ASTM International recently issued a "Standard Guide for Financial Disclosures Attributed to Climate Change" (E2718-10). The ASTM standard draws upon some of the same information used by the SEC and has many parallels with the SEC guidance. However, the guide is intended for use on a voluntary basis and recognizes that there may be requirements, such as regulatory directives, affecting its use. Like the SEC guidance, the ASTM standard may be revised or supplemented over time as experience is gained with climate change financial disclosures.
A key concept in the ASTM standard is that reporting entities should either disclose material "financial impacts attributed to climate change" or disclose the basis for determining that such an assessment is not warranted. Impacts attributed to climate change include the risk of physical damage to facilities, regulatory costs and incentives, and shifts in the market for products and services. Factors to consider in determining whether disclosure is warranted include enforcement of climate change laws, predicted changes/trends in resource costs or availability, predicted changes in a company's assets due to financial impacts attributed to climate change, contractual assumption of risk or risk transfer agreements, litigation related to climate change, and information indicating that financial impacts attributed to climate change have been incurred or are likely to be incurred.
Disclosure categories identified by the standard include management's strategic analysis of material financial impacts attributed to climate change; the financial impacts of regulatory requirements; the estimated likelihood, magnitude, and timing of material financial impacts attributed to climate change; an estimate of anticipated insurance or other recoveries; and key external and internal factors regarding the timing or amount of material financial impacts attributed to climate change.