資本市場上溫室氣體排放之資訊揭露與漂綠風險

Carbon Emission Disclosure and Greenwashing Risk in the Capital Market

在全球暖化與氣候變遷的當下，如何有效減少溫室氣體排放係重要的課題，公開資訊揭露制度，對於各種直接或間接促使企業進行減碳作為的規範機制，扮演著重要的角色，但公開資訊揭露制度的成效，必然取決於揭露的內容是否有提供市場參與者確實可靠有用的資訊。本文的基本假說為，企業出於自利的誘因以及碳排放盤查交易成本的限制，加上相關揭露項目的模糊性，碳排放揭露應會呈現出相當程度漂綠的狀況。本文觀察我國自2011年以來上市企業於資本市場上的碳排放揭露實務，有以下主要發現：首先，有自願進行揭露的企業數量並不多，可支持主管機關朝向強制揭露的規範趨勢；其次，企業揭露內容的平均字數不多，顯示內容有限，可量化的碳排放數量資訊的揭露方式亦欠缺一致性，形成破碎化或選擇性揭露的狀況，許多企業亦未揭露外部查驗的資訊或未經外部查驗就質化的資訊，其內容通常並無可比較性，亦無法驗證其真偽與執行狀況。因此，本文認為我國過去的碳排放揭露實務，確實呈現出相當程度漂綠的狀況，主管機關宜更進一步思考，如何平衡交易成本以及充實揭露的內容，來提升揭露資訊的可信度，以期能提供更有效且有用的資訊至市場，從而達成資訊揭露機制的目的。

Amid global warming and climate change, it is important for individuals and enterprises to reduce their carbon emissions. Adequate information is necessary to facilitate different stakeholders (from the government and corporate managers to investors, consumers and financial firms) to monitor an enterprise’s carbon emission performance and any action to face global warming. There arises the need for public disclosure of carbon emissions and other climate-related information. This is duly reflected in the reporting obligation of some firms to report their carbon emission data to the Ministry of Environment and the obligation to disclose relevant information in the capital market, the latter of which is the focus of this article. However, given the self-interest of enterprises and transaction costs of verifying carbon emissions and preparing disclosure documents, this article hypothesizes that public disclosure of carbon emission-related information will present a serious greenwashing risk, defined broadly to cover situations where a company offers wrong, misleading, inaccurate or selective information in order to make it looked more environment-friendly. The problem could be exacerbated by vague and ambiguous items that enterprises have to disclose. To test this hypothesis, this article analyses past disclosure documents of listed companies in Taiwan between financial years 2011 and 2021 in the Market Observation Post System, operated by the Taiwan Stock Exchange. This article finds that there were not many firms voluntarily making carbon emission disclosure in or before 2020 in the capital market. The finding may lend support the financial regulator’s decision to impose a mandatory disclosure regime from 2023 in Taiwan. In addition, the average length of disclosure is relatively short (indicating a lack of content) and there are significant inconsistencies regarding the ways companies disclose carbon emission data. Some firms did not even verify their disclosed data by a credible third-party institution. There is also a lack of consistent information on third-party verification of carbon emissions. Moreover, qualitative answers tend to be vague and cannot be verified. It is also difficult to compare the descriptions and information provided by companies in disclosure documents. The findings of this article suggest that there could be serious greenwashing risk from past practices. The updated disclosure form in 2022 by the financial regulator does not seem to make huge improvements. Therefore, greenwashing risk may persist under the current regulatory framework as in 2023. This article argues that regulators should issue further guidelines to substantiate and standardize the contents of disclosure documents. In particular, the regulator should focus first on quantifiable data (such as carbon emission) and reconsider the target audience of disclosure of carbon emission data and information related to climate change in order to provide more useful, meaningful and comparable information to the market and to reduce the chance that carbon disclosure regime is deployed as a greenwashing tool by firms in Taiwan.