ESRS vs TCFD
TCFD was formally disbanded in October 2023. Its framework now lives inside ESRS E1. If you are reporting under CSRD, you are already reporting TCFD-aligned disclosures — here is exactly how they map.
ESRS E1 fully absorbs TCFD. If you report ESRS E1 in compliance with CSRD, you satisfy TCFD requirements automatically. There is no need to produce a separate TCFD report — point investors to your ESRS E1 disclosures instead.
TCFD is no longer a standalone framework
The Task Force on Climate-related Financial Disclosures was established by the Financial Stability Board in 2015 and published its recommendations in 2017. It became the dominant climate risk disclosure framework globally — adopted by the UK, EU, Japan, Singapore and many others as a baseline.
In October 2023, TCFD formally disbanded. The ISSB took over monitoring responsibilities. TCFD's four-pillar structure — Governance, Strategy, Risk Management, and Metrics & Targets — is now embedded in both IFRS S2 (climate) and ESRS E1 (climate). Reporting under either of these satisfies TCFD.
How TCFD pillars map to ESRS E1
TCFD's four pillars map directly into ESRS E1:
Governance → ESRS E1-GOV: Board oversight of climate, management roles and responsibilities, incentive structures.
Strategy → ESRS E1-SBM: Climate-related risks and opportunities, scenario analysis, business model resilience, transition plan.
Risk Management → ESRS E1-IRO: Climate risk identification, assessment and prioritisation processes.
Metrics & Targets → ESRS E1-5 through E1-9: Scope 1, 2 and 3 emissions, energy consumption, climate targets, carbon credits.
What ESRS E1 adds beyond TCFD
ESRS E1 is more comprehensive than TCFD in several areas:
Impact materiality — TCFD is financially focused. ESRS E1 also requires disclosure of your company's own impacts on climate (emissions), not just financial risks from climate.
Scope 3 — TCFD recommended Scope 3 disclosure. ESRS E1-5 mandates it for material categories.
Transition plans — TCFD encouraged transition plan disclosure. ESRS E1-1 makes it mandatory.
Physical risk — Both cover physical risk, but ESRS E1 requires more granular location-specific physical risk assessment.
ESRS vs TCFD — side by side
| Aspect | ESRS | TCFD |
|---|---|---|
| Status | Active (CSRD mandatory) | Disbanded October 2023 |
| Governance pillar | ESRS E1-GOV | Governance disclosures |
| Strategy pillar | ESRS E1-SBM + transition plan | Strategy disclosures |
| Risk pillar | ESRS E1-IRO | Risk management disclosures |
| Metrics pillar | ESRS E1-5 to E1-9 | Metrics & targets |
| Scope 3 | Mandatory (ESRS E1-5) | Recommended |
| Transition plan | Mandatory (ESRS E1-1) | Encouraged |
| Assurance | Mandatory | Not required |
Frequently asked questions
Is TCFD still required if I report under CSRD?
No separate TCFD report is needed. ESRS E1 fully satisfies TCFD requirements. Point any investors or lenders requesting TCFD disclosures to your ESRS E1 section.
Who took over from TCFD?
The ISSB (International Sustainability Standards Board) took over monitoring of climate-related disclosures from TCFD in October 2023. TCFD's methodology now lives inside IFRS S2 and ESRS E1.
Do I still need to complete CDP questionnaires?
CDP questionnaires are separate from TCFD and CSRD, though they draw on the same data. Your ESRS E1 disclosures and GHG Protocol calculations feed directly into CDP climate responses — significantly reducing the effort.
What is the difference between ESRS E1 and IFRS S2?
ESRS E1 and IFRS S2 both build on TCFD and overlap approximately 70%. ESRS E1 additionally requires impact materiality disclosures (how your company affects climate) — IFRS S2 focuses only on financial materiality (how climate affects your company).
If TCFD is disbanded, why do investors still ask for TCFD reports?
Many investor questionnaires and lender requirements still reference TCFD because the terminology is familiar and the framework was widely adopted. In practice, your ESRS E1 disclosure satisfies these requests — explain this to investors and provide a TCFD-to-ESRS E1 mapping.