Disclosure focus
The practical focus is on the breadth and usefulness of the response, not just on a few headline projects. Organisations should think about whether their actions cover the full business where relevant, including operations, supply chains, sites, and other material parts of the business, rather than only flagship locations or isolated initiatives. The aim is to show how risk reduction and adaptation are being embedded in the organisation’s overall approach.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official CARB source.
Prepare
What to collect before drafting
Tick each field as the evidence lands. Owners are the teams that usually hold the source files.
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Adaptation actions
Risk management / SustainabilityRecord the actions the business has put in place to adjust to climate-related financial risk.
Evidence Board papers, risk register updates, adaptation plan, project tracker, or approved management actions.
Watch for The list is built from general resilience work and does not reconcile to the climate risk register or approved mitigation plan.
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Effectiveness view
Risk management / FinanceCapture the expected result of each action: what change it should deliver and how that expectation was formed.
Evidence Business case, scenario analysis, risk assessment, or management memo setting out the expected outcome.
Watch for The stated effect is a vague aspiration and does not tie back to the specific measure or the underlying risk assessment.
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Accountable owner
Risk management / GovernanceIdentify the person or function responsible for overseeing each risk response measure.
Evidence RACI, committee terms of reference, delegated authority schedule, or risk ownership matrix.
Watch for The named owner does not match the risk register or committee accountability, so responsibility is assigned to the wrong function.
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Delivery stage
Project management / Risk managementState whether each measure is planned, underway, completed, paused, or otherwise at its current stage.
Evidence Project status report, implementation tracker, steering committee pack, or milestone log.
Watch for The status is taken from an outdated tracker and the measure is reported as complete when delivery is still in progress.
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Funding set aside
FinanceCapture the amount of money set aside for each risk response measure, in USD, for the reporting period.
Evidence Budget approval, capex/opex plan, forecast, ledger extract, or funding request.
Watch for The amount is pulled from a project budget that does not reconcile to the finance ledger, or mixes committed spend with approved funding.
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Risk reduction actions
Risk management / SustainabilityRecord the actions the business has put in place to lower climate-related financial risk.
Evidence Risk treatment plan, board papers, control register, or approved management actions.
Watch for The measure is described as a general sustainability initiative rather than a specific action linked to the climate risk it is meant to reduce.
Before you start
- Which actions are you counting here: only the steps already in place, or also planned work that has not started yet?
- For the money figure, have you fixed the period and basis you will use, and is it in USD?
- Can each measure and the amount behind it be traced back to a source document or owner record?
- Who in the organisation is the named owner for these risk measures, and is that person or group settled before drafting?
- Have you agreed how you will judge whether the measures are working, and what evidence you will use for that judgement?
- Are you separating actions that cut the risk from actions that help the business adjust to it, or treating them as one set?
How to prepare it
Request the data
Request the climate risk mitigation and adaptation evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What actions are in place to reduce and adapt to climate-related financial risk, who owns them, how far along are they, what resources support them, and how effective are they expected to be?
Use your organisation’s own terms first, then map them to the disclosure language. For example, if you talk about business continuity, site resilience, asset hardening, or transition planning internally, use those labels in the request and only translate them afterwards for reporting.
Weak request
Please provide the measures adopted to adapt to climate-related financial risk, the expected effectiveness, governance owner, implementation status, and resources allocated.
Why it fails: It uses framework language that may not match how the business tracks work, so the owner may not know which projects, budgets, or approvals to pull. It also does not say which part of the business, which period, or which source records to use.
Better request
Please send the current list of resilience, continuity, and risk-reduction actions for [business unit/site/portfolio] for [period], including the owner for each action, whether it is planned or already under way, the budget or spend attached to it, and a short note on how well it is expected to work. Use your normal project names and attach the source file or system reference.
Formal email template
Subject: Request for climate risk mitigation and adaptation evidence for [reporting period] Dear [name/team], We are preparing the climate-related risk section for [reporting period] and need your help to gather the evidence for the actions already in place, the actions being delivered, and the support behind them. Please send, for [business unit / site / portfolio], the following in your own internal wording where possible: - the measures currently in place or underway to reduce exposure to climate-related financial risk; - the measures used to adapt operations, assets, or plans to climate-related financial risk; - who owns or oversees each measure; - the current delivery status of each measure; - the resources set aside or spent on each measure; and - your view of how effective each measure is expected to be. Please include the source document or system for each item, the period covered, and any approval or governance reference. If you use different internal labels, please keep those and add a short mapping note so we can translate them for reporting. A possible LRA training template is attached below. Please adapt this to your organisation and check the source material before sign-off. Many thanks, [preparer name] [team] [contact details]
Short Teams / Slack version
Hi [name] — could you share the evidence for the climate risk actions in [business unit/site/portfolio] for [period]? We need: what’s in place, who owns it, current status, budget/spend, and how effective it’s expected to be. Please use your normal internal labels and add the source link or file name. A possible LRA training template is attached below. Please adapt this to your organisation and check the source material before sign-off. Thanks.
Industry examples
Manufacturing
Context. A plant team tracks flood barriers, backup power, and heat controls in a maintenance and capital project log.
Adapted request. Please share the plant-level resilience and continuity actions for [site] in [period], including the project name, engineering owner, delivery status, approved spend, and the expected impact on downtime and asset protection. Use the names from the maintenance and capital tracker.
Example response. Returned table includes: project name, site, owner, status, approved budget (USD), spend to date (USD), expected impact, source record, and sign-off reference.
Financial services
Context. A risk team tracks branch continuity, data-centre resilience, and supplier continuity in the enterprise risk register and business continuity plans.
Adapted request. Please provide the current risk-reduction and resilience actions for [business unit] in [period], with the risk owner, committee oversight, implementation status, allocated budget, and a short note on expected effectiveness. Please use the risk register and continuity plan labels already in use.
Example response. Returned table includes: control or project name, risk category, owner, committee, status, budget (USD), expected effectiveness note, source register entry, and review date.
Draft your disclosure
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
Describe how the company defined the climate-related financial risk actions, how it distinguished steps to limit exposure from steps to adapt, and what basis it used to judge progress, ownership, resources, and expected effectiveness.
Context note
Explain what the figures show about the company’s readiness to manage climate-related financial risk, including which actions are in place, who is accountable, how far implementation has progressed, and how much support has been committed.
Fluctuation statement
If the numbers changed from the prior period, note whether that reflects new actions added, measures completed, changes in assigned responsibility, revised resource levels, or a different view of how effective the actions are likely to be.
Content index entry
SB261-RISK-MITIGATION-ADAPTATION Measures to reduce and adapt to climate-related financial risk — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for SB261-RISK-MITIGATION-ADAPTATION with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We mapped the disclosed measures to the specific climate-risk issues we said we were addressing, and we limited the coverage to the parts of the business included in the report.
Risk Assurer checks whether the coverage is complete, whether any relevant operations, sites or activities were left out, and whether the scope matches the basis used elsewhere in the report.
Evidence to check Scope memo; list of included entities, sites and activities; boundary-setting paper; cross-check to the report’s defined perimeter; sign-off showing the same scope was used consistently.
For each measure, we kept a short note on what it is meant to do, so the reader can see how it is intended to lower exposure or help the business adjust.
Risk Assurer probes whether the description is specific enough, whether the measure really relates to the stated risk, and whether the wording overstates what the action can achieve.
Evidence to check Measure register; project briefs; risk-to-action mapping; management papers explaining the intended purpose; review notes showing the description was checked against source documents.
Where we said a measure was already in place, we had evidence that it had moved beyond planning and into delivery or operation.
Risk Assurer checks whether implementation status is accurate, current and supported, and whether any item described as live is still only planned, approved or partially started.
Evidence to check Project status reports; implementation tracker; approvals; completion certificates; meeting minutes; dated evidence of launch or operation; version history showing the status was updated before publication.
We named the person or function responsible for each measure and used internal records to confirm who was accountable for delivery.
Risk Assurer probes whether the named owner is real, current and appropriately senior, and whether accountability is clear where more than one team is involved.
Evidence to check RACI or ownership matrix; org chart; committee terms of reference; appointment emails or minutes; role descriptions; evidence of escalation routes and oversight.
We set out the budget or other resources linked to the measures using the same currency basis throughout, and we checked the figures against finance records before release.
Risk Assurer checks whether the amounts are complete, correctly converted to USD where needed, and tied to the right period and project set; they also test whether any shared costs or assumptions were handled consistently.
Evidence to check Finance extracts; budget approvals; cost centre reports; currency conversion workings; allocation methodology; reconciliation to ledger or management accounts; review and approval evidence.
Before publication, we carried out a final consistency check so the narrative, the status of the measures and the amounts disclosed all matched the underlying files.
Risk Assurer probes whether the final pack is internally consistent, whether there are contradictions between sections, and whether the published wording is supported by the working papers.
Evidence to check Final disclosure pack; review checklist; legal/compliance or sustainability review comments; redline changes; sign-off sheet; evidence of issue resolution and final approval.
Evidence pack to prepare
Common reporting gaps
- Figures are stated without the supporting narrative, or narrative without figures.
- Scope is inconsistent between the text and the numbers.
- The reporting boundary is left undefined.
- Material changes since the previous period are not disclosed.
- Estimates and measured values are not distinguished.
- Source records for the figures are not identified.
Where drafts go wrong
Mistakes to avoid and where judgement is needed
The left column is what preparers get wrong while collecting; the right column is where you will have to make and explain a judgement.
Mistakes to avoid
- Wrong owner askedThe request goes to a policy team or sustainability lead when the person who actually tracks the controls, budget, or delivery status is elsewhere in the business.
- Framework language usedThe data call is sent in disclosure jargon, so teams cannot map it to their own project names, risk registers, or operational workstreams.
- Scope left vagueNo one states which business units, assets, or activities are in scope, so different teams send different slices of the same topic.
- Timing basis not fixedPeople pull figures from different cut-off dates or reporting periods, which makes the set of answers internally inconsistent.
- Counting basis mixedOne source reports spend, another reports commitments or forecasts, and the final pack blends them without separating the basis used.
- Source labels strippedOriginal file names, system tags, or document references are removed, so the team cannot trace each figure back to where it came from.
- Separate groups mergedMeasures for different sites, regions, or risk types are rolled into one total even though they should stay distinct for review.
- Evidence trail missingThe pack contains the numbers but not the supporting notes, version history, or sign-off record needed to show who checked them.
Judgement needed
- Acquisition or disposal changes the reporting perimeterSet out whether the measures list and spend cover the business as it stood at period end or are adjusted for bought or sold operations, and explain the basis used if the perimeter moved during the year.
- Different country labels for the same controlIf the same action is described differently across locations, map those local labels to one group-wide description and note any country-specific differences that affect how the measure works.
- Units at the edge of the scopeDecide whether to include partially owned, newly launched, dormant, or outsourced activities where they materially affect the risk response, and explain the inclusion rule used.
- Current-year spend versus committed spendState whether the resource figure reflects cash spent, amounts committed, or both, and make clear the cut-off date used for the figure.
- Estimated benefit versus measured outcomeWhere the effect of a measure is not yet observed, describe it as an estimate, say what evidence supports it, and separate it from results that have been measured in practice.
- One measure, several risk typesIf a single action helps with more than one climate-related financial risk, explain how you avoided double counting and how you assigned the measure in your narrative.
- Rounding of resource figuresApply one rounding approach across the disclosure, disclose the basis if it changes the reported total, and keep the narrative aligned with the rounded figure.
- Privacy limits on location-level detailWhen local detail cannot be shown because of data protection or confidentiality, group the information at a higher level and say that the aggregation is due to privacy limits.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We have put in place a programme to cut and manage climate-related financial exposure through flood defences at two sites, heat-resilient equipment upgrades, and a supplier continuity plan; these actions are led by the risk committee, with day-to-day delivery owned by the chief risk officer. Of the £12.0 million set aside for this work, £7.2 million is already committed and £4.8 million remains available, and we expect the package to lower our near-term loss exposure by about 35% once fully rolled out.
- The main actions are already under way, with site works 60% complete and supplier planning complete.
- We judge the measures to be moderately to highly effective because they address the largest weather-related loss drivers in our operations and logistics network.
Synthetic illustration only; shows how a reporter might describe actions taken to both limit and adapt to climate-linked financial exposure, who owns delivery, how far implementation has progressed, what resources are assigned, and the expected level of benefit.
Our group has introduced portfolio screening, client transition support, and branch resilience upgrades to reduce and adapt to climate-related financial exposure; oversight sits with the board risk committee, while the chief sustainability officer coordinates implementation across business lines. We have allocated €3.5 million in total, of which €1.4 million has been spent and €2.1 million is reserved for the next 18 months, and we expect the measures to reduce the relevant exposure by roughly 28% once the remaining work is finished.
- Implementation is partly complete: portfolio screening is live, client support is in pilot, and branch upgrades are 40% complete.
- On current plans, the measures should be effective at lowering the most material weather- and transition-linked losses, though the full benefit depends on completion of the remaining actions.
Synthetic illustration only; shows a different sector using plain language to describe mitigation and adaptation actions, governance ownership, delivery status, budgeted resources, and expected effectiveness.
Quality ladder
- Basic
We allocated USD 250,000 to climate-risk actions.
- Better
We allocated USD 250,000 to flood-proofing, supplier checks and site cooling, with the finance team overseeing delivery and the work now under way.
- Best
We allocated USD 250,000 this year to flood-proofing, supplier checks and site cooling across our main sites, with the finance team overseeing delivery; we expect these steps to cut disruption and insurance pressure, and the budget rose from last year because we added two higher-risk locations.
Check your understanding
Scenarios to work through
A finance team has approved a flood barrier upgrade for one warehouse and a heat-resilience plan for a distribution hub. The project note says the work is partly complete, but no one has named who oversees delivery or whether the budget is enough.
A risk committee has agreed to relocate some critical stock away from a coastal site and to add backup power at another facility. Management believes these steps will help, but there is no formal assessment yet showing how much risk reduction they are expected to deliver.
A group has split responsibilities between the sustainability lead, the operations director, and the audit committee for different climate-risk actions. The team is unsure whether to name one person, several people, or the committee structure in the disclosure.
A company has set aside USD 2.4 million for drought planning, equipment hardening, and staff training. Two of the projects are already underway, while the training programme is scheduled for next quarter, and the team is unsure how to present the mix of completed and planned work.
Real reports
How 3 companies report it
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
CSX Corporation
Ingersoll Rand Inc.
Cargill
| Field | CSX Corporation | Ingersoll Rand Inc. | Cargill |
|---|---|---|---|
| Adaptation actions | Not found | Not found | Not found |
| Effectiveness view | Not found | Not found | Not found |
| Accountable owner | Partial | Partial | Not found |
| Delivery stage | Not found | Not found | Not found |
| Funding set aside | Not found | Partial | Not found |
| Risk reduction actions | Not found | Not found | Not found |
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Advice, not assurance
Framework references
Relevant California requirements and related disclosures
California
SB261-RISK-MITIGATION-ADAPTATION
within California SB 261: Climate-Related Financial Risk Act
Related & explore
More in California SB 261 →Browse full catalogue →Search all disclosures →
FAQ
Questions this page answers
The page says to prepare six datapoints: adaptation actions, an effectiveness view, an accountable owner, delivery stage, funding set aside, and risk reduction actions. Use those as the starting checklist before you draft anything.
Use it as a practical sequence for getting from raw inputs to a draft disclosure. The page is designed to help you organise the work, rather than just describe the topic in theory.
The page includes an evidence pack with five items to support assurance readiness. Build your pack around those items so you can show where the disclosure data came from and how it was checked.
The page says there are six assurance claims to verify, each framed around claim, risk and evidence. Use that structure to test whether the disclosure is supported and whether the evidence is complete enough for review.
The page lists common reporting gaps and mistakes to help you avoid weak or incomplete drafting. Check those before sign-off so you do not miss a required datapoint or leave the narrative too vague.
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the datapoints, track evidence, and prepare the disclosure in a way that is easier to review.
The Download Centre includes a printable Library Card in .pdf format. It is there as a practical companion to the page content, so you can keep the disclosure checklist and key prompts to hand while drafting.
The page includes draft-output support with visualisation ideas, narrative starters and a content-index line. Use those to turn your prepared datapoints into a clear first draft rather than starting from a blank page.
The page includes synthetic illustrative example disclosures, including a quantitative data table. Use them as a formatting and drafting guide only, not as a template for real-world values.
The page notes ESRS E1 (Climate Change) as the closest correspondence, so some data may be reusable. Treat that as a practical cross-reference, not as proof that the disclosure requirements are identical.
More questions this page can help with