ClientEarth response to the UK Transition Plan Taskforce’s disclosure framework and implementation guidance consultation survey for a Sector-Neutral Framework for private sector transition plans

ClientEarth’s response emphasises the imperative for the Transition Plan Taskforce to create standards for transition planning which:

1. provide a corrective solution to issues identified in relation to current market practice in transition plan disclosure:
2. empower regulators by setting clear, forceful and ambitious standards that can be translated into effective regulation and are not unduly ambiguous or permissive of approaches which undermine sustainability; and
3. compare favourably with the EU’s disclosure regime, and do not give rise to opportunities for regulatory arbitrage which undermine the impact of the EU’s own rules (or the recommendations of the UN High Level Expert Group).

ClientEarth identifies three key issues in particular in relation to which the framework should be strengthened:

1. science-based, Paris-aligned ambition should be mandatory;
2. plans, targets and reporting should cover all of an organisation’s Scope 1-3 GHG emissions, with no material exceptions; and
3. GHG removals, carbon credits and avoided emissions should not be permitted to displace absolute GHG emissions reductions in the achievement of GHG emissions reduction targets.