Towards an effective EU climate disclosure strategy? : An ex-ante evaluation and derivation of an analytical framework, of criteria and indicators regarding the EU Commission’s 2018 Action Plan on Financing Sustainable Growth and the 2018 Non-Financial Reporting Directive

Abstract

The EU climate disclosure strategy regarding the EU Commission’s 2018 Action Plan on Financing Sustainable Growth and the 2018 Non-Financial Reporting Directive is not effective enough. More clarity regarding the defini- tion of material climate-related risks for companies and the transparency of their long-term resilience strategies is needed. The EU should implement a more regulative disclosure framework, i.e. the NFI Directive should include stress tests to ensure future-orientation and comparability. Through such reforms and further improvements the EU should take a global lead in transforming the financial system.