Corporate conduct, climate action and market regulation: An analysis of the scope and impact of newly enacted, TCFD aligned, corporate reporting obligations

The Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Act was introduced into the Federal Parliament in 2024 and came into effect in 2025. The Act imposes positive disclosure obligations on corporations relating to climate change resilience. These
obligations are consistent with those developed by the Task Force on Climate-related Financial Disclosures (‘TCFD’) reporting framework, which is an international organisation. This article evaluates the impact of the newly enacted Act. To do so, it first outlines the TCFD framework and analyses public reports by the Big 4 Australian banks (ANZ, CBA, NAB and Westpac) as illustrations of its practical implementation. Second, the article outlines the new Act and analyses its contribution to the climate action transparency space in Australia. Finally, the article draws conclusions about the anticipated capacity of the new Act to enable corporate stakeholders to make informed decisions about a corporation’s climate change performance.