Perigon's Banking Barometer 2024.
Sustainability disclosures assessed for 61 institutions across the full breadth of UK and Irish financial services.
TCFD phase-in complete. Page counts kept growing.
Welcome to the second of Perigon's Financial Institution Sustainability Reporting Benchmarks. It is always daunting at the start of the process, looking at the mountain of information and analysis we need to climb to produce this report. But this year, like last, we are confident that we have pulled out some important trends that sustainability professionals in Financial Services should be aware of.
The main change in recent years has been the growth in TCFD (or Climate-related Financial Disclosures), both in volume terms and sophistication. 2023 was the final year of the phased introduction of reporting requirements, with many of the smaller companies in our cohort having to disclose for the first time.
Next year, I expect we will see a similar step up in companies going further and disclosing their first climate transition plans. Meanwhile, I hope you find the wealth of information in this 2024 Benchmark of interest and of use as you work through your priorities for your next set of year-end disclosures.
Emma Walford, Founding Partner, Perigon Partners
Recommendations
- More ≠ better. Have the confidence to be concise.
- Get real about materiality. Understanding is the critical foundation.
- Harness transition plan momentum. A powerful tool to galvanise action.
- Remember your core purpose. The socio-economic story is under-told.
The volume of sustainability reporting kept growing. The quality did not always follow.
Average sustainability page count has risen from 8.5 pages in 2020 to 40.0 pages in 2024. The highest single page count was 188 pages.
Reports have burgeoned since 2020
TCFD regulations have driven a steady increase in sustainability-related ARA content. Those having grappled with TCFD requirements for longer have started to rein back on the volume and incorporate more into the ARA rather than in separate reports, a sign of maturity.
More is not better. We are seeing a trend of scaling back following a peak last year. IFRS S1/S2 will require a stricter lens on materiality and balance. The largest banks have already started pulling back. Smaller institutions should take note.
People-related narrative dominates despite climate surge
Sentiment analysis of the ARA front sections shows the people story remains dominant for banks even after the proliferation of climate-related financial disclosures. This (AI-supported) analysis was completed for 51 of the cohort, with 10 reports excluded due to formatting / readability challenges. Building societies who have typically been later in adopting climate disclosures focused closer to 90% of non-financial content on societal and colleague issues.
30% have assessed materiality. Broadly in line with last year.
Materiality remains a minority pursuit — most common among the largest institutions, largely absent among the smallest.
A Materiality Assessment is where a company follows a structured process to identify which sustainability-related impacts, risks and opportunities are most significant. Over 70% of those with more than 10,000 employees have done one — but only 22% of those with 500–2,000 employees.
Although headline numbers have remained broadly static between 2023 and 2024, there has been an increase in the proportion of materiality assessments referenced that were clearly labelled as a "Double Materiality Assessment" (DMA). This approach assesses a company's impact on people and the planet as well as considering the financial risks and opportunities from ESG matters. It is considered the gold standard and underpins new CSRD legislation in Europe which comes into force from this year end. This year, two Irish banks undertook their first CSRD-aligned DMA.
Four shortcomings persist
A sophisticated assessment of materiality supports risk management, resource efficiency, the relevance and commerciality of plans, and the brevity of disclosures. The Barometer findings make clear that too few institutions are placing sufficient importance on materiality and those who do regularly undertake this process are often not approaching it in a way that realises its potential value.
Insufficient focus
There is a tendency to list numerous material issues. The true strategic value is to enable you to pinpoint and focus on a few areas of greatest significance.
Value chain blindness
Many firms focus their assessment on direct operations rather than the far more significant impacts through products, services and purchasing choices.
Governance gremlins
Governance shows up often as a material issue. Its place is as an important mitigant to both financial and non-financial risks — not as an impact or risk of its own.
Materiality for the sake of it
The outputs of a DMA should underpin strategy first and foremost, reporting second. If it does neither, it was probably a waste of time and money.
70% have a sustainability strategy. Less than a quarter link it to materiality.
Having a strategy that is not grounded in evidence or linked to the commercial strategy is unlikely to be effective.
70% of the 2024 cohort have a sustainability strategy that they reference in their annual report. However, 8 use "Environment", "Social" and "Governance" as their three sustainability strategy priorities — a generic approach demonstrating a lack of linkage to the commercial strategy or understanding of the firm's unique impacts, risks and opportunities.
Integration is increasing. Three companies notably moved from separate or linked sustainability strategies to a much more commercially embedded approach this year — Perigon's core belief is the need for a single, integrated sustainable corporate strategy.
The materiality linkage gap. Less than a quarter of those with a sustainability strategy clearly and explicitly linked it to materiality. Without that grounding, strategy risks being a collection of good intentions rather than a disciplined response to the institution's most significant impacts, risks and opportunities.
Climate continues to be the most common element of firms' sustainability strategies, rising in 2024. The articulation of positive impact from FIs' core business model is seldom done clearly or well, though efforts to include this as part of a strategy have improved this year.
13% have published a transition plan. 23% intend to do so this year.
In 2023, the Transition Plan Taskforce finalised its gold-standard framework. A leading group of firms have already published. Many more are on their way.
In addition to the eight firms that have set out their first transition plans, 14 stated their intention to develop one in the coming year. Perhaps surprisingly, six of these had only just published their first Climate-Related Financial Disclosures — this rapid acceleration suggests smaller institutions will quickly be on par with their larger peers.
Transition planning can galvanise action. This is a sensible step regardless of where you are on your climate journey. It provides a construct to start out smartly and re-align existing, sometimes disparate, efforts. For institutions without a net zero target, a transition plan is still a valuable organising framework.
63% chose to publish within the ARA. A narrow majority of those with a transition plan chose to publish it within their Annual Report and Accounts, rather than as a standalone document.
Larger firms lead the charge. Seven of the eight published transition plans belong to firms with over £10bn in customer lending, split between the larger full service banks and building societies. No fintech has yet published a transition plan.
Scope 1 & 2 disclosures near-universal. Scope 3 starting to catch up.
21 firms made a good attempt at reporting their full GHG emissions inventory — up from 12 firms last year. Financed emissions rose from 33% to 52% of firms reporting.
Scope 1 & 2 emissions are now near-universally reported, even by firms who sit beneath the Streamlined Emissions and Carbon Reporting (SECR) threshold.
Scope 3 operational emissions (e.g. travel, waste, commuting) are at least partially reported by an overwhelming 87%. Supplier and financed emissions pose significantly more challenge on data availability and accuracy, but progress was made on reporting both in the last year.
Emissions intensity was most commonly calculated per number of FTE but firms took different approaches to which scopes of emissions to include in the calculation. Of those reporting, averages were:
- 0.2 tCO₂e/FTE for scope 1 and 2 only (8 firms);
- 2.0 tCO₂e/FTE for scope 1, 2 and operational scope 3 (18 firms); and
- 12.9 tCO₂e/FTE for scope 1, 2 and 3 excluding financed emissions (5 firms).
Carbon credits were purchased by 27 firms (44%). While the largest banks were seen to step back from carbon neutrality claims and move towards SBTi-aligned terminology of "Beyond Value Chain Mitigation", the majority of other firms engaging with carbon credits still made — now potentially misleading — claims about carbon neutrality and offsetting.
Cohort and definitions.
Timing
Assessment was based on publicly available annual reports and supplementary documents as at our cut-off date in summer 2024. These reports span year-end dates between May 2023 and April 2024.
Two firms were removed from the previous year's cohort due to M&A activity (Sainsbury's Bank and Tesco Bank) and twelve were added.
Full Service Banks (11)
Specialist / Challenger Banks (22)
Fintechs (10)
Building Societies (17)
* New additions to the 2024 cohort.
Glossary
- ARA
- Annual Report and Accounts.
- BVCM
- Beyond Value Chain Mitigation — investment in GHG reduction outside the value chain.
- CSRD
- Corporate Sustainability Reporting Directive — EU regulation from 2024.
- DMA
- Double Materiality Assessment — assesses both financial materiality and impact on people and planet.
- GFANZ
- Glasgow Financial Alliance for Net Zero — coalition committed to net zero lending.
- IFRS S1/S2
- ISSB sustainability (S1) and climate (S2) disclosure standards.
- SECR
- Streamlined Energy and Carbon Reporting — required for large unquoted UK companies.
- TCFD
- Task-force for Climate-related Financial Disclosures — now subsumed into the ISSB.
- TPT
- Transition Plan Taskforce — developed the gold-standard framework for transition plans.
- UK SRS
- UK Sustainability Reporting Standards — based on ISSB standards, replacing TCFD.