A Study on the Development of a Carbon Accounting Disclosure Framework for the Coal Industry Under the TCFD

Abstract

Against the backdrop of the ongoing advancement of the “dual carbon” goals and the continuous refinement of international sustainable disclosure standards, the coal industry—as a typical high-carbon sector—is facing multiple challenges, including emission reduction constraints, pressure to transition, and revaluation by capital markets. Carbon accounting disclosure is no longer merely an expression of environmental responsibility but is gradually becoming a critical information mechanism linking corporate governance, strategic decision-making, risk management, and the identification of financial impacts.The TCFD framework, centered on the four pillars of governance, strategy, risk management, and metrics and targets, provides a relatively mature international paradigm for corporate climate-related financial disclosure. However, its application in the coal industry still faces issues such as fragmented disclosure content, insufficient quantification, inadequate disclosure of financial impacts, weak connectivity between reports, and insufficient assurance support.Given the coal industry’s characteristics of high emissions, high sunk costs, and long-term investment cycles, this paper, based on a review of relevant research and practical realities, proposes that the carbon accounting disclosure system for the coal industry should be structured around seven key areas: governance mechanisms, strategic responses, risk management, metrics and targets, financial impacts, connectivity, and assurance support. Furthermore, it outlines an implementation pathway that combines phased implementation with data governance and external oversight.The study argues that carbon disclosure in the coal industry should shift from “compliance-oriented disclosure” to “decision-useful disclosure.” By enhancing disclosure quality through standardization, quantification, forward-looking perspectives, and verifiability, this approach will support corporate low-carbon transitions and regulatory governance.