The PCAF Disclosure Checklist (DCL) is the formal tool PCAF uses to assess whether a signatory's financed emissions disclosure meets the requirements and recommendations of the Standard. Published in May 2025, the checklist is a structured questionnaire that guides financial institutions through the key elements of a compliant disclosure and provides the basis for PCAF's review process.
Purpose and Scope of the Checklist
The DCL serves three purposes for PCAF signatories:
- Self-assessment: Financial institutions can use the checklist before publishing their disclosure to verify they have covered all required elements
- External review: PCAF reviews submissions from signatories that have been members long enough to publish their first full annual disclosure
- Progress tracking: The checklist enables year-on-year comparison of disclosure quality as signatories mature their financed emissions programmes
The checklist applies to Part A (Financed Emissions) disclosures only. Separate guidance applies to Part B (Facilitated Emissions) and Part C (Insurance-Associated Emissions) reporting.
Checklist Structure
The DCL is organised into six sections:
| Section | Key Items Covered |
|---|---|
| 1. General Disclosure Criteria | Identity of the reporting entity; boundary definition; reporting period; base year; asset classes included; what is excluded and why; disclosure channel (sustainability report, website, CDP, etc.) |
| 2. Coverage | Percentage of total portfolio covered by outstanding amount; adequacy of coverage for each asset class; explanation of any material exclusions |
| 3. Absolute Emissions | Absolute financed emissions in tCO2e; disaggregation by asset class; Scope 1+2 and Scope 3 separately; data quality scores; emission intensity metrics (recommended) |
| 4. Avoided Emissions and Emission Removals | Optional reporting of attributed avoided emissions and removals; verification of separate reporting from absolute figures; methodology disclosure |
| 5. Recalculation | Whether base year recalculation was required; significance threshold applied; disclosure of the impact of recalculation on the time series |
| 6. Data Quality | Weighted average data quality score by asset class; description of the data sources used for each option; improvement plans and progress |
The Four-Step Signatory Disclosure Process
PCAF has simplified its signatory process as of the 2025 edition. The process for new signatories is:
Step 1: Commit Sign the PCAF commitment letter and publicly list as a PCAF signatory. No emissions disclosure is required at this stage, but the institution commits to beginning measurement within 12 months.
Step 2: Measure Calculate financed emissions for at least one asset class that is material to the institution's portfolio. Publish the first disclosure (which can be partial) within 24 months of signing.
Step 3: Disclose Publish a full annual disclosure (covering all material asset classes) using the DCL as a self-assessment guide. PCAF's review process begins once the institution has published at least one annual report.
Step 4: Improve Demonstrate year-on-year improvement in coverage and data quality. Participate in PCAF's capacity-building programmes and community of practice calls.
PCAF's review is not a mandatory audit or external verification. It is a lightweight checkup by the PCAF Secretariat that provides constructive feedback rather than a compliance ruling. The goal is to support signatories in improving their disclosures, not to penalise early-stage reporters.
Common FAQ Clarifications
Based on the PCAF Disclosure Checklist FAQ document (May 2025), the following points address the most frequent signatory questions:
"Does the DCL review affect our PCAF membership status?" No. The review does not result in removal from the PCAF signatory list. Signatories receive written feedback on areas for improvement.
"Can our financed emissions disclosure be private or confidential?" No. PCAF requires that financed emissions disclosures are made publicly available. The specific disclosure channel (sustainability report, TCFD report, website, CDP submission) is flexible, but public accessibility is mandatory.
"Are we required to have our financed emissions externally verified?" No. External verification is recommended but not required under the current PCAF Standard. Verification status does affect the data quality score (verified data = Score 1a vs unverified = Score 1b).
"If we change our methodology from one year to the next, what must we disclose?" Disclose the nature of the change, the reason for it, and the impact on the current year's financed emissions versus what they would have been under the old methodology. Assess whether base year recalculation is required.
"Do we need to submit the DCL template to PCAF, or just self-assess against it?" The DCL can be used for self-assessment at any time. Formal submission to PCAF is required only when the institution has received an invitation to undergo the review process (typically after publishing at least one full annual disclosure).
DCL self-assessment in practice
A bank preparing its second annual PCAF disclosure uses the DCL to review its Section 3 (Absolute Emissions) compliance:
Required criteria:
- Absolute financed emissions in tCO2e reported
- Disaggregated by asset class
- Scope 1+2 and Scope 3 reported separately
- Data quality score disclosed
- Portfolio coverage percentage disclosed
Recommended:
- WACI disclosed for corporate asset classes
- Portfolio carbon footprint disclosed (not done this year; planned for next year)
- Sector-level breakdown for emission-intensive sectors included
Self-assessment result: 5 of 5 required criteria met; 2 of 3 recommended criteria met. The bank notes the missing portfolio carbon footprint as an improvement target for the next reporting cycle.
Timing and Publication
PCAF expects financial institutions to publish their financed emissions disclosure within the same annual reporting cycle as their financial statements, typically within 6 months of the fiscal year end. The disclosure should be clearly labelled as a PCAF-aligned disclosure and should reference the edition of the Standard used (e.g., "This disclosure was prepared in accordance with the PCAF Global GHG Accounting and Reporting Standard Part A: Financed Emissions, Third Edition, December 2025").
Key Takeaways
- 1The PCAF Disclosure Checklist (DCL) covers six sections: general criteria, coverage, absolute emissions, avoided emissions/removals, recalculation, and data quality
- 2The four-step signatory process is: Commit (sign up), Measure (calculate for at least one material asset class within 24 months), Disclose (publish annually), Improve (demonstrate year-on-year progress)
- 3PCAF's review is a constructive checkup, not a mandatory audit - it provides feedback rather than compliance rulings and does not affect membership status
- 4Financed emissions disclosures must be publicly available - the specific channel (sustainability report, website, CDP) is flexible
- 5External verification is recommended but not required - verification status affects only the data quality score (verified = Score 1a vs unverified = Score 1b)