How ESG disclosures may expand the nature of the CFO’s role

CFO Insights

In this edition of CFO Insights, we'll explore some issues for CFOs to consider as they prepare for the SEC's final disclosure rules and the challenges they may encounter.


At a recent finance conference, the CFO of a manufacturing company expressed some misgivings about attending a breakout session about the US Securities and Exchange Commission’s proposed rules for climate disclosure. “I’m violating my own rule by being here,” he said. “I said I wasn’t going to spend any time on this until I know what the rules are.”

He clarified that his own organization had taken a few early steps towards climate-disclosure preparedness—assigning the finance function responsibility for collecting climate data as well as making plans to add resources to aid with data collection. But otherwise, he said, “we are waiting on the final rules.” Those proposed rules, otherwise known as the Enhancement and Standardization of Climate-Related Disclosures for Investors, could be finalized as early as this spring.

Based on the findings of Deloitte's Sustainability action report on preparedness for environmental, social, and governance (ESG) disclosures, the CFO and his employer are hardly alone. The Deloitte report, published in December 2022, included an online survey of 300 senior executives at publicly owned companies with annual revenues of $500 million or more, as well as interviews with senior executives from a range of industries. The result: 57% of executives report that their companies have established a cross-functional ESG council or working group for the purpose of driving strategic attention to ESG.1 That figure represents a marked increase from the 21% who reported having gotten that far when Deloitte conducted its first ESG survey in late 2021.2

Still, 45% of surveyed companies have yet to lay the cross-functional groundwork required to integrate ESG strategy into both business operations and long-term strategy, according to last year’s survey.3 “While most companies are beginning to take meaningful steps toward enhancing their ESG disclosures, some challenges remain,” the December report concluded. A significant share of those ESG-related challenges could fall under the purview of CFOs, given their responsibility for companywide data and oversight over budgetary matters.

In this edition of CFO Insights, we'll explore some issues for CFOs to consider as they prepare for the SEC's final disclosure rules and the challenges they may encounter.

How ESG disclosures may change the nature of the CFO’s role


1Sustainability action report: Survey findings on ESG disclosure and preparedness,” Deloitte Development LLC, December 2022.

2ESG executive survey: Preparing for high-quality disclosures,” Deloitte Development LLC, March 2022. 

3 “Sustainability action report: Survey findings on ESG disclosure and preparedness.”

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Get in touch

Danny Griffiths
Partner, Extended Enterprise Risk Management
Deloitte UK


Kristian Park
Partner, Extended Enterprise Risk Management
Deloitte UK


Jon Raphael
National Managing Partner Sustainability, Transformation, and Assurance
Deloitte & Touche LLP

Dr. Sanjoy Sen
Head of Research and Eminence, Extended Enterprise Risk Management
Deloitte LLP


Kristen Sullivan
Audit & Assurance Partner Sustainability and ESG Services Leader
Global Audit & Assurance Sustainability and Climate Services Leader
Deloitte & Touche LLP

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