Civil society as a quasi-regulator: Coordination in financial regulation on climate change

Abstract

As early as 2015, financial regulators were developing disclosure frameworks aimed at enabling capital markets to price climate risks. Yet the literature on sustainability disclosure offers little insight into how regulatory agendas change, instead focusing on how nongovernmental organizations drive voluntary disclosure. To address this deficiency, this paper charts how financial regulators came to embrace climate risk, analyzing how an array of non-state initiatives became coordinated in highlighting climate-related impairment risks. This coordination is conceptualized via scholarship on decentered regulation, allowing a first, theoretical, contribution by constructing and demonstrating one analytical approach to studying substantive change on sustainability. This paper draws on a 25-month participant observation of a United Nations standard-setting project, supported by semi-structured interviews. This allows a second, empirical, contribution by mapping how an accounting device, the so-called “carbon budget” (the maximum amount of cumulative greenhouse gas emissions that limits the probability of exceeding 2°C of warming to 20%), coordinated this array of non-state action toward resolving a core trade-off: if we burn our current fossil fuel reserves, we will exceed our warming targets. The paper then shows how these coordinated efforts pressured regulatory authorities to intervene on how finance affects and is affected by climate change.