The Task Force on Climate-related Financial Disclosures (TCFD) requires organisations to report how they manage climate risks and opportunities. Accountants play a key role in verifying these disclosures, particularly around governance. This involves ensuring board oversight and management’s role are accurately documented and audit-ready. Without proper verification, organisations risk regulatory, legal, and reputational challenges.

Key Steps for Verification:

• Set up a framework: Define what to verify, gather evidence (e.g., board minutes, management reports), and create clear procedures.

• Review board oversight: Check meeting minutes, training records, and strategic plans to confirm active involvement in climate governance.

• Examine management’s role: Validate processes for identifying and addressing risks, and assess reporting systems for accuracy.

• Ensure quality disclosures: Statements must be specific, consistent, and comparable, supported by strong evidence.

• Prepare for audits: Organise documentation systematically to meet assurance requirements.

Using tools like Neoeco can streamline this process, offering centralised file management and audit-ready controls. By focusing on clear evidence and precise disclosures, accountants help build trust and meet evolving regulatory demands.

Perspectives series: The state of assurance for sustainability disclosure

Step 1: Set Up a Governance Verification Framework

The first step in aligning with TCFD requirements is to establish a verification framework. This framework acts as the backbone of your verification process, ensuring consistency and readiness for audits. It defines what needs to be verified, the evidence required, and how findings should be documented. A well-structured framework not only simplifies the process but also ensures your audit records are thorough and defensible.

You don’t need to overcomplicate things. Focus on three main components: defining the scope of verification, identifying the necessary documentation, and setting up clear, actionable procedures. These steps build a system that can be applied consistently across various clients and reporting cycles.

Define What Needs to Be Verified

Start by pinpointing the governance elements that require verification. TCFD governance disclosures usually focus on two key areas: board oversight and management’s role in climate-related governance. Your framework should systematically address both.

Here are some specific elements to focus on:

• Board oversight: Assess how frequently climate issues are discussed at the board level, identify which committees are responsible for climate governance, and evaluate how climate considerations influence strategic decisions.

• Management’s role: Examine the organisational structure for climate governance, reporting lines between operational teams and the board, and the processes in place for identifying and addressing climate risks.

A simple checklist can help track the verification status of these elements. Mark each item as complete, missing, or ready for review. This approach not only provides a clear snapshot of progress but also highlights any gaps that need attention before they become major issues.

Additionally, the checklist is a valuable communication tool. When discussing progress with clients or presenting findings to boards, you can quickly show which governance elements have been verified and which require further work. This transparency builds trust in your assurance process.

Determine Required Documentation

Once you’ve outlined what needs to be verified, identify the specific documents that will serve as evidence for each disclosure. Different governance disclosures require different types of supporting materials.

For board oversight, you might need:

• Board minutes detailing climate-related discussions

• Committee terms of reference that outline climate responsibilities

• Board papers showing how climate information is presented to decision-makers

For management’s role, examples of necessary documentation include:

• Organisational charts illustrating climate governance structures

• Job descriptions for roles with climate-related responsibilities

• Management reports tracking climate risks and responses

To keep everything organised, create a centralised repository for all compliance files. Use clear naming conventions and version control to ensure documents are easy to locate. This hub should allow you to quickly provide evidence when auditors request it. A master list of required documents, paired with the actual files, helps you identify and address any missing evidence early in the process.

Using sustainability accounting platforms can simplify this step. Tools like neoeco (https://neo.eco) integrate with financial systems, making it easier to trace and verify the financial impacts of governance decisions. For firms handling multiple clients, centralising documentation is a game-changer for maintaining efficiency and consistency.

Create Verification Procedures

With your scope defined and documentation identified, the next step is to develop practical procedures for conducting verification. These procedures should be standardised across your firm but flexible enough to adapt to different client needs.

For example, when verifying board oversight, your procedures might include:

• Reviewing board minutes from the past year

• Comparing committee terms of reference with their actual activities

• Ensuring climate issues are integrated into strategic planning

For management roles, steps might involve interviewing key personnel, reviewing reporting templates, and mapping how information flows from operational teams to the board.

Consistency is key. Standardised procedures ensure that your team works uniformly across reporting cycles, which strengthens your position during external assurance reviews. Templates or policy-building tools can help you align these procedures with TCFD requirements and industry standards, saving time and effort when working with multiple clients.

Your procedures should also specify what evidence needs to be retained, how findings should be recorded, and when to escalate issues to senior reviewers. This level of detail transforms the verification process into a structured, audit-ready system.

As regulations evolve, including those related to ISSB reporting, robust verification procedures will help your firm adapt quickly to new requirements. The framework you establish today can also support expanded assurance services in the future.

Finally, include quality control checkpoints in your procedures. Regular reviews of completed work can highlight areas for improvement, whether through refining processes or additional training. This ensures your framework stays effective and up-to-date as client needs and regulatory expectations change.

With your verification framework in place, you’re ready to dive into the details of verifying board oversight disclosures in the next step.

Step 2: Verify Board Oversight Disclosures

Once your verification framework is in place, the next step is to ensure that board oversight disclosures genuinely reflect how climate-related issues are managed at the highest level. This means going beyond surface-level claims and digging into the actual processes boards use to fulfil their oversight responsibilities.

Board oversight disclosures are closely examined during assurance reviews because they showcase accountability. Stakeholders, including auditors, want to see that climate governance is more than just ticking a box - it must be a real part of strategic decision-making. As an accountant, your job is to confirm that the disclosures align with the board's actual activities.

This process focuses on two main areas: how boards oversee climate-related matters and the roles assigned to board committees. Both require a thorough review of documentation and a solid understanding of what effective oversight looks like under TCFD principles.

Review Board Oversight Mechanisms

Start by reviewing board meeting minutes to confirm active involvement in climate discussions. TCFD guidance expects boards to engage deeply, not just acknowledge climate issues. Look at the minutes from the past year and check for detailed discussions, decisions, questions, or directives related to climate matters. Vague or superficial mentions don’t cut it - you need proof of meaningful engagement. If the records lack this detail, flag it as a gap that needs addressing before the assurance process begins.

Next, assess board papers and information packs. These documents reveal what kind of information the board receives to guide their oversight. Check if climate data is regularly presented, integrated into strategic documents, or treated as standalone reports. Strong oversight includes climate data tied to financial metrics and forward-looking risk assessments.

Another area to examine is board training records. While TCFD doesn’t mandate climate training for boards, it’s increasingly seen as good practice. Review training logs for details on topics covered, dates, and which members participated. This helps demonstrate that the board is staying informed on evolving climate challenges.

Also, look at strategic planning documents to see how climate considerations are embedded in the organisation’s long-term plans. If board minutes show approval of climate-integrated strategies, that’s strong evidence of oversight. However, if climate issues are absent from strategic documents, it raises questions about the board’s effectiveness in this area.

Consistency is key. If a company claims its board reviews climate matters quarterly, there should be documentation to back this up. Any inconsistency between disclosures and actual records needs to be investigated and resolved.

Centralised platforms for storing compliance files can simplify this process, ensuring everything is audit-ready. As Jennifer Kaplan, Sustainability Manager, explains:

"I found the Policy Builder extremely useful at our stage because having a template of a well-conceived policy helps in the standardisation of new practices and ensure that written guidelines are best-in-class."

Once you’ve verified the overall board practices, shift your focus to the specific roles of dedicated committees.

Check Board Committee Roles

In many organisations, climate oversight is delegated to specific committees, such as audit, risk, or sustainability committees. Your task is to confirm that these committees have clear mandates, are fulfilling their responsibilities, and that their actions align with disclosed practices.

Start by reviewing committee terms of reference. Check whether climate governance is explicitly included, with responsibilities such as "quarterly reviews of climate risk assessments" or "monitoring progress against emissions targets."

Then, examine committee meeting minutes from the past year. Look for evidence of regular discussions on climate risks, emerging challenges, and risk mitigation strategies. If the minutes show only occasional or shallow engagement, it suggests a gap between what’s disclosed and what’s actually happening.

Verify reporting lines between committees and the full board. TCFD expects information to flow effectively from committees to the board. Check whether committee chairs report on climate matters during board meetings and whether these updates are documented.

Another important check is committee composition. Review membership lists and any disclosed qualifications of committee members. If a company highlights specific expertise, ensure those individuals are indeed part of the relevant committees.

Look at committee work plans or agendas to see if climate matters are proactively scheduled for review. This demonstrates forward-thinking governance rather than reactive measures. Document all instances where the evidence aligns with TCFD requirements.

In cases where multiple committees share responsibility for climate oversight, ensure their roles are clearly defined to avoid confusion. For instance, one committee might handle climate risk while another focuses on strategy. Both are valid approaches, but the division of responsibilities must be clear in the documentation and disclosures.

Using sustainability accounting tools can make managing and verifying committee documentation easier. Platforms with audit-ready controls help ensure all governance files are complete and up-to-date. As one platform notes:

"Policy and evidence hub. Store all your compliance files safely so you're always ready for audit."

Finally, check that committee activities align with broader governance frameworks, such as ISSB reporting. As reporting standards evolve, the role of committees in overseeing sustainability will only grow. Verifying that current practices meet TCFD requirements will help position your clients for future regulatory changes.

Step 3: Verify Management Role Disclosures

Once you've confirmed board oversight, the next step is to ensure that management is embedding climate governance into daily operations. This goes beyond high-level oversight and focuses on how management handles climate-related responsibilities in practice. Under the TCFD framework, disclosures should show that climate risks and opportunities are actively monitored, assessed, and factored into business decisions. As an accountant, your job is to ensure these disclosures reflect actual processes, not just ambitions. This involves two main tasks: verifying the implementation of management processes and assessing the accuracy of monitoring and reporting systems.

Validate Management Processes

Start by examining how management identifies and evaluates climate risks through its risk assessment processes. Look for evidence that scenario analysis outputs are properly documented and integrated into business planning. Ensure that sustainability accounting tools, particularly those tied to financial systems, produce reliable climate-related data.

Once you're confident in the management processes, shift your attention to the systems monitoring and reporting this data. These systems should provide real-time, audit-ready insights.

Check Monitoring and Reporting Systems

Effective monitoring systems are essential for tracking climate-related performance. Check that these systems capture accurate data, provide live dashboards, and include features like audit-ready controls, secure policy hubs, and checklist functions. They should also support reporting under frameworks such as GHGP, SECR, UK SRS, and ISSB.

One key feature to look for is "smart matching", which automatically maps transactions to emissions categories under frameworks like GHGP or ISO 14064. This reduces manual errors and ensures consistent reporting.

Additionally, review whether reporting workflows are designed to streamline the communication of validated climate data. Systems should enable direct auditor access and align with third-party standards. Assess how well information flows from operational teams to management and the board, and ensure that robust data validation procedures are in place.

Document all instances where these systems meet TCFD requirements, and identify areas needing improvement. Reliable monitoring and reporting systems do more than ensure compliance - they prepare organisations to adapt to changing standards. For companies with intricate supply chains, these systems are especially critical for tracking Scope 3 emissions and accounting for indirect impacts.

Step 4: Evaluate Disclosure Quality Against TCFD Principles

To ensure your disclosures align with TCFD standards, they should meet key criteria: specificity, relevance, consistency, and comparability. The goal is to move beyond generic statements and provide an accurate reflection of the organisation's climate governance practices.

Check for Specificity and Relevance

Vague statements like "the board oversees climate risks" fall short of TCFD expectations. Instead, disclosures should include concrete details about governance operations, supported by verifiable organisational data. This is where sustainability accounting tools can be incredibly helpful. Platforms that integrate financial and sustainability data make it easier to produce disclosures that are both specific and relevant.

For example, neoeco (https://neo.eco), a platform tailored for accounting firms in the UK and Australia, simplifies this process. It automatically maps transactions to recognised emissions categories and generates audit-ready reports. This ensures disclosures are grounded in real, traceable data and align with governance standards.

Standardised documentation also plays a vital role. It helps external stakeholders clearly understand the organisation's climate governance approach. As Jennifer Kaplan, a Sustainability Manager, explained:

"I found the Policy Builder extremely useful at our stage because having a template of a well-conceived policy helps in the standardisation of new practices and ensures that written guidelines are best-in-class".

By maintaining thorough documentation and audit-ready controls, organisations can ensure their disclosures are transparent and verifiable. Once specificity and relevance are addressed, the next step is to evaluate consistency and comparability.

Verify Consistency and Comparability

Disclosures should not only be detailed but also consistent over time and comparable with those of peer organisations. Consistency means using the same metrics, definitions, and reporting boundaries across reporting periods, while comparability ensures stakeholders can assess governance practices against industry standards.

Review current disclosures alongside those from previous periods to confirm that any changes in governance roles or methodologies are clearly explained. Tools with built-in policy hubs, like sustainability accounting platforms, can help store and organise compliance files, ensuring data remains up-to-date and verified.

For comparability, consider whether an investor could reasonably benchmark the organisation's governance approach against its peers. If the format or terminology deviates without explanation, this could signal a need for improvement.

Focusing on these quality measures strengthens the evidence trail required for third-party assurance, ensuring disclosures meet the high standards expected by stakeholders.

Step 5: Document Evidence and Prepare for Audit

As you progress through the verification process, maintaining thorough and accurate documentation is critical. Properly organised evidence can mean the difference between meeting governance requirements and falling short under regulatory scrutiny. When assurance providers or regulators ask for proof, you need to deliver it promptly, clearly, and in a format that’s ready for audit. This calls for a systematic approach to managing your evidence.

Build an Audit-Ready Evidence Trail

Start by identifying all the evidence that supports your governance disclosures. Documents like board minutes, committee charters, and risk registers should be organised both chronologically and by governance theme. This makes it easier to trace decisions and actions over time.

Every document should be dated, version-controlled, and stored securely. For instance, if your board reviews climate risks quarterly, the meeting minutes should clearly outline the topics discussed, decisions made, and any follow-up actions. Auditors need to see specific, verifiable details.

To make document retrieval effortless, establish consistent naming conventions. A file labelled "Board_Climate_Review_Q3_2025.pdf" is far more useful than something vague like "Meeting_Notes_Sept.pdf". Consistency in naming not only saves time during audits but also ensures clarity.

This structured organisation of evidence sets the stage for leveraging technology to streamline documentation management.

Leverage Technology for Document Management

As compliance demands grow, relying on manual methods like spreadsheets or shared drives can lead to version control problems and security risks. These methods often fall short when it comes to providing a systematic way to grant auditors access.

A tool like Neoeco (https://neo.eco) is specifically designed for accounting firms in the UK and Australia. Neoeco's Policy & Evidence Hub centralises file management, offering audit-ready controls. It acts as a live checklist, helping you track which documents are complete, missing, or ready for review. Additionally, it provides auditors with secure, straightforward access to the necessary files. Built on a fully SOC 2 and GDPR-compliant system, Neoeco can also integrate with financial tools like Xero, Sage, and QuickBooks, aligning with the principles of Financially-integrated Sustainability Management.

By using technology like Neoeco, you can ensure your documentation process meets the precision and timeliness required throughout the verification process.

Get Ready for Third-Party Assurance

Once your evidence is well-organised, you’re better prepared for external validation. Third-party assurance providers don’t just check for the existence of documents - they evaluate whether your governance processes are genuinely embedded in your operations.

Compile a comprehensive evidence pack that maps directly to your TCFD disclosures. Review it internally to identify and resolve any gaps or inconsistencies. For example, if you’ve disclosed that the board receives quarterly updates on climate risks, include both the updates and the meeting minutes where they were discussed. Providing context is key - pairing a committee charter with evidence of its actual operations (such as meeting schedules, attendance records, and decisions made) shows that governance processes are active and effective.

Finally, ensure your documentation system allows you to produce evidence quickly when requested. Assurance engagements often operate on tight deadlines, and delays in providing materials can lead to higher costs and extended timelines. Systems like Neoeco, with features like instant trust sharing, enable you to provide up-to-date, verified documentation on demand - giving you a clear edge when working with external reviewers.

Conclusion

Establishing a solid framework is the cornerstone of effective TCFD governance verification. This means clearly defining the scope, gathering credible evidence, and standardising procedures. But beyond the framework, the way you present your disclosures carries immense weight.

Disclosures need to be specific and consistent. Detail concrete actions like board minutes that document climate risk discussions, well-defined committee charters, and proactive management reports. Importantly, back every disclosure with evidence that can stand up to scrutiny.

Technology plays a vital role here. neoeco (https://neo.eco) simplifies this process by integrating with financial systems like Xero, Sage, and QuickBooks. It aligns data effortlessly and ensures your compliance documentation is audit-ready. Its Policy & Evidence Hub centralises all relevant materials, helping you track progress, identify gaps, and prepare for reviews with ease.

Once your processes are streamlined, the focus shifts to external assurance. Assemble evidence packs that directly align with your disclosures, allowing auditors to access the information quickly through automated systems. Auditors will assess whether governance processes are actively embedded in your operations - not just written into policies.

FAQs

How does the TCFD framework promote effective board oversight of climate-related issues within organisations?

The TCFD framework promotes strong board oversight on climate-related matters by pushing organisations to weave climate risks and opportunities into their governance processes. It places the responsibility on boards to evaluate and manage these risks, ensuring they align with the organisation's broader strategy and financial goals.

A major focus is on transparency. Organisations are encouraged to disclose the board's role in overseeing climate-related risks and opportunities. Additionally, they should explain how management identifies, evaluates, and addresses these issues. This openness not only builds stakeholder trust but also highlights accountability in tackling climate challenges.

How can sustainability accounting tools like Neoeco simplify the verification of TCFD governance disclosures?

Neoeco streamlines the verification of TCFD governance disclosures by providing finance-grade, audit-ready reports that seamlessly connect with your clients’ financial data. Forget about tedious manual tasks like juggling spreadsheets or converting data - Neoeco ensures precision and compliance with established frameworks such as GHGP, ISO 14064, and UK-specific standards like SECR and SRS.

Through automated transaction mapping to emissions categories, Neoeco enables accounting firms to produce dependable governance disclosures quickly and efficiently. This not only saves valuable time but also boosts trust in compliance and audit preparedness.

What challenges do organisations face when preparing governance disclosures for TCFD assurance?

Organisations face multiple hurdles when preparing governance disclosures for external assurance under the TCFD guidelines. One major issue is ensuring that governance structures and processes are well-documented and meet TCFD's criteria. This includes showing clear board-level oversight and defining management's role in handling climate-related risks and opportunities.

Another significant challenge is maintaining consistency and accuracy in reporting, especially when integrating climate governance into existing financial and operational systems. Data availability and quality can also pose problems, alongside the need to adhere to relevant standards and frameworks.

Tools like neoeco can simplify this process. By directly integrating with financial systems, it provides precise, audit-ready data while ensuring alignment with recognised frameworks such as GHGP and ISO 14064. This not only reduces manual work but also improves the reliability of disclosures, making assurance efforts smoother and more effective.

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