Our five recommendations were:

• First, endorse and implement ISSB's IFRS S2 IFRS S2 ‘Climate-related Disclosures’ standard globally: UK Finance calls on BCBS to back the ISSB’s IFRS standards and throw its weight behind promoting their adoption globally. We recommend that BCBS encourage IFRS S2 adoption by banks in those regions that do not implement them. We recommend that the BCBS do all that is necessary to ensure that the global baseline framework of IFRS S2 requirements become and continue to inform jurisdictional climate risk disclosure requirements, driving consistency, comparability and thereby support broader sustainability disclosure objectives. Rather than developing a wholly new Pillar 3 disclosure standard, it would be more beneficial for IFRS S2 or equivalent standards to be adopted and implemented by all sectors in all jurisdictions to support the transition to a decarbonised economy.
• Second, allow sufficient time for IFRS S2 implementation: Following endorsement and implementation of IFRS S2, BCBS should allow sufficient time for banks and companies to implement the requirements, and for corporate disclosures to evolve through learnings and investor and market discipline.
• Third, develop prudential capital regime: Whilst corporate disclosures evolve and improve, as discussed in 2.2, BCBS should evaluate and finalise any climate financial risk related prudential regime requirements, as needed, including through Quantitative Impact Studies (QIS) and other tools. This should precede any new Pillar 3 disclosure proposals.
• Fourth, implement supervisory reporting: BCBS should develop supervisory reporting standards, incremental to requirements of IFRS S2 or similar standards. We recommend that these be disseminated through jurisdictional supervisors and allow sufficient time for embedding. This should precede any new Pillar 3 disclosure proposals.
• Fifth, develop incremental Pillar 3 disclosures where required and related cost-benefit analysis: Starting with supervisory reporting standards, BCBS should select summaries or extracts for evaluation for potential Pillar 3 proposals. Should BCBS go ahead with Pillar 3 proposals, we recommend undertaking a cost benefit analysis, including considering duplication with IFRS S2 or equivalent standards before moving forward. BCBS should draw on existing best practices and lessons learned from the implementation of frameworks such IFRS S2 and EU Pillar 3 to maximise regulatory coherence. Whilst standardisation may be an objective, BCBS should reduce the risk of climate reporting becoming an industry in its own right, with slightly different requirements across different regulatory bodies for no meaningful benefit to users. Any future Pillar 3 proposals should follow the BCBS’s guiding principles for Pillar 3 As set out in DIS10, 10.13-10.20. of Clarity, Comprehensiveness, Meaningfulness, Consistency over time, and Comparability across banks. It is important that BCBS focus on the prudential rationale for any Pillar 3 disclosures.