PCAF prescribes specific reporting requirements and recommended metrics that financial institutions must fulfil when disclosing their financed emissions. Understanding what must be disclosed, what is recommended, and how the disclosure should be structured is essential for any institution preparing its first PCAF-aligned report.
The Minimum Required Disclosures
To conform with the PCAF Standard, a financial institution shall disclose all of the following:
1. Absolute Financed Emissions
The total financed emissions across all covered asset classes, expressed in tCO2e. This is the primary metric and must be disaggregated by:
- Asset class: Listed equity/bonds, business loans, project finance, CRE, mortgages, motor vehicle loans, UoP, securitizations, sovereign debt, sub-sovereign debt
- Emission scope: Scope 1 and Scope 2 of borrowers/investees as a combined figure; Scope 3 of borrowers/investees separately
Absolute financed emissions represent the aggregate annual GHG footprint of the financial institution's portfolio.
2. Portfolio Coverage
The percentage of total loans and investments (by outstanding amount) that is covered in the financed emissions calculation. Coverage is not expected to be 100% from day one, but financial institutions must disclose:
- The percentage covered
- What is excluded and why (e.g., data limitations, immaterial asset classes, regulatory restrictions)
3. Weighted Average Data Quality Score
Financial institutions shall calculate and disclose the weighted average data quality score by asset class. This signals the reliability of the reported figures.
4. Emission Intensity Metrics (Recommended)
While absolute emissions are required, PCAF strongly recommends also reporting:
- Weighted average carbon intensity (WACI): tCO2e per million USD/EUR of revenue, for each asset class where revenue data is available
- Portfolio carbon footprint: Total Scope 1 + 2 financed emissions / Total portfolio value (in tCO2e/million invested)
These intensity metrics enable comparison across portfolios of different sizes and provide the data needed for TCFD Metrics and Targets disclosures.
5. Disaggregation by Emission-Intensive Sectors
For emission-intensive sectors, PCAF requires disaggregated reporting. Sectors typically requiring separate disclosure include:
- Coal mining and extraction
- Oil and gas exploration and production
- Power generation
- Steel, cement, and other heavy industry
- Aviation and shipping
PCAF aligns its sector classification with NACE (European) and GICS (American) sector codes to maximise consistency across reporting frameworks. Financial institutions should ensure their portfolio management systems are configured to tag exposures with the appropriate sector codes.
The Financed Emissions Reporting Table
PCAF provides a standard reporting table in Annex 10.2 that financial institutions are encouraged to complete and publish. The table includes columns for:
- Asset class
- Outstanding amount
- Total financed emissions (Scope 1 + 2 combined and Scope 3 separately)
- Coverage percentage
- Weighted average data quality score
- Emission intensity metric (WACI or portfolio carbon footprint)
- Notes on methodology and exclusions
Financial institutions may publish the table in their annual sustainability report, integrated report, or as a standalone climate disclosure document.
Sample disclosure table extract (illustrative)
| Asset Class | Outstanding (โฌB) | Coverage | Scope 1+2 (ktCO2e) | DQ Score | WACI |
|---|---|---|---|---|---|
| Listed Equity | 12.5 | 95% | 2,340 | 1.8 | 185 tCO2e/โฌM rev |
| Business Loans | 45.0 | 78% | 8,910 | 3.2 | 310 tCO2e/โฌM rev |
| Mortgages | 28.0 | 100% | 1,120 | 3.6 | โ |
| Project Finance | 6.0 | 100% | 3,200 | 2.1 | โ |
| Total | 91.5 | 89% | 15,570 | 2.9 | โ |
Scope 3 of Borrowers and Investees
Starting with reports published in 2025, PCAF requires Scope 3 financed emissions to be disclosed. However, given the difficulty of obtaining comprehensive Scope 3 data from all borrowers and investees, PCAF specifies:
- Scope 3 financed emissions shall be reported separately from Scope 1 and 2
- Financial institutions shall disclose which Scope 3 categories of borrowers/investees are included
- The Scope 3 reporting can build on existing Scope 1 and 2 reporting infrastructure and expand progressively
Removing Emissions and Carbon Credits
Financial institutions may also report:
- Attributed emission removals: Based on borrowers' or investees' carbon removal activities (same attribution factor applies)
- Attributed carbon credits: Both credits generated by and retired by investees
These data points shall be reported separately from absolute emissions and must never be used to offset reported absolute financed emissions.
GHG Inventory Integration
PCAF requires that financed emissions are integrated into the financial institution's overall GHG inventory rather than reported as a standalone figure. This means:
- Financed emissions are reported under Scope 3 Category 15 in the GHG inventory
- Facilitated emissions (Part B) are disclosed as a supplementary accounting note within Category 15
- Insurance-associated emissions (Part C) are disclosed as a separate supplementary note
- Scope 1 and scope 2 operational emissions of the financial institution itself continue to be reported separately
This integrated approach ensures the complete climate impact of the institution is visible in one place, allowing stakeholders to compare operational and portfolio-level emissions.
PCAF's reporting framework is like the annual report of a company: there are required financial statements (the profit and loss account, balance sheet) representing the minimum disclosure, and there are optional additional disclosures (management discussion, segment analysis) that provide richer context. Absolute financed emissions are the profit and loss account. Intensity metrics, sector breakdowns, and data quality roadmaps are the supplementary disclosures that transform a compliance exercise into a genuine transparency tool.
Key Takeaways
- 1Required disclosures include absolute financed emissions (tCO2e) disaggregated by asset class, portfolio coverage percentage, and weighted average data quality score
- 2Scope 1+2 and Scope 3 financed emissions of borrowers must be reported separately - Scope 3 reporting is required starting with 2025 reports
- 3WACI and portfolio carbon footprint are strongly recommended intensity metrics that enable cross-portfolio comparison and TCFD compliance
- 4Emission removals and carbon credits must be reported separately and can never offset absolute financed emissions
- 5Financed emissions integrate into the institution's overall GHG inventory under Scope 3 Category 15, alongside facilitated and insurance-associated emissions as supplementary notes