Climate disclosure and financed emissions: analyzing ESG regulations, reporting challenges, and comparative data between Brazil and the USA (2020-2024)
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2026-02-04
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Sampaio, Rômulo Silveira da Rocha
Camilo Junior, Ruy Pereira
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This doctoral thesis addresses the following research problem: given the low adoption of reporting on financed emissions (Scope 3, Category 15) by listed commercial banks in Brazil and the United States—where most institutions remain at medium or low levels of reporting between 2020 and 2024—is it possible to increase this level of disclosure through regulatory mechanisms, considering that this scenario generates informational asymmetry between regulators and companies, as well as between companies and investors? From a theoretical standpoint, the thesis argues that Brazil and the United States exhibit similar levels of Scope 3 climate reporting among listed commercial banks, despite having securities markets of significantly different levels of maturity and depth. This convergence at a low level of transparency is detrimental to market efficiency and investor decision making. The central hypothesis is that this structural deficiency can be mitigated through the adoption of targeted regulatory measures, particularly those outlined in the second part of Chapter 5, aimed at enhancing the quality, comparability, and reliability of climate related disclosures. Methodologically, the research is grounded in a comparative empirical analysis conducted in light of recent regulatory developments, particularly CVM Resolution No. 218/2024, which incorporates the ISSB – IFRS S2 standard and requires the disclosure of Scope 3, Category 15 emissions. The study examines a sample of 44 listed commercial banks—Brazilian and American—over the period from 2020 to 2024. A qualitative classification framework was developed to assess disclosure practices, categorizing institutions into three levels: High, Medium, and Low Reporting. This approach enables a systematic evaluation of disclosure maturity across jurisdictions. The findings reveal a persistent lack of transparency among these regulated entities, particularly in contexts where disclosure remains voluntary or weakly enforced. This deficiency negatively impacts regulators, who face constraints in effectively monitoring climate-related risks, and investors, who are deprived of consistent and decision-useful information necessary for rational capital allocation. Despite recent regulatory advancements in both jurisdictions, including the incorporation of climate disclosure standards into domestic frameworks, the overall performance of listed commercial banks remains limited. The conclusions of this research can be summarized as follows: (i) regardless of differences in economic scale and market sophistication, both Brazil and the United States demonstrate low levels of performance in climate disclosure practices; (ii) although some banks report Scope 3 emissions, there is a systematic omission or insufficiency regarding financed emissions (Category 15), which are central to understanding financial sector exposure to climate risks; (iii) this problem is driven by a combination of factors, including the voluntary nature of disclosure regimes, high reporting costs, reputational concerns, and data limitations; and (iv) broader sociopolitical dynamics—such as resistance to ESG agendas and climate related regulation—also contribute to the persistence of low transparency, manifesting similarly across both countries in the discourse of scientists, policymakers, and market participants.