Climate disclosure rules ask how much you're spending to adapt, not just how exposed you are. Far fewer reporters answer the second question.
Most of the attention on a climate risk disclosure lands on one number: how much of your asset base sits in a hazard zone. That's the exposure figure, and it's the part everyone braces for.
The rule quietly asks for a second number that gets far less airtime: how much capital you're actually putting toward reducing that exposure. Resilience spending. Flood defences, storm-rated roofing and cladding, cooling and backup power for heat, raising critical equipment above flood level. (There's a transition and opportunity side too, but the physical-resilience piece is the one that ties straight back to hazard exposure.)
Here's the odd part. The exposure question has a clear home in the standard. The spending question is required everywhere but explained almost nowhere. The provisions that let you off certain details stop just short of it, and the general guidance points you at boilerplate. So a lot of reporters disclose the exposure and go quiet on the spend.
Why is the spend number hard? Because you can't report it credibly without a defensible base underneath it. A resilience spend figure only means something against the exposure it's reducing: which sites, to which hazard, and how much value sits behind them. It has to tie to real locations and reconcile back to the financial statements. Without that base, "we're investing in resilience" is a sentence, not a number.
One limit worth naming: flood damage is the part you can put in dollars today, using published damage curves. Wind, wildfire and drought are still exposure ratings rather than dollar figures, across the whole industry, not just us. And any single-model projection carries scenario uncertainty.
The practical move is to build the exposure base once, at real coordinates, so the spend number has something solid to sit on. Do it once and it carries across reporting cycles.
For anyone reporting under these rules: are you disclosing the resilience-spending side, or is it the part that quietly drops off because there's no clean base to compute it against?
Full walkthrough: https://continuuiti.com/blog/ifrs-s2-paragraph-29e-capital-deployment/
Posted Jul 13, 2026, 10:34 AM UTC