Corporate Climate Disclosures KPIs by Sector
Essential KPIs for evaluating corporate climate disclosure quality, with 2024-2025 benchmark ranges across sectors and guidance on navigating CSRD, SEC, and ISSB requirements.
Corporate climate disclosure has shifted from voluntary sustainability reporting to regulated financial disclosure. The EU's Corporate Sustainability Reporting Directive (CSRD), SEC climate rules, and ISSB standards create overlapping requirements that affect thousands of companies globally. Understanding disclosure quality—not just compliance—has become essential for investors, companies, and their advisors. This benchmark deck provides the KPIs that matter for evaluating climate disclosures, with ranges drawn from 2024-2025 reporting across sectors.
The Disclosure Landscape in 2025
The regulatory convergence is unprecedented. CSRD requires approximately 50,000 companies to report under European Sustainability Reporting Standards (ESRS) starting in 2024-2026. The SEC's climate rules, though legally contested, signal US regulatory direction. ISSB standards (IFRS S1 and S2) are being adopted across 140+ jurisdictions.
A 2024 analysis by the World Business Council for Sustainable Development found that multinational companies face an average of 4.7 distinct climate disclosure regimes. The compliance burden is real—but so is the opportunity to demonstrate credibility to investors increasingly focused on climate risk.
The core challenge: disclosure frameworks ask similar questions (emissions, risks, targets) but with different definitions, boundaries, and assurance requirements. Companies that build robust underlying data and governance can adapt to multiple frameworks; those treating disclosure as a compliance exercise will struggle.
The 8 KPIs That Matter
1. Emissions Disclosure Completeness
Definition: Percentage of material emissions sources disclosed across Scope 1, 2, and 3.
| Scope | Bottom Quartile | Median | Top Quartile | CSRD Requirement |
|---|---|---|---|---|
| Scope 1 | <75% sources | 85-92% | >98% | 100% of material |
| Scope 2 (Location) | <80% sources | 88-94% | >98% | 100% of material |
| Scope 2 (Market) | <60% reported | 70-82% | >92% | Required if claimed |
| Scope 3 Categories | 3-5 of 15 | 7-10 of 15 | 12-15 of 15 | Material categories |
| Scope 3 Coverage | <40% estimated | 55-70% | >85% | Majority of material |
Materiality matters: Frameworks allow omitting immaterial sources, but definitions of materiality vary. Conservative approach: disclose all categories above 1% of total emissions.
2. Transition Plan Quality Score
Definition: Comprehensiveness and credibility of disclosed climate transition plans.
| Element | Weight | Assessment Criteria |
|---|---|---|
| Emission Reduction Targets | 20% | Science-based, interim milestones, Scope 3 inclusion |
| Decarbonization Pathway | 20% | Sector-specific strategies, technology assumptions, timeline |
| Capital Allocation | 15% | Climate-aligned CapEx, R&D investment, stranded asset assessment |
| Governance | 15% | Board oversight, management incentives, accountability mechanisms |
| Implementation Actions | 15% | Concrete initiatives, progress metrics, avoided emissions |
| Risk Management | 10% | Transition risks identified, mitigation strategies |
| Just Transition | 5% | Workforce considerations, community impacts |
| Quality Level | Score | Prevalence (2024) |
|---|---|---|
| Leading | 80-100 | 8-12% |
| Developed | 60-79 | 20-28% |
| Emerging | 40-59 | 30-40% |
| Basic | 20-39 | 20-30% |
| None/Minimal | <20 | 10-18% |
3. Climate Risk Disclosure Depth
Definition: Quality of physical and transition risk identification and assessment.
| Risk Disclosure Component | Current Median | Best Practice |
|---|---|---|
| Physical Risk Identification | Qualitative only | Asset-level quantification |
| Transition Risk Identification | High-level categories | Sector-specific pathways |
| Time Horizons | <10 years typically | Short/medium/long (30+ years) |
| Scenario Analysis | 1 scenario or none | 3+ scenarios including 1.5°C |
| Financial Impact Quantification | Rare (<20%) | Material impacts valued |
| Opportunity Identification | Often absent | Balanced risk/opportunity |
Scenario analysis gap: TCFD recommendations and ISSB require scenario analysis, but quality varies dramatically. Many companies perform pro-forma scenarios that don't inform strategy.
4. Target Credibility Index
Definition: Assessment of whether disclosed targets are achievable based on plans and progress.
| Target Element | Credible Indicator | Red Flag |
|---|---|---|
| Base Year | Recent, verified | Distant, restated repeatedly |
| Target Year | Progressive (2025, 2030, 2050) | 2050 only, no interim |
| Scope Coverage | Full Scope 1+2, material Scope 3 | Scope 1+2 only, or partial |
| Absolute vs. Intensity | Both disclosed | Intensity only (hides growth) |
| Pathway | Year-by-year trajectory | Target year only |
| Progress Tracking | Annual vs. baseline | Narrative without numbers |
| Third-Party Validation | SBTi or equivalent | Self-validated only |
| Target Status | Prevalence | Interpretation |
|---|---|---|
| SBTi Validated | 35% of large caps | Highest credibility |
| Stated Net Zero | 65% of large caps | Variable credibility |
| Aligned with Paris | 25-35% assessed | Depends on methodology |
| On Track to Target | 20-30% | Based on current progress |
5. Assurance Level and Scope
Definition: Type and coverage of third-party assurance on climate disclosures.
| Assurance Level | Current Adoption | CSRD Trajectory |
|---|---|---|
| None | 42% | Not acceptable (2025+) |
| Limited (Scope 1+2) | 35% | Minimum 2025-2027 |
| Limited (Full) | 15% | Target 2027+ |
| Reasonable (Scope 1+2) | 6% | Required 2028+ |
| Reasonable (Full) | 2% | Future expectation |
| Region | Limited+ Assurance Rate | Growth Rate |
|---|---|---|
| EU | 65% | +8% annually |
| UK | 52% | +10% annually |
| US | 38% | +12% annually |
| Asia-Pacific | 28% | +15% annually |
Assurance scope matters: Many companies claim "assured" disclosures when assurance covers only Scope 1 and 2. Scope 3 assurance remains rare and methodologically challenging.
6. Data Quality and Controls
Definition: Robustness of underlying data systems and internal controls.
| Control Level | Characteristics | Audit Readiness |
|---|---|---|
| Financial-Grade | Documented controls, SOX-like testing, integrated systems | Reasonable assurance ready |
| Structured | Formal processes, some automation, annual review | Limited assurance ready |
| Manual-Intensive | Spreadsheet-based, limited documentation | Significant remediation needed |
| Ad Hoc | Collected for reporting only, inconsistent | Not assurance-ready |
| Sector | Financial-Grade Controls | Manual-Intensive |
|---|---|---|
| Energy/Utilities | 25-35% | 15-25% |
| Financial Services | 20-30% | 20-30% |
| Technology | 18-28% | 25-35% |
| Manufacturing | 12-22% | 30-40% |
| Consumer/Retail | 8-18% | 35-45% |
7. Governance Integration
Definition: Degree to which climate considerations are embedded in corporate governance.
| Governance Element | Leading Practice | Current Median |
|---|---|---|
| Board Climate Expertise | Dedicated director or committee | General ESG committee |
| Climate in Risk Framework | Integrated ERM process | Separate sustainability risk |
| Executive Incentives | Quantified climate metrics | Qualitative sustainability |
| CapEx Review | Climate impact assessment | Project-by-project |
| Strategy Integration | Climate scenario in strategy | Parallel sustainability strategy |
| Integration Level | Prevalence | Characteristics |
|---|---|---|
| Deep Integration | 12-18% | Climate embedded in core governance |
| Formal Structures | 30-40% | Dedicated committees, some incentives |
| Emerging | 25-35% | ESG committee, limited integration |
| Minimal | 15-25% | Disclosure-driven only |
8. Comparability and Consistency
Definition: Ability to compare disclosures across time periods and peer companies.
| Comparability Factor | Current Challenge | Best Practice |
|---|---|---|
| Methodology Consistency | Annual changes common | Stable with documented changes |
| Boundary Definition | Unclear operational control | Explicit consolidation rules |
| Restatement Practice | Opaque base year changes | Transparent recalculation |
| Peer Alignment | Different scope definitions | Industry protocol adoption |
| Time Series | Limited historical data | 5+ year data availability |
GHG Protocol evolution: Pending GHG Protocol updates will clarify boundary and Scope 3 calculation issues. Companies should prepare for potential restatement requirements.
What's Working in 2024-2025
Integrated Reporting Platforms
Companies consolidating climate data into enterprise sustainability platforms (Persefoni, Watershed, Salesforce Net Zero Cloud, SAP Sustainability) achieve higher data quality and auditability than spreadsheet-based approaches. Platform adoption correlates with 30-40% higher assurance readiness scores.
The key benefit: consistent methodology application across business units and geographies, with audit trails suitable for third-party verification.
Double Materiality Assessment
CSRD requires double materiality—assessing both financial impact of climate on the company and company impact on climate. Organizations conducting rigorous double materiality assessments report better stakeholder engagement and more defensible disclosure scope decisions.
The process forces explicit decisions about what to disclose and why, improving disclosure quality even for companies not subject to CSRD.
Climate Competency in Audit Committees
Board audit committees increasingly take responsibility for climate disclosure accuracy, applying financial reporting rigor to sustainability data. This governance shift drives investment in controls, documentation, and assurance readiness.
Companies with audit committee climate oversight achieve 25% higher assurance levels than those with sustainability committee oversight alone.
What Isn't Working
Framework Proliferation
Despite convergence efforts, companies still navigate CDP, GRI, SASB, TCFD, ISSB, CSRD, SEC, and regional frameworks. The reporting burden consumes resources that could improve actual performance. True consolidation remains years away.
Pragmatic response: build ISSB/ESRS-compliant data foundation (the most comprehensive requirements), map to other frameworks.
Scope 3 Estimation Theater
Many Scope 3 disclosures are spend-based estimates with 40-100% uncertainty ranges. These numbers satisfy disclosure checkboxes but provide limited decision-relevant information. Regulators and investors increasingly distinguish between high-quality primary data disclosures and estimated placeholders.
Assurance Standard Gaps
Sustainability assurance standards (ISAE 3000, ISAE 3410) are less developed than financial audit standards. Assurance providers interpret requirements differently; assurance scope and depth vary widely. The IAASB's new ISSA 5000 standard aims to close gaps, but implementation will take years.
Key Players
Established Leaders
- CDP (Carbon Disclosure Project) — 23,000+ companies disclosing through CDP platform. Industry standard for climate reporting.
- ISSB (International Sustainability Standards Board) — Global baseline for sustainability disclosure (IFRS S1/S2).
- GRI (Global Reporting Initiative) — Most widely used sustainability reporting standards.
- TCFD (Task Force on Climate-related Financial Disclosures) — Framework adopted by 4,000+ organizations.
Emerging Startups
- Persefoni — Carbon accounting platform for CSRD and SEC disclosure compliance. Used by 200+ enterprises.
- Watershed — Enterprise carbon accounting software. Used by Stripe, Airbnb, Klarna.
- Normative — AI-powered carbon accounting for emissions calculation and disclosure.
- Emitwise — Supply chain emissions tracking and disclosure platform.
Key Investors & Funders
- SEC — Mandatory climate disclosure rules for US public companies.
- European Commission — CSRD requiring disclosure from 50,000+ companies.
- Sequoia Capital — Backing Watershed and climate disclosure tech.
Examples
Unilever Climate Transition Action Plan: Published comprehensive transition plan including Scope 1, 2, and 3 targets (validated by SBTi), detailed decarbonization pathways by business unit, climate-aligned CapEx allocation (€1B+ annually), and integration with executive compensation (25% of bonus tied to sustainability metrics). Third-party reasonable assurance on Scope 1 and 2, limited assurance on Scope 3.
Microsoft Carbon Negative Commitment: Disclosed full Scope 3 inventory with methodology transparency, including purchased goods (Category 1), use of products (Category 11), and cloud services emissions allocation. Internal carbon fee of $100/tonne drives business unit accountability. Third-party reasonable assurance on emissions data.
Shell Climate Target Update: Following court ruling requiring stronger targets, Shell published revised net emissions intensity targets with transition pathway. Illustrates both regulatory pressure and challenges—critics argue intensity targets allow absolute emission growth. Demonstrates that disclosure alone doesn't ensure credibility.
Action Checklist
- Conduct double materiality assessment to define disclosure scope and priorities
- Map existing disclosures to ISSB/ESRS requirements to identify gaps
- Implement enterprise sustainability data platform for consistency and auditability
- Develop Scope 3 improvement roadmap moving from spend-based to activity-based data
- Establish internal controls framework for climate data comparable to financial controls
- Create transition plan with sector-specific decarbonization pathways
- Obtain limited assurance on Scope 1 and 2; plan trajectory to reasonable assurance
- Integrate climate metrics into executive compensation and capital allocation
FAQ
Q: How do we handle overlapping CSRD, SEC, and ISSB requirements? A: Build to the most comprehensive requirement (typically CSRD/ESRS), then map to others. ISSB is designed for interoperability with ESRS. SEC requirements are narrower (Scope 1, 2, and material Scope 3 only). Invest in data infrastructure that supports multiple outputs from single collection.
Q: What level of Scope 3 disclosure is "enough"? A: Material categories must be disclosed—typically 80%+ of Scope 3 footprint. For most companies, this means Categories 1 (purchased goods), 3 (fuel/energy), and either 11 (use of products) or 15 (investments). Start with spend-based screening to identify material categories, then invest in improved data for those categories.
Q: How do we prepare for reasonable assurance requirements? A: Treat sustainability data with financial controls rigor: documented policies, segregation of duties, evidence retention, variance analysis, management certification. Work with your auditor to identify control gaps before formal assurance engagement. Budget 12-18 months for remediation.
Q: Should we get SBTi validation for our targets? A: SBTi validation provides credibility and comparability. For companies in SBTi-covered sectors, validation is increasingly table stakes. For others, alignment with SBTi methodology (even without formal validation) signals rigor. Be aware that SBTi is revising standards—near-term commitments may require updates.
Sources
- EFRAG, "European Sustainability Reporting Standards (ESRS) Implementation Guidance," 2024
- ISSB, "IFRS S1 and S2 Application Guidance," 2024
- SEC, "The Enhancement and Standardization of Climate-Related Disclosures," Final Rule, 2024
- CDP, "Global Disclosure Report: Climate Data Quality Analysis," 2024
- WBCSD, "Corporate Climate Disclosure Benchmark Study," October 2024
- Science Based Targets initiative, "SBTi Annual Progress Report," 2024
- PwC, "State of Climate Reporting: Global Assessment," November 2024
Related Articles
Case study: Corporate climate disclosures — A startup-to-enterprise scale story
How companies scale climate disclosures from early-stage transparency to enterprise-level compliance under CSRD, SEC rules, and TCFD frameworks.
Deep Dive: Corporate Climate Disclosures — A Buyer's Guide: How to Evaluate Solutions
a buyer's guide: how to evaluate solutions. Focus on a startup-to-enterprise scale story.
Interview: practitioners on Corporate climate disclosures — what they wish they knew earlier
A practitioner conversation: what surprised them, what failed, and what they'd do differently. Focus on materiality, assurance, data controls, and reporting-operating model design.