supervisory actions to curb greenwashing (Annex, section 1.4) and developing a taxonomy for sustainable finance (Annex, section 1.3). The Ordinance does not include further information about how these actions are going to be carried out, but announces a forthcoming Action Plan (Annex, section 2).Ordinance CVM/PTE 10/2023: https://conteudo.cvm.gov.br/export/sites/cvm/legislacao/portarias/anexos/PortariaPTE2023_010.pdfUnknownFinancial regulatory authoritySecurities and Exchange CommissionUnknownNot applicableNot applicableDoes not reference standards
31
01/08/2023BR-030BR - BrazilClaims and financial product standardsInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedConsumer Protection LawProhibits misleading or abusive advertising, which includes disrespecting "environmental values"Current regulatory understanding could be expanded by including net-zero claims as a part of a specific category (e.g. greenwashing), so that such claims could be specially monitored. In particular, the Consumer Protection Law is compatible with such regulation. Article 37 of the law already prohibits misleading or abusive advertising and highlights that disrespect for environmental values is a form of abuse (§ 2°).Consumer Protection Law: https://www.planalto.gov.br/ccivil_03/leis/l8078compilado.htmEntities involved in commercial activitiesLegislativeCongressLaw19901991Does not reference standards
32
01/08/2023BR-031BR - BrazilClaims and financial product standardsInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedResolution CVM 175/2022Regulates green claims made by fundsThe Securities and Exchange Commission (Comissão de Valores Imobiliários - CVM, in the original name and acronym) regulates the securities market in the country. Resolution CVM 181/2023 includes in Resolution CVM 175/2022 a regulation on green claims made by investment funds (Art. 49). Any fund that makes reference to ESG factors must describe (i) the ESG benefits of the fund and how it plans to reach them (Art. 49, I), (ii) the methodologies used to support the claim (Art. 49, II), (iii) if available, the entity that evaluates/certifies the fund's claims (Art. 49, III), and (iv) how the ESG report will follow the ESG benefits of the fund overtime (Art. 49, IV and Art. 60). Funds that do not aim to generate ESG impacts through their investment cannot make use of ESG terms (Art. 49, "Parágrafo único"). While ESG-related claims are broad enough to encompass climate claims, they are not specifically defined or regulated. Therefore, the Resolution is classified as "broad-based".Resolution CVM 175/2022: https://conteudo.cvm.gov.br/legislacao/resolucoes/resol175.htmlIssuers of securitiesFinancial regulatory authoritySecurities and Exchange CommissionResolution20232023Does not reference standards
33
14/08/2023BR-032BR - BrazilDisclosureInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordCircular Susep nº 666/2022Defines and includes climate change risks in risk management and disclosure systems of insurers and private pension fundsThe Superintendence of Private Insurance (Superintendência de Seguros Privados - Susep, in the original language) is a government agency responsible for insurance and private pensions in Brazil (Susep, 2022). The new regulation mandates the integration of climate considerations by insurers and reinsurers as well as private pension providers (Circular Susep nº 666/2022, Article 1). It does so by (i) defining climate change risks, which include physical, transitional and litigation risks (Circular Susep nº 666/2022, Article 2.II), (ii) including material climate change risks in the risk management structures (Circular Susep nº 666/2022, Article 3, §s 1º and 2º, Article 4), which obliges them to identify, measure, evaluate, monitor, report, control and mitigate these risks (Circular Susep nº 666/2022, Article 4.I), and (iii) monitoring and adding up climate losses (Circular Susep nº 666/2022, Article 4.III.b). The companies, except if small-sized (as defined in Resolution 4553/2017, Article 2), must also select their investment portfolio based on sustainable risks and a clearly-stated investment policy (Circular Susep nº 666/2022, Article 6). The disclosure of material climate-related risks is mandatory (Circular Susep nº 666/2022, Articles 15 and 16). The format of disclosure of information was regulated in a later regulation (Standard Tables for Sustainability Reporting), described in a separate tracker entry.
The Circular also regulates transition plans, which is described in a separate tracker entry.		Susep, 2022: https://www.gov.br/susep/pt-br/acesso-a-informacao/institucional/sobre-a-susep

Circular Susep nº 666/2022:
https://www2.susep.gov.br/safe/scripts/bnweb/bnmapi.exe?router=upload/26128

Resolution 4553/2017: https://normativos.bcb.gov.br/Lists/Normativos/Attachments/50335/Res_4553_v3_L.pdf		Insurers, reinsurers, and private pension providersFinancial regulatory authoritySuperintendence of Private Insurance - SusepCircular20222022Does not reference standards
34
14/08/2023BR-033BR - BrazilDisclosureInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordStandard Tables for Sustainability ReportingDefines the standards that must be followed by insurers and private pension providers when disclosing climate-related informationThe Standard Tables for Sustainability Reporting define the standards according to which the sustainability report demanded by Circular Susep nº 666/2022 must be published (Standard Tables for Sustainability Reporting, Section 1.4). The document provides 5 tables, 3 mandatory and 2 voluntary (Standard Tables for Sustainability Reporting, Section 2).
The "Strategy" table (Tabela EST – Estratégias associadas aos riscos de sustentabilidade, in the original language), which is mandatory, is where the disclosure of climate risks is located (Standard Tables for Sustainability Reporting, Section 2.2). This entry is therefore classified as carbon-specific and mandatory.
Additionally, the "Opportunities" table (Tabela OPO – Oportunidades de negócios associadas aos temas de sustentabilidade, in the original language), which is voluntary, further describes how climate opportunities could be exercised by the companies (Standard Tables for Sustainability Reporting, Section 2.5).
Susep claims that the result sustainability report is aligned with the TCFD recommendations (Susep, 2023), with "Governance", "Strategy" and "Risk management" mandatory tables available described in sections 2.1 - 2.3.		Standard Tables for Sustainability Reporting: https://www.gov.br/susep/pt-br/arquivos/arquivos-regulacao-prudencial/manual-tabelas-de-sustentabilidade-versao-abr23-e-vigencia-abr23.pdf

Susep, 2023: https://www.gov.br/susep/pt-br/central-de-conteudos/noticias/2023/abril/susep-divulga-tabelas-padrao-para-o-relatorio-de-sustentabilidade		Insurers, reinsurers, and private pension providersFinancial regulatory authoritySuperintendence of Private Insurance - SusepStandard20232023Is aligned with standardsTCFD
35
10/05/2023BR-034BR - BrazilDisclosureInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordResolution CVM 59/2021Mandates the disclosure and oversight of climate change risksThe Securities and Exchange Commission (Comissão de Valores Imobiliários - CVM, in the original name and acronym) regulates the securities market in the country. In 2021 and 2022, Resolutions incorporated climate risks in financial disclosure documents. While the Commission does not yet mandate the disclosure of climate risks following a particular standard (Resolution CVM 80/2022, Annex C, 1, g and C, 1.9, i), it requires climate risks to be described and oversaw (Resolution CVM 80/2022, Annex C, 7.1, f).
More specifically, as of 2023, issuers of securities must disclose and inform, on a "comply or explain" basis (Resolution CVM 80/2022, Annex C, 1.9, i), (i) whether they are taking into effect recommendations from TCFD or other recognized entities (Resolution CVM 80/2022, Annex C, 1, g), (ii) if they carry out GHG inventories, the scope of inventoried emissions and the link to this information (Resolution CVM 80/2022, Annex C, 1.9, h), (iii) the description of climate risks related to its operation (Resolution CVM 80/2022, Annex C, 4.1, L), and (iv) the role of management bodies in assessing, managing and oversight of climate-related risks and opportunities (Resolution CVM 80/2022, Annex C, 7.1, f).
The new pieces of information are part of a form that the entities must disclose periodically (Resolution CVM 80/2022, Art. 22, II), at least annually (Resolution CVM 80/2022, Art. 25, § 1º).		Resolution CVM 59/2021: https://conteudo.cvm.gov.br/legislacao/resolucoes/resol059.html

Resolution CVM 80/2022, updated by Resolution CVM 59/2021: https://conteudo.cvm.gov.br/legislacao/resolucoes/resol080.html		Issuers of securitiesFinancial regulatory authoritySecurities and Exchange CommissionResolution20212023Encourages actors to follow the standardsTCFD
36
09/05/2023BR-035BR - BrazilDisclosureInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordResolution CMN 4943/2021Defines and includes climate change risks in risk management and disclosure systems of large and medium-sized financial institutionsIn September 2021, the Brazilian Central Bank (Banco Central do Brasil - BCB, in the original name and acronym) and the National Monetary Council (Conselho Monetário Nacional - CMN, in the original name and acronym) published a series of resolutions to upgrade the ESG considerations enforced on the financial institutions operating in the country. Resolution CMN 4943/2021 is one of them and updates a previous resolution (CMN 4557/2017).
The new resolution improves regulation around the structures for risk and capital management, as well as the disclosure of information (Resolution CMN 4557/2017, Art 1). It does so by (i) defining climate change risks, which include physical and transitional risks (Resolution CMN 4557/2017 Art. 38-C), (ii) including climate change risks in the risk management structures of large and medium-sized financial institutions (as defined in Resolution BCB 4553/2017), which obliges them to identify, measure, evaluate, monitor, report, control and mitigate these risks (Resolution CMN 4557/2017 Art. 6, VIII, Art 38-D, Art. 38-E), and (iii) monitoring and adding up climate losses (Resolution CMN 4557/2017, Art. 34 caput and § 2º). The disclosure of such pieces of information is mandatory (Resolution 4557/2017, Art. 2, III and Art. 56) and was regulated in a later regulation (BCB 139/2021).
Moreover, it is worth noticing that the addition of climate risks to the Resolution automatically impacts essential financial instruments, such as the Risk Appetite Statements (RAS) and the Integrated Risk Management, which from then on must take climate risks into account (Vote CMN 68/2021, page 7).		Resolution CMN 4943/2021: https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?tipo=Resolu%C3%A7%C3%A3o%20CMN&numero=4943

Resolution CMN 4557/2017, updated by CMN 4943/2021: https://normativos.bcb.gov.br/Lists/Normativos/Attachments/50344/Res_4557_v4_P.pdf

Vote CMN 68/2021: https://normativos.bcb.gov.br/Votos/CMN/202168/VOTO_DO_CMN_68_2021_BCB_SECRE_Numerado_Manualmente_01.pdf

Resolution 4553/2017: https://normativos.bcb.gov.br/Lists/Normativos/Attachments/50335/Res_4553_v3_L.pdf		Large and medium-size financial institutionsFinancial regulatory authorityNational Monetary CouncilResolution20212022Does not reference standards
37
09/05/2023BR-036BR - BrazilDisclosureInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordResolution CMN 4944/2021Defines and includes climate change risks in risk management and disclosure systems of small-sized financial institutionsIn September 2021, the Brazilian Central Bank (Banco Central do Brasil - BCB, in the original name and acronym) and the National Monetary Council (Conselho Monetário Nacional - CMN, in the original name and acronym) published a series of resolutions to upgrade the ESG considerations enforced on the financial institutions operating in the country. Resolution CMN 4944/2021 is one of them and updates a previous resolution (CMN 4606/2017). It is the simplified version of Resolution CMN 4943/2021 for small-size, low-risk financial institutions (as defined in Resolution BCB 4553/2017, Article 2).
The new resolution improves regulation around risk management. It does so by (i) defining climate change risks (Resolution CMN 4606/2017, Art. 27-C), and (ii) including climate change risks in risk management structures (Resolution CMN 4606/2017, Art. 20, V), which obliges them to identify, measure, evaluate, monitor, report, control and mitigate these risks (Resolution CMN 4606/2017, Art. 20). The disclosure of such information is simplified in relation to medium and large-scale institutions. Although the information must be available for the verification of BCB (Resolution CMN 4606/2017, Art. 32-B), the regulation is silent in relation to its method of disclosure.		Resolution CMN 4944/2021: https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?tipo=Resolu%C3%A7%C3%A3o%20CMN&numero=4944

Resolution CMN 4606/2017, updated by CMN 4944/2021: https://normativos.bcb.gov.br/Lists/Normativos/Attachments/50454/Res_4606_v7_L.pdf


Resolution 4553/2017: https://normativos.bcb.gov.br/Lists/Normativos/Attachments/50335/Res_4553_v3_L.pdf		Small-sized financial institutions operating in the countryFinancial regulatory authorityNational Monetary CouncilResolution20212022Does not reference standards
38
05/05/2023BR-037BR - BrazilDisclosureInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordResolution BCB 139/2021Partially enforces the disclosure of TCFD's core recommendations to financial institutions operating in BrazilIn September 2021, the Brazilian Central Bank (Banco Central do Brasil - BCB, in the original name and acronym) and the National Monetary Council (Conselho Monetário Nacional - CMN, in the original name and acronym) published a series of resolutions to upgrade the ESG considerations enforced on the financial institutions operating in the country. Resolution BCB 139/2021 is one of them. It enforces the TDCF recommendations to financial institutions in Brazil (Vote 198/2021-BCB, item 8) via the yearly publication of the Social, Environmental and Climate Risks and Opportunities Report (GRSAC Report, in the original acronym) (Resolution BCB 139/2021, Article 2). The report is the disclosure mechanism for the instruments defined in Resolution CMN 4943/2021.
The enforcement is done in a tiered approach. Large and medium-sized financial institutions (as defined in Resolution BCB 4553/2017) must follow TCFD governance recommendations (Vote 198/2021-BCB, item 8-I and Resolution BCB 139/2021, Articles 3 and 9). Moreover, the strategy and risk management recommendations must be followed by larger financial institutions (Vote 198/2021-BCB, item 8-I and Resolution BCB 139/2021, Articles 3 and 8). The Resolution does not enforce the TCFD recommendations on metrics and targets. Rather, the Resolution classifies this set of recommendations as optional (Article 4).
Missing from the Resolution (even as optional items of disclosure), however, are the important TCFD recommendations around the disclosure of Scope 1, Scope 2 and, when appropriate, Scope 3 greenhouse gas (GHG) emissions (TCFD Core Recommendations, Metrics and Targets, b). The BCB claim that more stringent enforcement will be done in future regulations (Vote 198/2021-BCB, item 8-II), an advocacy opportunity.		Resolution BCB 139/2021: https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?tipo=Resolu%C3%A7%C3%A3o%20BCB&numero=139

Vote 198/2021-BCB: https://normativos.bcb.gov.br/Votos/BCB/2021198/Voto_do_BC_198_2021.pdf

TCFD Core Recommendations: https://www.fsb-tcfd.org/recommendations/#core-recommendations

Resolution 4553/2017: https://normativos.bcb.gov.br/Lists/Normativos/Attachments/50335/Res_4553_v3_L.pdf		Large and medium-size financial institutionsFinancial regulatory authorityCentral Bank of BrazilResolution20212022Requires actors to follow the standardsTCFD
39
10/05/2023BR-038BR - BrazilProcurementInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedLaw 14133/2021 - Law of Tenders and Administrative ContractsSets the overarching rules for public procurement in BrazilThe national procurement law (14133/2021) regulates an overarching set of purchases and contracts done by the national, state and municipal governments. National sustainable development is one of its core principles (Art. 5) and goals (Art. 11, IV). As a result, when evaluating proposals, government officials can take a product's whole life cycle into account (Art. 34, § 1º), as well as environmental impacts (Art. 18, § 1º, XII). However, the legislation and its current regulamentations are silent in relation to net zero goals and/or how sustainability should be pursued.
Brazil's previous procurement law (8666/1993), which was valid until April 2023, counted with a Commission for Sustainability (Decree 7746/2012). Proposing a new committee, with the role of regulating sustainable and net zero purchases, is a potential opportunity.		Law 14133/2021: https://www.planalto.gov.br/ccivil_03/_ato2019-2022/2021/lei/l14133.htm

Law 8666/1993: https://www.planalto.gov.br/ccivil_03/leis/l8666cons.htm

Decree 7746/2012: https://www.planalto.gov.br/ccivil_03/_Ato2011-2014/2012/Decreto/D7746.htm		All purchases in the countryLegislativeCongressLaw20212023Does not reference standards
40
14/08/2023BR-039BR - BrazilTransition plansInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordCircular Susep nº 666/2022Mandates the disclosure of transition plans to a low-carbon economy by insurers and private pension providersThe Superintendence of Private Insurance (Superintendência de Seguros Privados - Susep, in the original language) is a government agency responsible for insurance and private pensions in Brazil (Susep, 2022). The new regulation mandates the integration of climate considerations by insurers and reinsurers as well as private pension providers (Circular Susep nº 666/2022, Article 1). In doing so, it defines climate change risks, which include physical, transitional and litigation risks (Circular Susep nº 666/2022, Article 2.II). In particular, for transition plan considerations, the Circular requires the publication of a sustainability policy (Circular Susep nº 666/2022, Article 9.VI), which must clearly describe how the organizations will manage sustainability aspects, including the "transition to a low carbon economy" (Circular Susep nº 666/2022, Article 8, § 1º, IV). Therefore, we classify this entry as "carbon-specific" and mandatory. The actions that should follow the sustainability policy must cover the development of new financial products and services and the day-to-day operation and activities of the companies (Circular Susep nº 666/2022, Article 11). These actions and how they relate to the company's risk management must be disclosed in a yearly sustainability report (Circular Susep nº 666/2022, Article 15). The format of disclosure of information was regulated in a later regulation (Standard Tables for Sustainability Reporting), described in a separate tracker entry.
The Circular also regulates the disclosure of climate risks, which is described in a separate tracker entry.		Susep, 2022: https://www.gov.br/susep/pt-br/acesso-a-informacao/institucional/sobre-a-susep

Circular Susep nº 666/2022:
https://www2.susep.gov.br/safe/scripts/bnweb/bnmapi.exe?router=upload/26128

Resolution 4553/2017: https://normativos.bcb.gov.br/Lists/Normativos/Attachments/50335/Res_4553_v3_L.pdf		Insurers, reinsurers, and private pension providersFinancial regulatory authoritySuperintendence of Private Insurance - SusepCircular20222022Does not reference standards
41
14/08/2023BR-040BR - BrazilTransition plansInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordStandard Tables for Sustainability ReportingDefines the standards that must be followed by insurers and private pension providers when disclosing climate-related informationThe Standard Tables for Sustainability Reporting define the standards according to which the sustainability report demanded by Circular Susep nº 666/2022 must be published (Standard Tables for Sustainability Reporting, Section 1.4). The document provides 5 tables, 3 mandatory and 2 voluntary (Standard Tables for Sustainability Reporting, Section 2).
The "Strategy" table (Tabela EST – Estratégias associadas aos riscos de sustentabilidade, in the original language), which is mandatory, is where the disclosure of the strategy to adapt to a low carbon economy is located (Standard Tables for Sustainability Reporting, Section 2.2). This entry is therefore classified as carbon-specific and mandatory.
Susep claims that the result sustainability report is aligned with the TCFD recommendations (Susep, 2023), with "Governance", "Strategy" and "Risk management" mandatory tables available described in sections 2.1 - 2.3.		Standard Tables for Sustainability Reporting: https://www.gov.br/susep/pt-br/arquivos/arquivos-regulacao-prudencial/manual-tabelas-de-sustentabilidade-versao-abr23-e-vigencia-abr23.pdf

Susep, 2023: https://www.gov.br/susep/pt-br/central-de-conteudos/noticias/2023/abril/susep-divulga-tabelas-padrao-para-o-relatorio-de-sustentabilidade		Insurers, reinsurers, and private pension providersFinancial regulatory authoritySuperintendence of Private Insurance - SusepStandard20232023Is aligned with standardsTCFD
42
14/06/2023BR-041BR - BrazilTransition plansInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordResolution BCB 139/2021Partially enforces the disclosure of TCFD's core recommendations to financial institutions operating in BrazilIn September 2021, the Brazilian Central Bank (Banco Central do Brasil - BCB, in the original name and acronym) and the National Monetary Council (Conselho Monetário Nacional - CMN, in the original name and acronym) published a series of resolutions to upgrade the ESG considerations enforced on the financial institutions operating in the country. Resolution BCB 139/2021 is one of them. It enforces the TDCF recommendations to financial institutions in Brazil (Vote 198/2021-BCB, item 8) via the yearly publication of the Social, Environmental and Climate Risks and Opportunities Report (GRSAC Report, in the original acronym) (Resolution BCB 139/2021, Article 2). The report is the disclosure mechanism for the instruments defined in Resolution CMN 4943/2021.
The enforcement is done in a tiered approach. Large and medium-sized financial institutions (as defined in Resolution BCB 4553/2017) must follow TCFD governance recommendations (Vote 198/2021-BCB, item 8-I and Resolution BCB 139/2021, Articles 3 and 9). Moreover, the strategy and risk management recommendations must be followed by larger financial institutions (Vote 198/2021-BCB, item 8-I and Resolution BCB 139/2021, Articles 3 and 8). Considering that the Strategy recommendation of TCFD covers key aspects of transition plans (Task Force on Climate-related Financial Disclosures, 2021, page 39), we understand that the Code is also a "transition plan" regulation. The Resolution does not enforce the TCFD recommendations on metrics and targets. Rather, the Resolution classifies this set of recommendations as optional (Article 4). Missing from the Resolution (even as optional items of disclosure), however, are the important TCFD recommendations around the disclosure of Scope 1, Scope 2 and, when appropriate, Scope 3 greenhouse gas (GHG) emissions (Task Force on Climate-related Financial Disclosures, 2021, page 4). The BCB claim that more stringent enforcement will be done in future regulations (Vote 198/2021-BCB, item 8-II), an advocacy opportunity.		Resolution BCB 139/2021: https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?tipo=Resolu%C3%A7%C3%A3o%20BCB&numero=139

Vote 198/2021-BCB: https://normativos.bcb.gov.br/Votos/BCB/2021198/Voto_do_BC_198_2021.pdf

Task Force on Climate-related Financial Disclosures, 2021: https://assets.bbhub.io/company/sites/60/2021/07/2021-Metrics_Targets_Guidance-1.pdf

Resolution 4553/2017: https://normativos.bcb.gov.br/Lists/Normativos/Attachments/50335/Res_4553_v3_L.pdf		Large and medium-size financial institutionsFinancial regulatory authorityCentral Bank of BrazilResolution20212022Requires actors to follow the standardsTCFD
43
09/05/2023BR-042BR - BrazilTransition plansInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordResolution CMN 4945/2021Mandates the planning of a transition to a low-carbon economy by financial institutionsIn September 2021, the Brazilian Central Bank (Banco Central do Brasil - BCB, in the original name and acronym) and the National Monetary Council (Conselho Monetário Nacional - CMN, in the original name and acronym) published a series of resolutions to upgrade the ESG considerations enforced on the financial institutions operating in the country. Resolution CMN 4945/2021 is one of them and mandates that all financial institutions in Brazil should establish a Social, Environmental and Climate Responsibility Policy (PRASC, in the original acronym) (Resolution CMN 4945/2017, Art. 2). Each PRASC must consider the climate impacts related to its operations and the creation of products/services, taking into consideration the risks identified by the institutions, as regulated in Resolutions CMN 4943/2021 and 4944/2021 (Resolution CMN 4945/2021, Art. 2, II).
Specifically, PRASC must include actions to transition to a low-carbon economy, as well as to reduce the impacts of weather-related events (Resolution CMN 4945/2021, Art. 3, § 1º, IV). For this reason, we classify this entry as "carbon-specific" and mandatory.
The Resolution does not set standards or criteria to which entities should comply when planning and implementing their transition. Instead, each institution is left to define and monitor their own proposal (Resolution CMN 4945/2021, Art. 4).		Resolution CMN 4945/2021: https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?tipo=Resolu%C3%A7%C3%A3o%20CMN&numero=4945Financial institutions operating in BrazilFinancial regulatory authorityNational Monetary CouncilResolution20212022Does not reference standards
44
10/05/2023BR-043BR - BrazilTransition plansInstrument identifiedPreparatory phaseUnknownUnknown21Record not regulatedUnknownNational policy for sustainable transitionThe government has announced an "Ecological transition plan", which includes climate change as one of its main areas. It is worth following the development of this plan. A draft version of the plan should be available in May/2023. Because the text is not yet available and we cannot confirm if it could be classified as a transition plan regulation.https://www2.camara.leg.br/atividade-legislativa/comissoes/comissoes-permanentes/cmads/noticias/comissao-de-meio-ambiente-ouve-ministro-haddad-sobre-plano-de-transicao-ecologica

https://icleconomia.com.br/ministerio-da-fazenda-plano-transicao-ecologica/		UnknownUnknownUnknownUnknownNot applicableNot applicableDoes not reference standards
45
02/08/2023CA-044CA - CanadaClaims and financial product standardsInstrument identifiedDraft phaseCarbon-specificDoes not mandate action20Record not regulatedTaxonomy Roadmap ReportDrafts a taxonomy for financial productsThe Sustainable Finance Action Council (SFAC) was created by the Canadian Government in 2021. It brings together public and private sector experts in the development of a sustainable finance market in Canada (Department of Finance Canada, 2021). The Taxonomy Roadmap Report proposes a voluntary taxonomy (Taxonomy Roadmap Report, page 3) in which companies that issue financial products claimed to support "green" or "transition" goals would be required to (i) comply with the pre-determined definitions of "green" and "transition" activities in the taxonomy, (ii) do no harm, and (iii) be backed up by company-level net zero targets, transition plans, and climate disclosures (Taxonomy Roadmap Report, page 4). Based on these characteristics, the taxonomy is classified as "non-mandatory" and "carbon-specific". The report announces the goal of finishing a short-form taxonomy in 2023 and in full by 2025 (Taxonomy Roadmap Report, page 7).Department of Finance Canada, 2021: https://www.canada.ca/en/department-finance/news/2021/05/canada-launches-sustainable-finance-action-council.html

Taxonomy Roadmap Report: https://www.canada.ca/content/dam/fin/publications/sfac-camfd/2022/09/2022-09-eng.pdf		Issuers of financial productsUnknownUnknownUnknown2022Not applicableEncourages actors to follow the standardsTCFD
GHG Protocol
46
08/05/2023CA-045CA - CanadaClaims and financial product standardsInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedCompetition Act. 52Regulates misleading representationsThere is room for expanding the current regulatory understanding by including net-zero claims as a part of a specific category (e.g. greenwashing), so that such claims could be specially monitored. In particular the Competition Act. 52 is compatible with such regulation. It has a section on false or misleading representations. It states that no person shall, for the purpose of promoting, directly or indirectly, the supply or use of a product or for the purpose of promoting, directly or indirectly, any business interest, by any means whatever, knowingly or recklessly make a representation to the public that is false or misleading in a material respect (Part IV, 52). Any person who contravenes this subsection is guilty of an offence and liable (Part IV, 5).https://laws.justice.gc.ca/PDF/C-34.pdfCommercial activities in CanadaLegislativeParliamentAct20232023Does not reference standards
47
08/05/2023CA-046CA - CanadaClaims and financial product standardsInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedConsumer Packaging and Labelling ActProhibits misleading advertisement in package products, which can lead to greenwashingFurther regulations, particularly for prepackaged non-food consumer products, might be possible under the Consumer Packaging and Labelling Act. The Consumer Packaging and Labelling Act requires that prepackaged non-food consumer products bear accurate and meaningful labelling information to help consumers make informed purchasing decisions.
Section 7 of the Act prohibits false and misleading representations relating to prepackaged products. All information on a package, whether in symbols or words, must be neither false nor misleading to the consumer. The administration and enforcement of the Act and Regulations, as they relate to non‑food products, is under the Competition Bureau, Industry Canada. The Competition Bureau is an independent law enforcement agency that protects and promotes competition for the benefit of Canadian consumers and businesses. The Competition Bureau enforces the Competition Act, the Textile Labelling Act, and the Consumer Packaging and Labelling Act. These are laws that apply directly to environmental claims that are false, misleading or not based on adequate and proper testing. The Bureau warns that products or services are portrayed as having more environmental benefits than they truly have, it may be greenwashing, which could be illegal.		Consumer Packaging and Labelling Act https://laws-lois.justice.gc.ca/PDF/C-38.pdf Competition Bureau
https://ised-isde.canada.ca/site/competition-bureau-canada/en/environmental-claims-and-greenwashing		Products in CanadaLegislativeParliamentAct20192019Does not reference standards
48
20/07/2023CA-047CA - CanadaDisclosureInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordGuideline B-15: Climate Risk ManagementMandates the disclosure of climate-related risks by financial institutionsAs a result of the 2022 budget commitments (Federal Budget 2022, page 106), one of the regulatory developments is Guideline B-15: Climate Risk Management. Building on the draft guideline released in May 2022, in March 2023, the Office of the Superintendent of Financial Institutions (OSFI) published Guideline B-15, which sets out OSFI’s expectations for the management of climate-related risks for federally regulated financial institutions (News release, 2023).
The Guideline mandates annual climate-related financial disclosure by financial institutions on a phased approach, depending on the size of the institution, between 2024 and 2026 (Guideline B-15, Chapter 2, section IV.29; Guideline B-15, Annex 2-2; Guideline B-15, Chapter 2, section VII.33). The Guideline does not mandate a specific standard of disclosure (Guideline B-15, A1) but rather encourages institutions to follow TCFD recommendations, and establishes minimum disclosure items, which are in line with the TCFD items - governance, strategy, risk management, and metrics and targets (Guideline B-15, Annex 2-2).		OSFI guideline B-15
https://www.osfi-bsif.gc.ca/Eng/fi-if/rg-ro/gdn-ort/gl-ld/Pages/b15-dft.aspx

Federal budget 2022
https://www.budget.canada.ca/2022/pdf/budget-2022-en.pdf

News release, 2023: https://www.osfi-bsif.gc.ca/Eng/osfi-bsif/med/Pages/b15-nr.aspx		All federally regulated financial institutions except foreign bank branchesFinancial regulatory authorityOffice of the Superintendent of Financial InstitutionsGuideline20232024Encourages actors to follow the standardsTCFD
GHG Protocol
49
08/05/2023CA-048CA - CanadaDisclosureInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordBudget 2021: A Recovery Plan for Jobs, Growth, and ResilienceCanada's 2021 budget, includes strengthening Public Climate-related DisclosuresCanada's 2021 budget includes strengthening Public Climate-related Disclosures and announces action from Crown Corporations, which are state-owned enterprises. These Corporations are to adopt the TCFD standards, or more rigorous, acceptable standards as an element of their corporate reporting. Large Crown corporations (entities with over $1 billion in assets) must report in calendar year 2022 at the latest. Crown corporations with less than $1 billion in assets should report in calendar year 2024 at the latest, or provide justification as to why climate risks do not have material impact on their operations.
Additionally, the government declares to engage with provinces and territories, with the objective of making climate disclosures, consistent with the Task Force on Climate-related Financial Disclosures, part of regular disclosure practices.
Although the budget is valid only for 2021, the announcement is still valid. Therefore, this record is kept as an active regulation.		https://www.budget.canada.ca/2021/home-accueil-en.htmlCanada’s Crown corporationsExecutiveDepartment of Finance CanadaBudget20212022Requires actors to follow the standardsTCFD
50
08/05/2023CA-049CA - CanadaDisclosureInstrument identifiedDraft phaseCarbon-specificMandates action21Record not regulatedNational Instrument NI 51-107, Disclosure of Climate-related MattersProposed new regulation, National Instrument 51-107 Disclosure of Climate-related Matters for issuers to disclose climate-related information in compliance with TCFD recommendationsOn October 2021, Canadian Securities Administrators (CSA) published for comment its proposed new regulation, National Instrument 51-107 Disclosure of Climate-related Matters. The Proposed instrument would require an issuer to disclose certain climate-related information in compliance with the TCFD recommendations. The CSA received comments on the proposition and, on October 12, 2022, the CSA announced that it was assessing the ISSB and SEC proposals and how they may impact or further inform CSA's proposed climate-related disclosure rule.Proposed regulation 2021: https://www.osc.ca/sites/default/files/2021-10/csa_20211018_51-107_disclosure-update.pdf Update on its status 2022:
https://www.securities-administrators.ca/news/canadian-securities-regulators-consider-impact-of-international-developments-on-proposed-climate-related-disclosure-rule/		All reporting issuers, other than investment funds, issuers of asset-backed securities, designated foreign issuers, SEC foreign issuers, certain exchangeable security issuers and certain credit support issuersFinancial regulatory authorityCanadian Securities Administrators (CSA)Proposed National Instrument2021Not applicableRequires actors to follow the standardsTCFD
51
08/05/2023CA-050CA - CanadaDisclosureInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedNet-Zero ChallengeA voluntary initiative to encourage businesses disclose climate-related information in lign with the TCFDFuture regulations must be possible building on the Net-Zero Challenge. The Challenge is an initiative (unenforced/ not mandatory) created by the Environment and Climate Change Canada Government department that encourages businesses to develop and implement credible and effective plans to transition their facilities and operations to net-zero emissions by 2050. The minimum requirements to join are:
1. Set a net-zero emissions target for 2050 or earlier.
2. Complete a Preliminary Participation Checklist within 12 months of joining.
3. Complete a Comprehensive Participation Checklist within 24 months of joining.
4. Set at least two interim reduction targets.
5. Report on progress annually.
6. Review and update net zero plans every five years.
7. Conduct and make public climate-related financial disclosures (SMEs exempt).

As part of the preliminary and comprehensive net-zero plan, all participants (except SMEs) must provide information on climate-related financial disclosure. Through the Participation Checklists participants must provide evidence that they are providing climate-related financial disclosures based on the recommendations identified by the Task Force on Climate-Related Financial Disclosures.		https://www.canada.ca/en/services/environment/weather/climatechange/climate-plan/net-zero-emissions-2050/challenge/technical-guide.html#toc11All businesses operating in Canada – domestic and multinational – with net-zero aspirationsExecutiveEnvironment and Climate Change CanadaInitiative20222022Requires actors to follow the standardsTCFD
52
05/05/2023CA-051CA - CanadaDisclosureInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedGreening Government Strategy: A Government of Canada DirectiveStrategy to reduce GHG emissions in the governmentGreening Government Strategy: A Government of Canada Directive aims to help to take action on climate change within federal operations and reduce environmental impacts as part of its commitment to have net-zero emissions from government operations by 2050. The strategy was created in 2017 and updated in 2020. The strategy considers the public disclosure of detailed environmental performance information on government operations, including a complete inventory of federal GHG emissions. The government encourages the adoption of the recommendations of the TCFD by federal Crown corporations (This included in Canada's 2021 budget).https://www.canada.ca/en/treasury-board-secretariat/services/innovation/greening-government/strategy.htmlAll core government departments and agenciesExecutiveCentre for Greening Government of the Treasury Board of Canada SecretariatDirective20172017Encourages actors to follow the standardsTCFD
53
05/05/2023CA-052CA - CanadaProcurementInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordPolicy on Green Procurement - Standard on the Disclosure of Greenhouse Gas Emissions and the Setting of Reduction TargetsFor procurements over $25 million, the standard induces suppliers to measure and disclose their greenhouse gas emissions and adopt a science-based target in line with the Paris AgreementThe Policy on Green Procurement seeks to reduce the environmental impacts of government operations, promote environmental stewardship, and adapt to climate change by integrating environmental considerations into the procurement process. In the policy, green procurement is set within the context of achieving value for money. Value for money considers many factors such as cost, performance, availability, quality and environmental performance (Section 4). In March 2023, two new standards were published under the Policy on Green Procurement and is consistent with the Directive on the Management of Procurement. These standards aim to reduce Canada’s GHG emissions and transition to net-zero carbon and climate-resilient operations by 2050. One of the Standards is on the Disclosure of GHG Emissions and the Setting of Reduction Targets. As part of this standard, government organizations must ensure that procurements over $25 million, including taxes, induces suppliers to measure and disclose their greenhouse gas emissions and adopt a science-based target in line with the Paris Agreement (Subsection 3.2.1). Therefore, for businesses bidding on a requirement with an estimated value over $25 million:
i) There may be evaluation criteria or other instructions related to measuring and disclosing your company’s GHG emissions
ii) you may be requested or required to join one of the following initiatives to submit a bid, offer or arrangement or if you are awarded the contract: Canada’s Net-Zero Challenge/ UN Race to Zero/ SBTi/ the Carbon Disclosure Project/ ISO
iii) you may be required to provide other evidence of your company’s commitment and actions toward meeting net-zero targets by 2050
Government organizations are mandated to comply with the directive or explain why they are not complying. But what they need to comply with is "inducing" business to follow the previously mentioned criteria. Therefore, not necessarily the measurement and disclosure of GHG emissions and adoption of science-based targets will be enforced.		Policy on Green Procurement
https://www.tbs-sct.canada.ca/pol/doc-eng.aspx?id=32573

New standards:
https://buyandsell.gc.ca/introducing-two-new-standards-under-the-policy-on-green-procurement

Standard on the Disclosure of Greenhouse Gas Emissions:
https://www.tbs-sct.canada.ca/pol/doc-eng.aspx?id=32743		All departments (Please refer to Financial Administration Act, Section 2 for more detail)ExecutiveCabinet committeeStandard20232023Encourages actors to follow the standardsRace to Zero
SBTi
CDP
Canada’s Net-Zero Challenge
54
05/05/2023CA-053CA - CanadaProcurementInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedGreening Government Strategy: A Government of Canada DirectiveStrategy to reduce GHG emissions in the governmentGreening Government Strategy: A Government of Canada Directive aims to help to take action on climate change within federal operations and reduce environmental impacts as part of its commitment to have net-zero emissions from government operations by 2050. The strategy was created in 2017 and updated in 2020. It expands the scope of the target to include, among others, the procurement of goods and services. Some relevant components considered as part of green procurement and that are part of the Green Procurement policy are:
1. Including criteria that address GHG emissions reduction, sustainable plastics and broader environmental benefits into procurements.
2. Incentivizing major suppliers to adopt a science-based target in line with the Paris Agreement, and to disclose their GHG emissions and environmental performance. (This is adopted in the Standard on the Disclosure of Greenhouse Gas Emissions and the Setting of Reduction Targets pursuant to the Policy on Green Procurement).

A Greening Government Fund has been established. It provides project funding to federal government departments and agencies to reduce greenhouse gas (GHG) emissions in their operations. For instance, it has funded the Buyers for Climate Action (BCA) as part of green procurement initiatives.		Greening Government Strategy:
https://www.canada.ca/en/treasury-board-secretariat/services/innovation/greening-government/strategy.html#toc3-5 Greening Government Fund:
https://www.canada.ca/en/treasury-board-secretariat/services/innovation/greening-government/greening-gov-fund.html		All core government departments and agenciesExecutiveCentre for Greening Government of the Treasury Board of Canada SecretariatDirective20172017Encourages actors to follow the standardsTCFD
55
05/05/2023CA-054CA - CanadaProcurementInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedDirective on the Management of ProcurementSets the overarching rules for public procurement in CanadaIssued in May, 2021, the directive on the Management of Procurement's objective is that the procurement of goods, services and construction obtains the necessary assets and services that support the delivery of programs and services to Canadians while ensuring the best value to the Crown. Among the expected results is that procurements enable operational outcomes and demonstrate sound stewardship and best value consistent with the Government’s socio-economic and environmental objectives. The document itself is not net zero specific, nevertheless the directive references the Policy on Green Procurement to be employed where appropiate.
One of the considerations for procurements' risk, complexity and best value is ensuring strategic category management, including socio-economic and environmental considerations, among others (Section 4.3.4).
It also mentions that, where appropriate, include in procurements environmental considerations in accordance with the Policy on Green Procurement and documenting files accordingly (Section 4.2.7.2).		https://www.tbs-sct.canada.ca/pol/doc-eng.aspx?id=32692Federal government and the LegislativeExecutiveTreasury BoardDirective20212021Does not reference standards
56
20/07/2023CA-055CA - CanadaTransition plansInstrument identifiedDraft phaseCarbon-specificMandates action21Record not regulatedGuideline B-15: Climate Risk ManagementMandates the disclosure of transition plans by financial institutionsBuilding on the draft guideline released in May 2022, in March 2023, the Office of the Superintendent of Financial Institutions (OSFI) published Guideline B-15, which sets out OSFI’s expectations for the management of climate-related risks for federally regulated financial institutions (News release, 2023).
In Chapter 1 – Governance and risk management expectations, principle 1 includes that the federally regulated financial institutions (FRFI) should develop and implement a Climate Transition Plan (Plan), in line with its business plan and strategy, that guides the FRFI’s actions to manage increasing physical risks from climate change, and the risks associated with the transition towards a low-GHG economy (Guideline B-15, Chapter 1, section I.3). Moreover, in developing the Plan, the FRFI should assess the achievability of its Plan under different climate-related scenarios and how it would measure and assess its progress against the Plan (e.g., internal metrics and targets such as GHG emissions) (Guideline B-15, Chapter 1, section I.3). It references the TCFD Guidance on Metrics, Targets, and Transition Plans for additional guidance on elements to consider as part of transition planning (Guideline B-15, Chapter 1, section I.3, footnote 5). According to TCFD guidance, a transition plan is an aspect of an organization’s overall business strategy that lays out a set of targets and actions supporting its transition toward a low-carbon economy, including actions such as reducing its GHG emissions (TCFD Guidance, page 42).
The Guideline, however, has not yet defined the year from which the publication of transition plans is mandatory ("Fiscal year-end for which implementation is expected" = "TBD") (Guideline B-15, Annex 2-2, item b) ii). As a result, the Guideline is classified as in a draft phase for this regulatory domain.		News release, 2023: https://www.osfi-bsif.gc.ca/Eng/osfi-bsif/med/Pages/b15-nr.aspx
Guideline B-15: Climate Risk Management
https://www.osfi-bsif.gc.ca/Eng/fi-if/rg-ro/gdn-ort/gl-ld/Pages/b15-dft.aspx TCFD Guidance
https://assets.bbhub.io/company/sites/60/2021/07/2021-Metrics_Targets_Guidance-1.pdf		All federally regulated financial institutions except foreign bank branchesFinancial regulatory authorityOffice of the Superintendent of Financial InstitutionsGuideline2023Not applicableEncourages actors to follow the standardsTCFD
GHG Protocol
57
08/05/2023CA-056CA - CanadaTransition plansInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedNet-Zero ChallengeA voluntary initiative to encourage businesses to develop transition plansFuture regulations must be possible building on the Net-Zero Challenge. The Challenge is an initiative (unenforced/ not mandatory) created by the Environment and Climate Change Canada Government department that encourages businesses to develop and implement credible and effective plans to transition their facilities and operations to net-zero emissions by 2050. The minimum requirements to join are:
1. Set a net-zero emissions target for 2050 or earlier.
2. Complete a Preliminary Participation Checklist within 12 months of joining.
3. Complete a Comprehensive Participation Checklist within 24 months of joining.
4. Set at least two interim reduction targets.
5. Report on progress annually.
6. Review and update net zero plans every five years.
7. Conduct and make public climate-related financial disclosures (SMEs exempt).

It is required that the comprehensive net-zero plan include the following elements:
1. The GHG emissions inventory baseline, as per the preliminary net-zero plan;
2. At least one of the two interim targets and the net-zero target (see Section 6.0);
3. A high-level description of the scenario analysis conducted to identify net-zero pathways (see Section 5.0);
4. A high-level description of some mitigation strategies (see Section 5.3);
5. A description of the corporate governance strategy (see Section 8.1); and
6. Information on climate-related financial disclosure (see Section 8.2), as per the preliminary net-zero plan.		https://www.canada.ca/en/services/environment/weather/climatechange/climate-plan/net-zero-emissions-2050/challenge.htmlAll businesses operating in Canada – domestic and multinational – with net-zero aspirationsExecutiveEnvironment and Climate Change CanadaInitiative20222022Encourages actors to follow the standardsISO 14064
TCFD
58
08/05/2023CA-057CA - CanadaTransition plansInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedNet-Zero Emissions Accountability ActLegally defines Canada's net zero goal by 2050Future regulations must be possible building on the Canadian Net-Zero Emissions Accountability Act, released in 2021. It aims to create transparency and accountability in Canada’s efforts to achieve net-zero greenhouse gas emissions by the year 2050. It legally binds the Government to achieve net-zero emissions by 2050.
It mentions that the Minister must establish a greenhouse gas emissions reduction plan for achieving the national greenhouse gas emissions target for 2050 (net-zero emissions). Also for each target set for each milestone year with a view to achieving the net-zero target.
It also sets out the Emissions reduction plan contents. It must explain how the greenhouse gas emissions target set out in the plan and the key measures and strategies that the plan describes will contribute to Canada achieving net-zero emissions by 2050.
Canada’s 2030 Emissions Reduction Plan was issued in 2022 to reduce Canada’s emissions by 40-45% from 2005 levels by 2030.		https://laws-lois.justice.gc.ca/eng/acts/c-19.3/fulltext.htmlGovernment of CanadaLegislativeParliamentAct20212021Does not reference standards
59
02/08/2023CN-058CN - ChinaClaims and financial product standardsInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordChina Green Bond Principles (GBP)Defines the rules for the issuance of green bonds, which include support for decarbonization projectsChina Green Bond Principles (GBP) were defined by the China Green Bond Standards Committee and aim to standardize the Green Bond Market by setting basic requirements for issuers (China Green Bond Principles (GBP), pages 8 and 14). China's Central Bank (People's Bank of China), the market regulator (China Securities Regulatory Commission), the National Association of Financial Market Institutional Investors and private sector institutions are members of the Committee (ICMA, 2022, page 2). The Principles have been accepted and taken forward by various financial regulators, including the Committee's members, the Shanghai Stock Exchange and the Shenzhen Stock Exchange (ICMA, 2022, pages 1-2). In practice, then, the instrument is mandatory, and we classify it as such.
The Principles define green bonds as those that support green activities, according to the prescribed conditions (China Green Bond Principles (GBP), page 9). The instrument is, therefore, a rules-based solution that defines what green activities are. The prescribed conditions for green bonds are (i) that 100% of the use of green bonds proceeds should be used for green activities, as defined in China's Green Bond Endorsed Project Catalogue (see entry in the tracker), (ii) disclosure of information about project evaluation and selection, (iii) tracking and other specifications around the use of proceeds, and (iv) disclosure of information about the use of proceeds (China Green Bond Principles (GBP), pages 9-13).
Green activities that can be supported by green bonds are those that support green and low-carbon development, improvements to the environment or pre-defined environmental benefits (China Green Bond Principles (GBP), page 9). They are divided into four types - 1. Standard Green Use of Proceeds Bond, 2. Carbon Yield Green Bond, 3. Green Project Revenue Bond, and 4. Green Asset-Backed Securities (China Green Bond Principles (GBP), pages 15-17). The pursuit of carbon neutrality is explicitly stated as part of type 1 ("contributing to reaching the goal of carbon neutrality"), whose proceeds "are specifically used for green projects with carbon emissions reduction impact" (China Green Bond Principles (GBP), page 16). The Principles are thus classified as carbon-specific.		China Green Bond Principles (GBP): https://www.nafmii.org.cn/ggtz/gg/202207/P020220801631427094313.pdf

ICMA, 2022:
https://www.icmagroup.org/assets/Analysis-of-Chinas-Green-Bond-Principles.pdf		Issuers of green bondsFinancial regulatory authorityChina's Green Bond Standard Committee under the People's Bank of ChinaFramework20222022Is aligned with standardsICMA Green Bond Principles (GBP)
60
15/05/2023CN-059CN - ChinaClaims and financial product standardsInstrument identifiedPreparatory phaseUnknownUnknown21Record not regulated14th Five-Year Plan for the Development of Financial StandardisationAnnounces rhe goal of developing a standard for green financeIn February 2022, the People's Bank of China, the State Administration for Market Regulation (SAMR), the China Banking and Insurance Regulatory Commission (CBIRC) and the China Securities Regulatory Commission (CSRC) jointly issued the "Development Plan for Financial Standardization During the 14th Five-Year Plan Period", which focuses on the need to improve the green financial standard system. It was formulated under the Outline of the 14th Five-Year Plan (2021-2025) for National Economic and Social Development and the Long-Range Objectives Through the Year 2035 and the National Standardization Development Outline.

The Plan clarified the guidelines, basic principles, main objectives, key tasks and supporting measures for advancing standardization of the financial sector. The Plan outlined seven key tasks. Within the third one, supporting innovation in financial products and services with standardization, the improvement of the green finance standard system was considered. This plan can set the foundations for future regulation of green finance claims.		Development Plan for Financial Standardization law (subscription needed)
http://lawinfochina.com/display.aspx?id=37685&lib=law Development Plan for Financial Standardization news
http://www.pbc.gov.cn/en/3688110/3688172/4437084/4469588/index.html 14th Five-Year Plan (2021-2025)
http://www.xinhuanet.com/fortune/2021-03/13/c_1127205564_7.htm		Financial institutionsFinancial regulatory authorityPeople's Bank of China, the State Administration for Market Regulation (SAMR), the China Banking and Insurance Regulatory Commission (CBIRC) and the China Securities Regulatory Commission (CSRC)Plan2022Not applicableDoes not reference standards
61
15/05/2023CN-060CN - ChinaClaims and financial product standardsInstrument identifiedDraft phaseBroad-basedMandates action20Record not regulatedUnknownDrafts a regulation for green fundsChina’s funds regulator, Asset Management Association of China (AMAC), has drafted regulations for green funds that will mandate mutual funds or exchange-traded funds to include as much as 60% of their assets under specific green investments group for making them suitable for sale as green products. China Securities Regulatory Commission (CSRC) will have to approve the AMAC rules. AMAC's draft rules borrow from the 2021 version of China's green bond catalogue, a classification scheme, to define green assets. The catalogue is currently only applied to debt financing. The new rules, which could be in place in the first half of 2023. Net zero or carbon neutrality specifications were not found.https://www.reuters.com/business/sustainable-business/china-unveil-new-rules-rein-fund-greenwashing-sources-2022-12-21/Green FundsUnknownUnknownUnknown2022Not applicableDoes not reference standards
62
15/05/2023CN-061CN - ChinaClaims and financial product standardsInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedAdvertising lawRegulates misleading advertisementsThere is room for expanding the current regulatory understanding by including net-zero claims as a part of a specific category (e.g. greenwashing), which requires special monitoring. In particular the Advertising law is a space that could account for such a regulation. Currently, greenwashing can be regulated through the Advertising law but there is no specific category for it. The law mentions that an advertisement shall not contain any false information, and shall not cheat or mislead consumers (Article 4). Where, in violation of the provisions of this Law, shall also be imposed thereupon a fine of not less than the amount of the advertising charges and not more than five times that amount (Article 37).http://www.npc.gov.cn/zgrdw/englishnpc/Law/2007-12/12/content_1383782.htmAdvertisers, advertising agents and advertisement publishers engaged in advertising activitiesLegislativePeople's CongressLaw19941994Does not reference standards
63
15/05/2023CN-062CN - ChinaClaims and financial product standardsInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedLaw on the Protection of Consumer Rights and InterestsRegulates misleading advertisementsThere is room for expanding the current regulatory understanding by including net-zero claims as a part of a specific category (e.g. greenwashing), which requires special monitoring. In particular, the Law on the Protection of Consumer Rights and Interests is a space that could account for such regulation. Currently, greenwashing can be regulated through the Consumer Rights and Interests law but there is no specific category for it. It states that business operators shall provide consumers with authentic information concerning their commodities or services, and may not make any false and misleading propaganda (Article 19). Furthermore, consumers whose legitimate rights and interests are infringed upon on account of commodities or services supplied by business operators by means of false advertisement may demand compensation from the business operators (Article 39).http://www.npc.gov.cn/zgrdw/englishnpc/Law/2007-12/12/content_1383812.htm#:~:text=Consumers%20shall%2C%20in%20their%20purchasing%20commodities%20or%20receiving%20services%2C%20have,compulsory%20transaction%20of%20business%20operators.Business operatorsLegislativePeople's CongressLaw19931993Does not reference standards
64
15/05/2023CN-063CN - ChinaClaims and financial product standardsInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedAnti-Unfair Competition LawRegulates misleading advertisementsThere is room for expanding the current regulatory understanding by including net-zero claims as a part of a specific category (e.g. greenwashing), which requires special monitoring. In particular, the Anti-Unfair Competition Law is a space that could account for such a regulation. Currently, greenwashing can be regulated through the Anti-Unfair Competition law but there is no specific category for it. It stipulates that a business operator may not, by advertisement or any other means, make false or misleading publicity of their commodities as to their quality, ingredients, functions, usage, producers, duration of validity or origin (Article 9 A). The supervision and inspection department may impose a fine of not less than 10,000 yuan but not more than 200,000 yuan in light of the circumstances (Article 24).http://www.npc.gov.cn/zgrdw/englishnpc/Law/2007-12/12/content_1383803.htmBusiness operatorsLegislativePeople's CongressLaw19931993Does not reference standards
65
02/08/2023CN-064CN - ChinaClaims and financial product standardsInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedChina's Green Bond Endorsed Project CatalogueEstablishes China's Taxonomy of green bonds, mandatory from 2021People’s Bank of China issued its green taxonomy in 2015, in the form of the Green Bond Endorsed Project Catalogue aiming to ensure the robustness of the green bond market (page 2).
The catalogue was revised in 2021 (page 2). It was jointly announced by the People's Bank of China (PBOC) (Central Bank), the National Development and Reform Commission (NDRC) and the China Securities Regulatory Commission (CSRC) (page 2). It states that "all regions, departments and relevant institutions should act based on the Green Bond Catalogue (2021) with the combination of their own green development goals and tasks" (page 1). As to the bonds that have not been approved or have not completed the registration process prior to release, they should apply the Green Bond Catalogue (2021) (page 2). Therefore, the instrument is classified as mandatory, though the details of how the Catalogue is used are described only in a supporting instrument (see "China Green Bond Principles (GBP)").
The Catalogue is divided into six industrial categories - 1. Energy-saving and Environmental Protection Industry, 2. Cleaner Production Industry, 3. Clean Energy Industry, 4. Ecology and environment Industry, 5. Green Upgrade of Infrastructure, 6. Green Services - and, below them, several programs. Although some of the listed programs can contribute to a net-zero goal (e.g.: 3.2.3.6. CCS projects, 4.2.2.3. Forest carbon sequestration), decarbonization is not stated as a goal of the Catalogue, neither is a category of green bonds. Therefore, we classify the instrument as broad-based.		https://www.climatebonds.net/files/files/the-Green-Bond-Endorsed-Project-Catalogue-2021-Edition-110521.pdfAll regions, departments and relevant institutions that issue green bonds (green financial bonds, green corporate bonds, green enterprise bonds, green debt financing tools and green asset-backed securities)Financial regulatory authorityPeople's Bank of ChinaNotice20212021Is aligned with standardsICMA Green Bond Principles (GBP)
66
30/06/2023CN-065CN - ChinaDisclosureInstrument identifiedPreparatory phaseCarbon-specificUnknown21Record not regulatedUnknownAnnounces ESG-related disclosuresChina is considering mandatory environmental, social, and governance (ESG) disclosures for domestic public firms (February 2023). The proposed regulations would require companies to include ESG information in their annual reports, including data on their carbon footprint, waste management, labor practices, and board diversity. Companies would also be required to report on their progress toward meeting sustainability goals, such as reducing greenhouse gas emissions. The regulations are still under review by the Chinese government and have not yet been finalized.https://www.bloomberg.com/news/articles/2023-02-22/china-mulls-mandatory-esg-disclosures-for-domestic-public-firms#xj4y7vzkgUnknownUnknownUnknownLawNot applicableNot applicableDoes not reference standards
67
15/05/2023CN-066CN - ChinaDisclosureInstrument identifiedPreparatory phaseCarbon-specificUnknown21Record not regulatedGuiding Opinions on Promoting Investment and Financing to Address Climate ChangeAnnounces the goal of establishing a disclosure systemOne of the potential routes for the development of such regulations is leveraging the Guiding Opinions on Promoting Investment and Financing to Address Climate Change released in October 2020. As part of its objectives, improving climate information disclosure standards was included. However, it does not enforce climate-related disclosure. It was issued by the Ministry of Ecology and Environment, the National Development and Reform Commission, the People's Bank of China, the China Banking and Insurance Regulatory Commission and the China Securities Regulatory Commission.
Its main objectives are by 2022, to have a policy environment conducive to the development of climate investment and financing, the promotion for the establishment of relevant standards for climate investment and financing.
By 2025, it aims to promote coordinated and efficient promotion of climate change policies and policies in various fields and gradually improve climate investment and financing policies, and, standard systems.
As part of its objectives, improving climate information disclosure standards was included. It seeks to accelerate the formulation of information disclosure standards for climate investment and financing projects, entities, and funds, and promote the establishment of a climate information disclosure system that makes corporate public commitments, information is disclosed in accordance with the law and is widely supervised by the society.		https://www.mee.gov.cn/xxgk2018/xxgk/xxgk03/202010/t20201026_804792.htmlGovernmentExecutiveMinistry of Ecology and Environment, National Development and Reform Commission, People's Bank of China, China Banking and Insurance Regulatory Commission, China Securities Regulatory CommissionStatement2020Not applicableDoes not reference standards
68
15/05/2023CN-067CN - ChinaDisclosureInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedGuidance for enterprise ESG disclosureGuidance for ESG disclosureThe China Enterprise Reform and Development Society (CERDS) a think-tank overseen by the state-owned Assets Supervision & Administration Commission, developed a Guidance for enterprise ESG disclosure. It was led by the China ESG Research Institute of Beijing Economic and Trade Co., Ltd in collaboration with other organizations and companies and it was implemented in June 2022. The ESG indicator system, standardizing disclosure requirements and applications can guide enterprises in ESG governance practices and information disclosure, and can also be used as a reference for enterprise self-evaluation and third-party evaluation.
The Environmental section of the indicators, among other components, includes climate change (GHG emissions, and emissions management). Under governance, climate risk identification and prevention indicators are considered.
The corporate ESG disclosure indicator system includes 3 first-level indicators, 10 second-level indicators, 35 third-level indicators, and 118 fourth-level indicators. It is based on ESG-related theories, relevant laws, regulations and standards.		Guidance (Chinese)
https://www.3060edu.com/static/upload/file/20220420/1650418903815960.pdf Press release
https://www.cueb.edu.cn/pub/xww2013/xydt/yx/144483.htm		Companies in ChinaExecutiveChina Enterprise Reform and Development SocietyGuideline20222022Is aligned with standardsISO 14090
ISO 37301
69
15/05/2023CN-068CN - ChinaDisclosureInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedGuidelines on Environmental Information Disclosure for Financial InstitutionsGuidance for environmental disclosurePeople's Bank of China (PBOC) issued Guidelines on Environmental Information Disclosure for Financial Institutions on 22 July 2021. It provides the principles, forms, elements and requirements that financial institutions are encouraged to follow for environmental information disclosure. It includes environmental risks as part of the disclosure contents.
It includes as disclosure contents: 1. Information about analysis and judgment of environment-related risks and opportunities (Section 6.2), Environmental risk management process of the financial institution (Section 6.5)
2. Environmental risks and opportunities of the financial institution (Section 6.6.1)
3. Quantitative analysis of environmental risks of the financial institution (Section 6.6.2)
4. Environmental impacts of underwriting activities of insurance companies include but are not limited to: Integrate environmental factors into risk management and continue to study and monitor climate change and other related risks (Section 6.7.4.)
5. Calculation and expression of impacts of environmental risks on investment and financing of the financial institution (Section 6.7.5.).
Financial institutions are encouraged to disclose their environmental information at least once a year. The disclosure contents are encouraged. Therefore, future efforts can leverage this guidelines to make mandatory for Financial Institutions to disclose environmental information including risks.		https://www.chinadevelopmentbrief.org/wp-content/uploads/2021/08/Guidelines-for-financial-institutions-environmental-information-disclosure.pdfBanking, asset management, insurance, trust, futures, securities and other
financial institutions		Financial regulatory authorityPeople's Bank of ChinaGuideline20212021Does not reference standards
70
22/05/2023CN-069CN - ChinaDisclosureInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedGreen Finance Guidelines for the Banking and Insurance IndustryThe Green Finance Guidelines for the Banking and Insurance Industry requires Banking and insurance institutions to identify, monitor, and prevent and control environmental, social, and governance risks in business activitiesRequirements for environmental risks disclosure were considered under the Green Finance Guidelines for the Banking and Insurance Industry. On June, 2022, the China Banking and Insurance Regulatory Commission (CBIRC) has introduced a set of new guidelines called Green Finance Guidelines for the Banking and Insurance Industry. It requires banking and insurance entities to promote carbon peaking and carbon neutrality. In Article 3 it is mentioned that Banking and insurance institutions shall fully promote green finance from a strategic perspective, increase support for green, low-carbon and circular economy, prevent environmental, social and governance risks, and improve their own environmental, social and governance risks.
As part of Article 4, Banking and insurance institutions shall effectively identify, monitor, and prevent and control environmental, social, and governance risks in business activities. Environmental, social, and governance requirements may be included in the management process and comprehensive risk management system, and information disclosure.
Banking and insurance institutions shall establish and continuously improve policies, systems and procedures for environmental, social and governance risk management in accordance with national green and low-carbon development goals and plans (Article 11).
Finally, it states that Banking and insurance institutions shall formulate environmental, social and governance risk assessment standards for customers, and conduct classified management and dynamic assessment of customer risks (Article 14).
Although there is no direct legal enforcement, the guidelines are regarded as binding (Refer to PRI Article). It mentions that the Guidelines shall come into force on the date of promulgation and that the Banking and insurance institutions shall establish and improve relevant internal management systems and procedures within one year from the date of implementation of these Guidelines to ensure that the management of green finance complies with regulatory requirements (Article 35). According to the Q&A document on the notice, the Guidelines require banking and insurance institutions to thoroughly implement new development concepts, promote green finance from a strategic perspective, increase support for green, low-carbon, and circular economies, prevent environmental, social, and governance risks, and improve their own environmental, social, and governance performance (...).
While the definitions of environmental risks may encompass climate risks as they are set in the context of carbon peaking and neutrality, they are not specifically defined or required. To sum up, the Guidelines are currently not aligned with climate disclosure but could be improved in the future to mandate the report of climate risks in a regulated and routine fashion.		Press release:
https://www.cbirc.gov.cn/en/view/pages/ItemDetail.html?docId=1055048&itemId=981
Notice on issuing the Green Finance Guidelines
http://www.cbirc.gov.cn/cn/view/pages/ItemDetail.html?docId=1054663&itemId=928
Q&A on the notice on issuing the Green Finance Guidelines
http://www.cbirc.gov.cn/cn/view/pages/ItemDetail.html?docId=1054659&itemId=915&generaltype=0 PRI Article
https://www.unpri.org/pri-blog/china-raises-the-bar-on-investor-regulations-to-promote-green-finance/10659.article#fn_1		Banking and insurance institutionsExecutiveChina Banking and Insurance Regulatory CommissionGuideline20222022Does not reference standards
71
15/05/2023CN-070CN - ChinaDisclosureInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedRules for the Disclosure of Enterprise Environmental Information for domestic entitiesMandates the disclosure of environmental information by companiesIn order to implement the “Plan for the Reform of the Legal Disclosure System of Environmental Information” issued by China’s Ministry of Ecology and Environment (MEE) in May 2021, the MEE has issued new rules for the Disclosure of Enterprise Environmental Information in December 2021 that requires domestic entities to disclose a range of environmental information on an annual basis, effective 8 February 2022. It aims to In order to standardize the legal disclosure of corporate environmental information.
Covered entities must disclose information on environmental topics including among others (Article 12):
1. Environmental management
2. Pollutant management
3. Carbon emissions
4. Ecological and environmental emergency information including information on environmental emergency plans, emergency response to heavily polluted weather, etc.
The rules are an update to regulations put in place in 2015, and implement proposals for reforms to the disclosure system published in May 2021. Carbon emissions data is a new addition, demonstrating a trend towards disclosing climate information.
Listed companies and bond-issuing enterprises shall, in addition to disclosing the environmental information specified in Article 12, disclose related information on climate change response, ecological environment protection, etc. of the projects invested by financing (Article 15).
The Plan for the Reform of the Legal Disclosure System of Environmental Information aims by 2025 to have a mandatory disclosure system where environmental information will be basically formed.		Plan for the Reform of the Legal Disclosure System of Environmental Information
https://www.mee.gov.cn/xxgk2018/xxgk/xxgk03/202105/t20210525_834444.html Environmental information disclosure rules
https://www.mee.gov.cn/xxgk2018/xxgk/xxgk02/202112/t20211221_964837.html		Listed companies and bond issuers that were subject to certain environmental penalties over the previous year and other entities identified by the MEE, including those that discharge high levels of pollutants, enterprises that implement mandatory cleaner production auditsExecutiveMinistry of Ecology and EnvironmentResolution20212022Does not reference standards
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15/05/2023CN-071CN - ChinaDisclosureInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedStandards for the Contents and Formats of Information Disclosure by Companies Offering Securities to the Public No. 2Mandates the disclosure information by companiesIn June 2021, the China Securities Regulatory Commission (CSRC) published revised versions of the information disclosure rules relating to annual reports and to half-year reports for listed companies, which were updated from their 2017 versions (Standards for the Contents and Formats of Information Disclosure by Companies Offering Securities to the Public No. 2—Contents and Formats of Annual Reports). It has a newly added section 15: Environmental and Social Responsibility to regulate ESG disclosure of listed companies (Articles 41 to 43).
Mandatory disclosure is included for companies or their major subsidiaries that are key pollutants regarding (Article 41):
1. Pollutant discharge information,
2. The construction and operation of pollution prevention and control facilities;
3. Environmental impact assessment of the projects and other environmental protection administrative permits
4. Contingency plans for environmental emergencies.
5. Environmental self-monitoring plan;
6. Administrative penalties due to environmental issues during the reporting period
7. Other environmental information.
The 2021 rules contain a number of items whose disclosure is encouraged but not mandated, including: 1. Information relating to the promotion of environmental protection, prevention and control of pollution, and any actions to perform environmental responsibilities;
2. Information on the measures taken to reduce carbon emissions during the reporting period and the effects of these measures		http://www.csrc.gov.cn/csrc/c101864/c6df1268b5b294448bdec7e010d880a01/content.shtmlCompanies that are key pollutantsFinancial regulatory authorityChina Securities Regulatory Commission (CSRC)Standard20212021Does not reference standards
73
22/05/2023CN-072CN - ChinaProcurementInstrument identifiedPreparatory phaseUnknownUnknown21Record not regulatedImplementation Plan for Promoting Green ConsumptionAnnounces new instruments for green procurementThe Implementation Plan for Promoting Green Consumption, released in January 2022 focuses on boosting the green transformation of consumption in key areas. This plan is formulated in accordance with the relevant requirements of the Action Plan for Carbon Peaking Before 2030. It was released by the National Development and Reform Commission (NDRC) and six other government organs. It states that green consumption modes will prevail by 2025 calling for efforts to arouse people's awareness of green consumption and waste and enhance the market share of green and low-carbon products. As main objectives, by 2030, it aims for green consumption to become the conscious choice of the public and for green and low-carbon products to become the mainstream of the markets.
Section 17 includes Promoting the revision of the "Recruitment Bidding Law and Government Procurement Law to improve green procurement policies. Section 21 aims to improve government green procurement standards and improve the proportion of low-carbon products in government procurement. Considering these sections, we understand that new green procurement instruments should be published soon. This is backed up by the goal, established in section 11, to vigorously promote the green transformation of consumption in public institutions.
The text also mentions green and low-carbon procurement. Net zero is particularly stated in section 12: Promote the application of advanced green and low-carbon technologies for strengthening low-carbon, zero-carbon and negative-carbon technology.		Implementation Plan for Promoting Green Consumption: https://www.ndrc.gov.cn/xxgk/zcfb/tz/202201/t20220121_1312524.html?code=&state=123 Article: http://english.www.gov.cn/statecouncil/ministries/202201/21/content_WS61ea55d7c6d09c94e48a40e8.htmlConsumers in the whole process of consumption activitiesExecutiveNational Development and Reform CommissionPlan2022Not applicableDoes not reference standards
74
18/08/2023CN-073CN - ChinaProcurementInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedLaw of the People's Republic of China on Energy ConservationMandates governmental bodies to give preference to energy-saving productsThe Law of the People's Republic of China on Energy Conservation aims to promote energy conservation (Article 1), including by public institutions (Articles 5 - 7). It states that when purchasing energy-using products and equipment, public institutions shall give first priority to the products and equipment listed in the catalogue of energy-saving products (Article 51). This list is discussed in a separate entry in the tracker (see Governmental Green Procurement (GPP)).
While reducing energy usage has effects on carbon emissions, this is not the goal of the instrument. The entry is therefore classified as mandatory and broad-based.		Law of the People's Republic of China on Energy Conservation: http://www.npc.gov.cn/zgrdw/englishnpc/Law/2009-02/20/content_1471608.htmAll levels of government in ChinaExecutivePresidencyLaw20072008Does not reference standards
75
18/08/2023CN-074CN - ChinaProcurementInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedGovernmental Green Procurement (GPP)Lists and gives preference to environmentally-friendly productsIn 2006, China launched its Governmental Green Procurement (GPP) program, which consists of a labelling scheme and the purchase of these certified products (IISD, 2015, page 15).
There are two lists of certified products - Energy Conservation Products (ECPs) and Environment Labeling Products (ELPs) (IISD, 2015, page 15). GPP requires the government to give priority to certified products over non-certified ones, but buying from the ECP list is mandatory while from ELP is not (IISD, 2015, page 15).
Both ECP and ELP are broad-based environmental instruments - though ELP also includes the certification of at least one low-carbon product, a tea manufacturer that reduced GHG emissions from its production (CEC, 2018).
We classify GPP as generally mandatory (though exceptions apply, such as for purchasing from the ELP list) but broad-based.		IISD, 2015: https://www.iisd.org/system/files/publications/green-public-procurement-china-quantifying-benefits-en.pdf

CEC, 2018: http://en.meecec.com/lowcarbonclimatechange/certification/certification-for-low-carbon-products/2021/6995.shtml		Governmental bodiesExecutiveMinistry of Finance, National Development and Reform Commission, and Ministry of Environmental ProtectionFramework20062006Does not reference standards
76
18/08/2023CN-075CN - ChinaProcurementInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedGovernment Procurement Law of the People's Republic of ChinaRegulates procurement in all levels of governmentThe Government Procurement Law of the People's Republic of China regulates procurement at all governmental levels (Articles 1 and 2).
Procurement is understood as a way to achieve the State's goals, including environmental protection (Article 9). However, the legislation does not mention net zero goals and/or how procurement shall be conducted to facilitate environmental protection.
The entry is therefore classified as mandatory and broad-based.		Government Procurement Law: http://www.npc.gov.cn/zgrdw/englishnpc/Law/2007-12/06/content_1382108.htmAll levels of government in ChinaLegislativePeople's CongressLaw20022002Does not reference standards
77
18/08/2023CN-076CN - ChinaProcurementInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedLaw of the People's Republic of China on Promotion of Cleaner ProductionMandates governmental bodies to give preference to water and energy-saving products, as well as recycled materialsThe Law of the People's Republic of China on Promotion of Cleaner Production requires governments at various levels to give preference to energy- and water-conservation products and products made out of recycled waste (Article 16). Carbon emission considerations are not present in the law. The entry is therefore classified as mandatory and broad-based.Law of the People's Republic of China on Promotion of Cleaner Production: http://www.npc.gov.cn/zgrdw/englishnpc/Law/2007-12/06/content_1382101.htmAll levels of government in ChinaLegislativePeople's CongressLaw20022002Does not reference standards
78
18/08/2023CN-077CN - ChinaProcurementInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedCircular Economy Promotion Law of the People's Republic of ChinaMandates governmental bodies to give preference to energy-saving, water-saving, material-saving, environment-friendly, and recycled productsThe Circular Economy Promotion Law of the People's Republic of China aims to promote the development of a circular economy in China (Article 1), including through actions by public institutions (Articles 3 and 6), including through procurement (Article 8). It requires governments at various levels to give preference to energy-saving, water-saving, material-saving, environment-friendly, and recycled products (Article 47). While these activities can reduce carbon emissions, this is not the goal of the instrument. The entry is therefore classified as mandatory and broad-based.Circular Economy Promotion Law https://www.lawinfochina.com/display.aspx?id=7025&lib=lawAll levels of government in ChinaExecutivePresidencyLaw20082009Does not reference standards
79
22/05/2023CN-078CN - ChinaTransition plansInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedWorking Guidance for Carbon Dioxide Peaking and Carbon Neutrality in Full and Faithful Implementation of the New Development PhilosophySets a carbon peaking goal by 2030 and net zero by 2060China had established a “1+N” policy framework for carbon dioxide peaking and carbon neutrality. The “1” means the guidance and the top-level design for carbon dioxide peaking and carbon neutrality. The “N” ” is the implementation schemes in key areas and sectors. The 1+N will form a full-fledged policy system for carbon dioxide peaking and carbon neutrality with objectives, division of functions, measures and collaboration. It consists of the two documents issued in 2021: Working Guidance for Carbon Dioxide Peaking and Carbon Neutrality in Full and Faithful Implementation of the New Development Philosophy and The Action Plan for Carbon Dioxide Peaking by 2030.
In October 2021, the CPC Central Committee and the State Council issued the “Working Guidance for Carbon Dioxide Peaking and Carbon Neutrality in Full and Faithful Implementation of the New Development Philosophy” (the Guidance), which is the guiding principle (the “1”). The Guidance aims to align the set 2030 carbon peaking and 2060 carbon neutrality targets and implementation with the overall social and economic development. Strengthening guidance in the planning of green and low-carbon development is part of its main objectives. However, no specific mention to require firms to outline their pathways to net zero was included.		1+N Policy system in NDCs
https://unfccc.int/sites/default/files/NDC/2022-11/Progress%20of%20China%20NDC%202022.pdf Working Guidance for Carbon Dioxide Peaking
https://en.ndrc.gov.cn/policies/202110/t20211024_1300725.html		Nationwide planningExecutiveDepartment of Resource Conservation and Environmental ProtectionGuideline20212021Does not reference standards
80
11/08/2023CN-079CN - ChinaTransition plansInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedAction Plan for Carbon Dioxide Peaking Before 2030Defines the national action plan for carbon peaking by 2030China had established a “1+N” policy framework for carbon dioxide peaking and carbon neutrality. The “1” means the guidance and the top-level design for carbon dioxide peaking and carbon neutrality. The “N” ” is the implementation schemes in key areas and sectors. The 1+N will form a full-fledged policy system for carbon dioxide peaking and carbon neutrality with objectives, division of functions, measures and collaboration. It consists of the two documents issued in 2021: Working Guidance for Carbon Dioxide Peaking and Carbon Neutrality in Full and Faithful Implementation of the New Development Philosophy and The Action Plan for Carbon Dioxide Peaking by 2030.
China’s first "N", - the "Action Plan for Carbon Dioxide Peaking Before 2030" was published in 2021. The Action Plan focuses on the roadmap of concrete measures for CO2 emission peaking before 2030, which covers the 14th and 15th Five-Year Plan period. One of the key tasks is to encourage enterprises to fulfil their social responsibilities. Under this task, state-owned enterprises in key areas, especially those managed by the central government, and major energy consumers should also draw up plans for emission peak and reduction. However, the plan itself does not mandate these actions to be carried out, which is why it is classified as "non-mandatory".		1+N Policy system in NDCs
https://unfccc.int/sites/default/files/NDC/2022-11/Progress%20of%20China%20NDC%202022.pdf Action Plan N
https://en.ndrc.gov.cn/policies/202110/t20211027_1301020.html		Nationwide planningExecutiveDepartment of Resource Conservation and Environmental ProtectionPlan20212021Does not reference standards
81
16/08/2023DE-080DE - GermanyClaims and financial product standardsInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordRegulation (EU) 2016/1011Defines rules for benchmarks marketed as "low-carbon"EU Regulations are automatically binding to EU members (EU, 2022). Therefore, this entry automatically applies in Germany.
Regulation (EU) 2016/1011 establishes the rules for "benchmarks" (Regulation (EU) 2016/1011, Article 1) - indices used to calculate the value or performance of investment funds (Regulation (EU) 2016/1011, Article 3.1). As the number of investors that make use of low-carbon considerations to select and evaluate the funds they invest in grows (Regulation (EU) 2019/2089, Recital, item 9), so does the number of benchmarks marketed as "low-carbon" (Regulation (EU) 2019/2089, Recital, item 11). In 2019, the Regulation was amended to create two mitigation-specific benchmarks and, thus, prevent greenwashing in the claims made by funds (Regulation (EU) 2019/2089, Recital, item 9).
The first benchmark is the "EU Climate Transition Benchmark" and is directed to portfolios that are on a decarbonisation trajectory (Regulation (EU) 2016/1011, Article 3.23b). Decarbonisation must be measurable, science-based, and time-bound and reduce scopes 1, 2 and 3 emissions (Regulation (EU) 2016/1011, Article 3.23c). The second benchmark is called the "EU Paris-aligned Benchmark". Its portfolio's carbon emissions must be aligned with the goals of the Paris Agreement (net zero) and not cause other significant harm to ESG objectives (Regulation (EU) 2016/1011, Article 3.23b). Both Benchmarks must follow the Regulation's requirements, which include disclosing information about how the benchmark is calculated, its emissions and targets (Regulation (EU) 2016/1011, Articles 19a, 19b, and Annex III).
The regulation is applicable to all EU member states (Regulation (EU) 2016/1011, Article 59).		Regulation (EU) 2016/1011: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02016R1011-20220101

Regulation (EU) 2019/2089: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32019R2089		BenchmarksLegislativeEuropean Parliament and the Council of the European UnionRegulation20192019Does not reference standards
82
02/08/2023DE-081DE - GermanyClaims and financial product standardsInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordCommission Delegated Regulation (EU) 2021/2139Supplements the EU Taxonomy by defining the conditions for determining no harm and significant contribution to climate change mitigation and adaptationEU Regulations are automatically binding to EU members (EU, 2022). Because the EU Taxonomy is a regulation, it automatically applies in Germany.
The Commission Delegated Regulation (EU) 2021/2139 supplements the EU Taxonomy by defining the criteria for determining whether an economic activity contributes to climate change mitigation or adaptation (Article 1 and Annex 1) and causes no harm (Article 2 and Annex 2). The Regulation is binding in its entirety and directly applicable in EU Member States (Article 3).		Commission Delegated Regulation (EU) 2021/2139: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R2139

EU, 2022: https://commission.europa.eu/law/application-eu-law/implementing-eu-law_en

Regulation (EU) 2020/852: https:
//eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX: 32020R0852		Financial market participantsExecutiveEuropean CommissionRegulation20212022Requires actors to follow the standardsISO 14067
ISO 14064-1
Commission Recommendation 2013/179/EU
ETSI ES 203 99
ISO 27914
ISO 20887
ISO 16000
ISO 18400
EU Regulation (EC) No 1907/2006
CEN/EN 16516
83
12/05/2023DE-082DE - GermanyClaims and financial product standardsInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordEU TaxonomyDefines financial products (including net zero related) that can be labelled as "sustainable" through EU regulationAs an EU regulation, the EU Taxonomy became automatically binding in Germany on its date of application, without the need for separate incorporation.
The EU Taxonomy, established by the Regulation (EU) 2020/852, is a rules-based regulation that defines which economic activities can be considered "green" or "sustainable" (item 5). By using a common concept of sustainability, financial products can only be labelled as sustainable if they follow the Taxonomy (item 14). This way, the Taxonomy regulates claims of sustainability performance according to a pre-defined standard.
Out of the six environmental objectives that can determine "sustainability" in the Taxonomy, one is directly related to net zero - climate change mitigation (item 23). The evaluation of an economic activity that pursues climate change mitigation takes into account whether it (i) substantially contributes to the stabilisation of greenhouse gas concentrations in the atmosphere, and (ii) is consistent with the long-term temperature goal of the Paris Agreement (Art. 10, 1).
The EU Taxonomy also incorporates new requirements for undertakings that are obliged to disclose non-financial information under Directive 2013/34/EU (Article 8).		Regulation (EU) 2020/852: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0852Financial market participants and undertakings that are obliged to disclose non-financial statements according to Directive 2013/34/EULegislativeEuropean ParliamentRegulation20202020Does not reference standards
84
16/08/2023DE-083DE - GermanyClaims and financial product standardsInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedESMA34-45-1427Guidance for the supervision of disclosure obligations in the EU, applicable to GermanyThe European Securities and Markets Authority (ESMA) is the EU's financial markets regulator and supervisor, aiming at bringing supervisory convergence to EU member states' authorities across banking, insurance and pensions (About ESMA, 2023).
The ESMA34-45-1427 supervisory briefing provides guidance for the supervision of sustainability-related disclosures and integration of sustainability risks (ESMA34-45-1427, page 4), which includes the EU Taxonomy and the Sustainable Finance Disclosure Regulation (SFDR) (ESMA34-45-1427, page 5), with the goal of avoiding greenwashing (ESMA34-45-1427, page 6). A range of sustainability terms is described in the guidance, including climate-specific (ESMA34-45-1427, page 11).
Although this is not a binding instrument, it brings clarity to how regulations are to be interpreted and supervised by EU member's National Competent Authorities (ESMA34-45-1427, page 4), which is why this instrument is applicable to Germany.		About ESMA: https://www.esma.europa.eu/about-esma

ESMA34-45-1427: https://www.esma.europa.eu/sites/default/files/library/esma34-45-1427_supervisory_briefing_on_sustainability_risks_and_disclosures.pdf		National Competent AuthoritiesFinancial regulatory authorityEuropean Securities and Markets Authority (ESMA)Briefing20222022Does not reference standards
85
13/06/2023DE-084DE - GermanyClaims and financial product standardsInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedGreen Bond FrameworkGreen Bond Framework aims to provide direction in the application of proceeds from German Federal Securities which can qualify as greenThe Green Bond Framework, issued in 2020, aims to provide direction in the application of proceeds from German Federal Securities which can qualify as green. Eligible Green Expenditures will fall within these green sectors: Transport, International cooperation, Research, innovation and awareness raising, Energy and industry, Agriculture, forestry, natural landscapes and biodiversity. For each Eligible Green Expenditure, the Core Green Bond Team (CGBT) with the relevant ministry have assessed the eligibility of the selected expenditures in light of International Capital Market Association (ICMA)'s Green Bond Principles (GBP) (GBP), the existing public taxonomies, and based on Federal expenditures. Moreover, they are designed to be in compliance with important elements of the draft EU Green Bond Standard and the categories are mapped with the six environmental objectives of the EU Sustainable Finance Taxonomy.

An Inter-Ministerial Working Group (“IMWG”) has been established to oversee and validate key decisions about the Green German Federal securities, the selection of Eligible Green Expenditures, and consequent allocation and impact reporting established from it. The framework is only applicable for federal securities, therefore, it is considered that does not mandates action.		https://www.deutsche-finanzagentur.de/en/federal-securities/types-of-federal-securities/green-federal-securitiesGerman Federal governmentExecutiveFederal Ministry of FinanceFramework20202020Does not reference standards
86
31/05/2023DE-085DE - GermanyClaims and financial product standardsInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedAct against Unfair Competition (UWG)Regulates misleading advertisementsTaking action against environmental misleading claims currently is possible through the Act against Unfair Competition (UWG) even though the act does not contain specific references to environmental or climate-related claims.
Section 5 points out circumstances when statements or information can be regarded as misleading. Criminal liability can be incurred when misleadingly advertising using false statements (Section 16). Nevertheless, there is room for expanding the current regulatory understanding by including net-zero claims as a part of a specific category (e.g. greenwashing), which requires special monitoring.		https://www.gesetze-im-internet.de/englisch_uwg/englisch_uwg.html#:~:text=This%20Act%20serves%20the%20protection,the%20public%20in%20undistorted%20competition.Any person who supplies or demands goods or servicesExecutiveFederal Ministry of JusticeAct20102010Does not reference standards
87
16/08/2023DE-086DE - GermanyClaims and financial product standardsInstrument identifiedApprovedBroad-basedDoes not mandate action50Record not regulatedEU EcolabelCreates a voluntary sustainability label for goods and productsEU Regulations are automatically binding to EU members (EU, 2022). Because the EU Taxonomy is a regulation, it automatically applies in Germany.
The EU Ecolabel (Regulation (EC) No 66/2010) is a voluntary label scheme (Article 1) that applies to goods and products in the EU market (Article 2). The label aims to recognize goods and services that are aligned with the EU's environmental strategic goals (Article 6.1), which nominally takes into account the impacts of climate change (Article 6.3.a). Decarbonization of net zero claims is not specifically defined in the Regulation, which is why the entry is classified as "broad-based". There is an opportunity to incorporate net zero-related goals to the label or to specific products and services (available at "Product groups and criteria").
Each EU member state designates a certification body to verify and certify the goods and services that apply to the label (Articles 4 and 9). It is also directly applicable to all EU member states (Article 20).		EU, 2022: https://commission.europa.eu/law/application-eu-law/implementing-eu-law_en

Regulation (EC) No 66/2010: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02010R0066-20171114

Product groups and criteria: https://environment.ec.europa.eu/topics/circular-economy/eu-ecolabel-home/product-groups-and-criteria_en		Goods and servicesLegislativeEuropean ParliamentRegulation20092010Is aligned with standardsISO 14024
88
11/05/2023DE-087DE - GermanyDisclosureInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordRegulation (EU) 575/2013Mandates financial institutions to disclose physical and transition risks through EU regulationAs an EU regulation, the Regulation (EU) 575/2013 became automatically binding in Germany on its date of application, without the need for separate incorporation. Regulation (EU) 575/2013 sets the prudential requirements for credit institutions and investment firms in the EU. The Regulation was amended in 2019 to mandate the disclosure of environmental, social and governance risks, including physical and transition risks (Art. 449a). The information must be disclosed annually in 2022 and biannually from 2023 onwards (Art. 449a). Additionally, it mandates the European Banking Authority to develop a standard format for such disclosures (Art. 434a). It is due to this requirement that the European Banking Authority published the ITS on Pillar 3 disclosures, which is also included in this spreadsheet.Regulation (EU) 575/2013: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02013R0575-20230101Large companies that trade securities in the marketLegislativeEuropean ParliamentRegulation20192022Does not reference standards
89
11/05/2023DE-088DE - GermanyDisclosureInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordImplementing Technical Standards (ITS) on Pillar 3 disclosuresRegulates how financial institutions must disclose physical and transition risks, mitigation actions and management of ESG risks through EU regulationAs an EU regulation, the Regulation (EU) 575/2013 became automatically binding in Germany on its date of application, without the need for separate incorporation. Regulation (EU) 575/2013 "establishes a single set of harmonised prudential rules, which banks throughout the EU must respect (...) to ensure the uniform application of global standards (Basel III) in all of the EU Member States" (Summary of Regulation (EU) No 575/2013, European Union, 2022). Article 449a in Regulation (EU) 575/2013 mandates the disclosure of ESG risks, including physical and transition risks (Regulation (EU) No 575/2013). Following the publication of the Article, the European Banking Authority regulated how the disclosure of information must occur via the document "Implementing Technical Standards (ITS) on Pillar 3 disclosures" (page 9). The ITS mandates and specifies the disclosure of climate change risks (page 4). The standards are in line with the TCFD recommendations and define quantitative and qualitative disclosure templates to facilitate data analysis (pages 4-5, 10). It requires the report of information in four categories - (i) climate change transition risk (item 2.3.1, (i)), (ii) climate change physical risk (item 2.3.1, (ii)), (iii) mitigation actions (item 2.3.1, (iii)), and (iv) management of environmental, social and governance (ESG) risks (item 2.3.2).Summary of Regulation (EU) No 575/2013: https://eur-lex.europa.eu/EN/legal-content/summary/prudential-requirements-for-credit-institutions-and-investment-firms.html

Regulation (EU) 575/2013: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02013R0575-20240101

ITS Pillar 3: https://www.eba.europa.eu/sites/default/documents/files/document_library/Publications/Draft%20Technical%20Standards/2022/1026171/EBA%20draft%20ITS%20on%20Pillar%203%20disclosures%20on%20ESG%20risks.pdf		Large companies that trade securities in the marketFinancial regulatory authorityEuropean Banking AuthorityStandard20222022Is aligned with standardsTCFD
90
16/08/2023DE-089DE - GermanyDisclosureInstrument identifiedDraft phaseCarbon-specificMandates action21Record not regulatedESRS E1 Climate ChangeGermany must incorporate the EU Corporate Sustainability Reporting Directive (CSRD) and its standard for the disclosure of climate information by 2024The Corporate Sustainability Reporting Directive (CSRD) demands the creation of a European sustainability reporting standard (ESRS) to specify how disclosure of the information is to be presented (Directive (EU) 2022/2464, Article 29b.1). The standards encompass ESG information, including climate change mitigation and adaptation (Directive (EU) 2022/2464, Article 29b.2), covering information on sustainability in accordance with the CSRD and also Regulations (EU) 2019/2088 and (EU) 2020/852, among others (Directive (EU) 2022/2464, Article 29b.5). ESRS should be commensurate with the Union’s objective of climate neutrality by 2050 as well as with the intermediate targets under Regulation (EU) 2021/1119 (Directive (EU) 2022/2464, Article 29a.2). The usage of the standard is mandated under CSRD (Directive (EU) 2022/2464, Article 29b.1). Based on this information, the standard to be developed is classified as carbon-specific and mandatory. Similarly to the CRSD, the standards fall into the disclosure and transition plan categories of regulation.
The ESRS is developed by the European Financial Reporting Advisory Group (EFRAG) (Directive (EU) 2022/2464, Article 29b.1). The standards are divided into 12 reporting standards, out of which ESRS E1 Climate change is specific to climate reporting (EFRAG, 2022).
The ESRS will be transmitted and put to the scrutiny of the European Parliament and the Council in August 2023 and is expected to be enacted in 2023 (Q&A adoption of European Sustainability Reporting Standards, 2023). The first reporting is due in 2025, relative to the financial year 2024 (Q&A adoption of European Sustainability Reporting Standards, 2023).
Member States, which includes France, have until 06/07/2024 to bring the CSRD into force (Article 5.1), which includes applying the ESRS standards. For this reason, we classify this instrument as in a draft phase in France as well as in the EU.		Directive (EU) 2022/2464: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022L2464

EFRAG, 2022: https://www.efrag.org/lab6?AspxAutoDetectCookieSupport=1#subtitle1

Q&A adoption of European Sustainability Reporting Standards, 2023: https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_4043		Large companies and all entities (except micro) that trade securities in the marketPrivate associationEuropean Financial Reporting Advisory Group (EFRAG)Standard2022Not applicableIs aligned with standardsISSB
91
13/06/2023DE-090DE - GermanyDisclosureInstrument identifiedDraft phaseCarbon-specificMandates action21Record not regulatedCorporate Sustainability Reporting Directive (CSRD)Germany must incorporate the EU Corporate Sustainability Reporting Directive (CSRD) into its national legislation by 2024The Corporate Sustainability Reporting Directive Implementation Act (CSR-RUG) was ratified in March 2017 and is specifically designed to implement the requirements of the European Union (EU) Non-Financial Reporting Directive (NFRD) into German law. However, from 2023, the NFRD became the Corporate Sustainability Reporting Directive (CSRD), which Germany must incorporate into national law. Member States, including Germany, shall bring into force the laws, regulations and administrative provisions necessary to comply with Articles 1 to 3 of the CSRD by 6 July 2024. They shall immediately communicate the text of those measures to the Commission.

CSRD expands the categories of companies that must disclose information (Directive (EU) 2022/2464, Art. 1, 1) and updates the item that must be disclosed. Mandatory disclosure encompasses the risks of sustainability matters to the company, as well as how the company impacts these matters ("double materiality") (Directive (EU) 2022/2464, item 29 and Art. 1, 1). Details on the Directive can be found as part of the European Union entries.		https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022L2464Large companies and all entities (except micro) that trade securities in the marketLegislativeEuropean ParliamentDirective2022Not applicableEncourages actors to follow the standardsISO 26000
92
31/05/2023DE-091DE - GermanyDisclosureInstrument identifiedApprovedCarbon-specificDoes not mandate action30Record not regulatedGuidance Notice on Dealing with Sustainability RisksSupports climate-related disclosures by the financial sectorThe German Financial Supervisory Authority BaFin published in December 2019, a Guidance Notice on Dealing with Sustainability Risks. It was directed in particular to supervised entities such as credit institutions, investment firms, insurance undertakings, fund management companies and pension funds. The notice shall be seen as non-binding guidance (good practice principles). This Guidance Notice can thus be seen as initiating a useful addition to the minimum requirements for risk management. As part of environmental risks, climate mitigation and adjustment to climate change are included. BaFin encourages its supervised entities to focus more strongly on climate risks and disclosure of climate-related risks.https://www.bafin.de/SharedDocs/Downloads/EN/Merkblatt/dl_mb_Nachhaltigkeitsrisiken_en.pdf?__blob=publicationFile&v=5Supervised entities such as credit institutions, investment firms, insurance undertakings, fund management companies and pension fundsFinancial regulatory authorityGerman Financial Supervisory Authority BaFinGuideline20192019The standard is cited in the textPrinciples for Responsible Investment (PRI)
TCFD
German Sustainability Code (DNK)
93
31/05/2023DE-092DE - GermanyDisclosureInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedGerman Commercial CodeThe German Commercial Code (Handelsgesetzbuch - HGB) includes regulation related to the preparation of non- financial statements including the disclosure of material environmental risks among othersThe German Commercial Code (Handelsgesetzbuch - HGB) includes regulation related to the preparation of financial and non-financial statements. It points out that the management report is to consider an analysis of the business development including assessing material opportunities and risks it faces. The code does not outline specific requirements for the disclosure. However, climate risks can be considered as principal risks within environmental matters.
Section 289c includes the content of the non-financial statement (management report):
1. The disclosure of environmental matters: greenhouse gas emissions, water consumption, air pollution, the use of renewable and/or non-renewable energy or the protection of biological diversity.
2. The disclosure of principal (material) risks that are related to the own business operations and that are highly likely to cause, now or in the future, seriously adverse impacts on the aspects including the environmental matters previously mentioned.
Organizations must comply or explain when they do not pursue policies for one or several disclosure aspects as per Sect. 289c Para. 4 HGB.
While the definitions of environmental risks are broad enough to encompass climate risks, they are not specifically defined or required. Rather, it is cited only as an example of environmental risk (Section 289c). To sum up, the HGB is currently not aligned with climate disclosure but could be improved in the future to mandate the report of climate risks in a regulated and routine fashion.		https://www.gesetze-im-internet.de/englisch_hgb/englisch_hgb.pdfCommercial entitiesExecutiveFederal Ministry of JusticeCode18971897Does not reference standards
94
31/05/2023DE-093DE - GermanyDisclosureInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedCSR Directive Implementation ActThe CSR Directive Implementation Act (CSR-RUG) focuses on the disclosure of non-financial information including environmental risks by certain large public-interest entities to respond to the EU's NFRDThe Corporate Sustainability Reporting Directive Implementation Act (CSR-RUG) was ratified in March 2017 and is specifically designed to implement the requirements of the European Union (EU) Non-Financial Reporting Directive (NFRD) into German law. However, from 2023, the NFRD will become the Corporate Sustainability Reporting Directive (CSRD), which Germany must incorporate into national law. The CSR-RUG focuses on the disclosure of non-financial information by certain large public-interest entities. The CSR-RUG is implemented within the existing legal framework of the German Commercial Code (Handelsgesetzbuch - HGB). Therefore, some sections regarding specific requirements for non-financial reporting of the HGB's provisions related to management reporting and disclosure are aligned in the CSR-RUG (such as HGB Sections 289c to 289e and 315b to 315c). Similarly to the HGB, the CSR-RUG does not outlines specific requirements for the disclosure of climate-related risks. However, climate risks can be considered as material risks within the environmental matters.HGB:
https://www.gesetze-im-internet.de/englisch_hgb/englisch_hgb.html

Additional information on the CSR-RUG: https://www.bmj.de/SharedDocs/Gesetzgebungsverfahren/Dokumente/BGBl_CSR-RiLi_UmsetzungsG.pdf;jsessionid=86494EEEFAEB60DB320B73985AE2BBD7.2_cid334?__blob=publicationFile&v=3		Capital market-oriented companies, financial institutions and insurance companies with more than 500 employees.LegislativeNational parliament of the Federal Republic of GermanyAct20172017Does not reference standards
95
02/08/2023DE-094DE - GermanyDisclosureInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedCommission Delegated Regulation (EU) 2021/2178Supplements the EU Taxonomy and Non-Financial Reporting Directive (NFRD) by specifying disclosure content and rulesEU Regulations are automatically binding to EU members (EU, 2022). Because the EU Taxonomy is a regulation, it automatically applies in Germany.
The Commission Delegated Regulation (EU) 2021/2178 specifies the format of disclosures required by the EU Taxonomy (Articles 2-6), applied in the Non-Financial Reporting Directive (NFRD). Furthermore, it requires and defines the format of disclosure of key performance indicators (KPIs) by financial and non-financial undertakings (Article 8). The Regulation is binding in its entirety and directly applicable in EU Member States (Article 10). Considering that the disclosure requirements do not cover climate-related risks, the Regulation is classified as broad-based.		Commission Delegated Regulation (EU) 2021/2178: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R2178

EU, 2022: https://commission.europa.eu/law/application-eu-law/implementing-eu-law_en

Regulation (EU) 2020/852: https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX: 32020R0852		Large (>500 employees) public interest entitiesExecutiveEuropean CommissionRegulation20212022Does not reference standards
96
11/05/2023DE-095DE - GermanyDisclosureInstrument identifiedApprovedBroad-basedMandates action40Record not regulatedSustainable Finance Disclosure Regulation (SFDR)Defines sustainable investment and mandates sustainability risk disclosure through EU regulationAs an EU regulation, the Sustainable Finance Disclosure Regulation became automatically binding in Germany on its date of application, without the need for separate incorporation. Directive (EU) 2019/2088, also called the Sustainable Finance Disclosure Regulation (SFDR), defines what a sustainable investment is (Art. 2, 17). The directive mandates a science-based approach for sustainable investments aimed at reducing GHG emissions (Art. 9, 3). It also mandates the disclosure of sustainable risk policies (Art. 3) and sustainability risks that can affect the financial performance of products in the financial sector, whether they fit or do not fit the definition of sustainable investment (items 13, 14 and 15). Sustainability risks encompass environmental, social and governance aspects (ESG) (item 14).Directive (EU) 2019/2088: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32019R2088Financial market participants and financial advisersLegislativeEuropean ParliamentDirective20192021Does not reference standards
97
31/05/2023DE-096DE - GermanyDisclosureInstrument identifiedApprovedBroad-basedDoes not mandate action50Record not regulatedGerman Sustainability Code (DNK)Provides guidance on how to comply with the CSR reporting obligationGerman Sustainability Code (DNK) is a voluntary reporting standard that provides guidance on sustainability reporting. It includes aspects related to greenhouse gas emissions, energy consumption, and material sustainability topics and environmental-related risks (opportunities and risks). It gives guidance on how to comply with the CSR reporting obligation.
The Sustainability Code was developed in 2010 by the German Council for Sustainable Development (RNE). RNE was established by the German federal government and operates as an advisory body to promote sustainable development in Germany.		https://www.deutscher-nachhaltigkeitskodex.de/en-GB/Home/DNK/DNK-OverviewLarge, small, public and private companiesExecutiveGerman Council for Sustainable Development (RNE)Code20102010Encourages actors to follow the standardsGerman Sustainability Code (DNK)
98
31/05/2023DE-097DE - GermanyDisclosureInstrument identifiedApprovedBroad-basedDoes not mandate action50Record not regulatedGerman Sustainable Finance StrategySupports climate-related disclosures by the private sectorThe German Sustainable Finance Strategy has as part of its objectives to improve the financial industry’s risk management and ensure financial market stability. As part of its measures (3), it mentions strengthening risk management and supervision. The document supports financial market participants to identify, assess and manage sustainability risks (measure 11) and =the real and financial sectors in improving risk management in relation to physical climate risks (measure 12). It includes information about climate-related disclosures (measure 5). The Strategy does not mandate action but can be leveraged for future regulations particularly targetting climate-related risks.https://www.bundesfinanzministerium.de/Content/EN/Standardartikel/Press_Room/Publications/Brochures/sustainable-finance-strategy.pdf?__blob=publicationFile&v=8Financial institutionsExecutiveFederal governmentStrategy20212021The standard is cited in the textPrinciples for Responsible Investment (PRI)
GRI Standards
TCFD
TNFD
German Sustainability Code (DNK)
99
30/05/2023DE-098DE - GermanyProcurementInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordGeneral Administrative Regulation on the Procurement of climate-friendly Services (AVV Klima)The AVV Klima ensures that climate-friendly alternatives are considered in the procurement processes (Greenhouse gas emissions, specifications of climate aspects and prohibits non-environmentally sustainable products)The General administrative regulations for the procurement of climate-friendly services (AVV Klima) replaces the General Administrative Regulation on the Procurement of Energy-Efficient Services (AVV EnEff). It ensures climate friendliness and, energy efficiency in all federal government procurement processes. It supports the goal of a climate-neutral administration by 2030 and the Federal Climate Protection Act (KSG) (§ 3, § 13 and § 15).

When determining procurement requirements, federal agencies have to identify whether there is a more climate-friendly variant. In particular, the greenhouse gas emissions should be considered in the award procedure. Some relevant requirements include:
1. To determine the most economical offer, life cycle costs must be taken into account including the costs of the greenhouse gas emissions of the service to be procured (§ 4 (4)) (applies only if the estimated order value exceeds 10,000 euros without sales tax). Considering the goal of reducing greenhouse gas emissions over the entire life cycle of the service, preference to the services that can be acquired at the lowest possible cost should be given (§ 2 (2)).
2. The climate-friendliness expectation of the service should be identified by the procurement offices and if this is not taken into account, it must be documented (§ 2 (4)). Therefore, they must comply or present explanations for non-compliance services.
3. It prohibits public bodies from purchasing certain non-environmentally sustainable products (§ 3). Includes a "negative list" of services that are generally not to be procured.

AVV Klima applies both to public contracts in the upper threshold area (GWB, VgV) and for the lower threshold area.		AVV Klima
https://www.bmwk.de/Redaktion/DE/Downloads/A/allgemeine-verwaltungsvorschrift-zur-beschaffung-klimafreundlicher-leistungen-avv-klima.html Federal Climate Change Act: https://www.bmuv.de/fileadmin/Daten_BMU/Download_PDF/Gesetze/ksg_final_en_bf.pdf		Federal agencies in direct federal administrationExecutiveFederal Ministry for Economic Affairs and Climate ProtectionRegulation20222022Requires actors to follow the standardsISO 14024
EMAS
ISO 50001
100
29/05/2023DE-099DE - GermanyProcurementInstrument identifiedApprovedCarbon-specificMandates action10Regulated recordFederal Climate Change ActThe Climate Change Act includes procurement as one of its components and demands climate targets to be observedThe Federal Climate Change Act is a legislation aimed at setting binding greenhouse gas reduction targets for Germany and ensuring the country's compliance with its climate commitments. The Act was enacted in December 2019 and it aims to achieve a 55% reduction in emissions by 2030 compared to 1990 levels, with the ultimate goal of reaching carbon neutrality by 2050. Germany amended the Climate Change Act, in June 2021 that sets higher national emissions reduction targets for 2030 (at least 65%) and 2040 (at least 88%), with the goal of achieving net greenhouse gas neutrality by 2045. As part of the programme, one of the fields considered is procurement.

Section 13 states that (2) When making procurements, the federal government shall examine how each of these operations can contribute to the achievement of the climate targets. Where there are two or more options for procurements, preference shall be given, after balancing against other relevant criteria, to the option with which the aim of reducing greenhouse gas emissions over the whole lifetime of the procured item can be achieved at the lowest cost.		Climate Change act
https://www.bmuv.de/fileadmin/Daten_BMU/Download_PDF/Gesetze/ksg_final_en_bf.pdf
General website
https://www.bundesregierung.de/breg-de/themen/klimaschutz/climate-change-act-2021-1936846		Federal governmentExecutiveFederal Ministry for Economic Affairs and Climate ActionAct20192019Does not reference standards