Critical Perspectives on Accounting 24 (2013) 397–409

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Critical Perspectives on Accounting

journal homepage: www.elsevier.com/locate/cpa

Free market environmentalism and the neoliberal project:

The case of the Climate Disclosure Standards Board
Jane Andrew a, Corinne Cortese b,*
a
Discipline of Accounting, Faculty of Economics and Business, The University of Sydney, NSW 2006, Australia
b
School of Accounting & Finance, University of Wollongong, NSW 2500, Australia

A R T I C L E I N F O A B S T R A C T

Article history: In the absence of good social, political, economic and environmental policy, the ecological
Received 12 October 2010 status of the planet continues to deteriorate. In this paper, we argue that environmental
Received in revised form 24 April 2013 decline has provided scope for new forms of policy-making, yet these emergent policies
Accepted 20 May 2013
and policy-making bodies remain poorly understood. Drawing on the work of political
Available online 13 June 2013
geographers and political economists this paper explores the impact of neoliberalism on
the development of global environmental regulation. We argue that climate disclosure
Keywords:
practices and regulation have provided an opportunity to reinforce the ideological
Climate change
Carbon disclosures landscape of neoliberalism. In order to anchor this argument, we show that the origins of
Accounting standards carbon regulation have emerged almost exclusively from within non-elected coalitions of
Climate Disclosure Standards Board multinationals operating through private, not-for-profit entities. These organisations
Neoliberalism continue to shape community expectations and influence government of climate change
abatement strategies. To explore the impact neoliberalism has had on the environment,
we examine the Climate Disclosure Standards Board (CDSB), its role, and its global impact
on the regulation of reporting firms.
Crown Copyright ß 2013 Published by Elsevier Ltd. All rights reserved.

1. Introduction

‘‘much of the power of neoliberalism stems from the way in which it structures the wider ‘policy environment’’ (Peck,
2001, p. 445).
It is well documented that we face a climate crisis. It is a crisis that will require enormous determination on behalf of
regulators, communities and corporations to find ways to respond to it meaningfully. Climate change and climate change
abatement both involve significant risks and, as such, much political and economic effort has gone into the development of a
variety of possible solutions. Mandatory regulatory requirements that relate to carbon pollution are now emerging, however
there is significant self regulatory activity and we know little about the impact this has on our collective understanding of the
climate change problem and climate change solutions. Given the risks involved, it is important to understand how climate
change policy and regulation has emerged and what political and economic interests are involved in the emergent policy
architecture. Drawing on the work of political economists and political geographers such as Peck (2001) and McCarthy and
Prudham (2004) we explore how carbon disclosure practice and policy has been framed and by whom. Using the CDSB as an
example and considering the growing body of literature that explores the connection between environmental policy and
neoliberalism, we argue that contemporary carbon disclosure practices have narrowed the policy arena. In effect, they have
provided space to reassert the neoliberal project through emerging environmental challenges.

* Corresponding author. Tel.: +61 2 42213697; fax: +61 2 42214297.

E-mail addresses: jane.andrew@sydney.edu.au (J. Andrew), corinne@uow.edu.au, corinnecortese@gmail.com (C. Cortese).

1045-2354/$ – see front matter . Crown Copyright ß 2013 Published by Elsevier Ltd. All rights reserved.
http://dx.doi.org/10.1016/j.cpa.2013.05.010
398 J. Andrew, C. Cortese / Critical Perspectives on Accounting 24 (2013) 397–409

As yet, little accounting research has explored carbon disclosure regulation as an opportunity to advance neoliberalism in
the context of environmental crises. Instead, accounting research has focused on the procedural and technical contribution the
profession can make to accounting or auditing for carbon (Kolk et al., 2008; Kolk and Pinske, 2007; Simnett and Nugent, 2007;
Simnett et al., 2009; Sullivan, 2006). Given the global impact of neoliberalism as an ideological and political project, it is
important to contextualise environmental regulation and developing accounting practices within the complex and uneven
mobilisation of the projects’ key ideas (Harvey, 2005). Although debates concerning the natural limits to growth have presented
a significant challenge to the neoliberal project, we have also seen the incorporation of environmentalism into new visions of a
neoliberalised green capitalism, enabling the expansion of its logic into spaces of resistance (McCarthy and Prudham, 2004). To
this end, McCarthy and Prudham (2004, p. 275) have argued that the ‘‘connections between neoliberalism, environmental
change and environmental politics remain under-explored in critical scholarship. . . relatively little has been said about the
manifestations of neoliberalism as environmental governance per se’’. Extending this further we contend that an understanding
of the connection between neoliberalism, environmental governance and public policy is critical if we are to achieve any viable,
globally relevant environmental regulations that offer inclusive possibilities for the future.
Environmentalism, emerging from the centres of global capitalism, provides opportunities to embed and advance
neoliberalism and to ensure the ongoing neoliberalisation of our environmental future. With the exception of a few
accounting researchers (Andrew et al., 2010; Lohmann, 2009; MacKenzine, 2009), the carbon accounting project has
sidelined philosophical and ethical questions to the much more pragmatic and digestible ‘real’ debates of technique and
descriptions of practice (such as Haque and Deegan, 2010; Kolk et al., 2008; Simnett and Nugent, 2007). Although these
technical challenges are important, part of our aim is to contribute to a broadening of the debate within accounting by asking
different types of questions that are process oriented and reveal a need for deeper consideration of the underlying
architecture that accounting practices are built upon.
The empirical focus of this paper, the Carbon Disclosures Project (CDP) and the Climate Disclosure Standards Board
(CDSB), provides an opportunity to explore the players involved in the process of carbon regulation. From its inception, the
CDSB has been affiliated with the voluntary and privately managed Carbon Disclosure Project (CDP), which holds the largest
repository of corporate carbon data. The CDP is now the world leader in carbon data collection and disclosure practices. The
‘success’ of the CDP means that it is now overseeing the development of ‘standardised best practice’ through the World
Economic Forum’s (WEF) CDSB. Using these organisations to provide the empirical focus for the paper we investigate the role
that the CDP and the CDSB play in the global policy arena, ‘‘excavating the underlying parameters, ideological orientations
and conspicuous silences of the policy-making process’’ (Peck, 2001, p. 449). This echoes a call from Merino et al. (2010, p.
777) to produce a fuller analysis of how the policy making process reconstitutes all crises to pave the way for ‘‘economic
elites to exercise power, almost invisibly’’ wherein ‘‘subjugation has been voluntary’’. According to Peck (2001, pp. 446–447)
‘‘the range of politically legitimate options in public policy seems to be narrowing rather than widening’’ enacted by a
‘‘hollowed out’’ state that ‘‘we need to see as a qualitative process of state restructuring, not as a quantitative process of sate
erosion or diminution’’.
This paper will begin with a brief introduction to the emerging literature on neoliberal environmentalism and its impact
on global policies and practices. In order to explore the structures that support neoliberal environmental solutions, we will
first examine the CDSB and its corporate focus; we will then critique the emerging climate related regulation and the
interests that are mobilising to influence this regulation. Unlike much of the previous carbon related accounting research, we
do not accept the fundamentals of neoliberal thinking as an appropriate starting point for climate policy.

2. Neoliberalism and the environment

2.1. Neoliberalism
‘‘the hegemony of neoliberalism is made most evident by the ways in which profoundly political and ideological
projects have successfully masqueraded as a set of objective, natural, and technocratic truisms’’ (McCarthy and
Prudham, 2004, p. 276).
In 2001, Peck suggested that we needed to spend less time critiquing public policy outputs and more time exploring the
political and economic contexts in which policy is formulated. He argued that the macro context that surrounds policy
making ‘‘is dominated by various strands of neoliberal conviction politics’’ which claims there is ‘‘’no alternative’ to a course
of deregulation, marketisation, privatisation and public asset stripping’’ (Peck, 2001, p. 445). Ten years on, his call for a better
understanding of the policy process is still relevant.
Although deregulation, marketisation and privatisation are features of the neoliberal project, it would be inappropriate to
suggest that neoliberalism itself has a definitive identity. Instead, it has been characterised as ‘‘perplexingly amorphous’’
(Cahill, 2010; Harvey, 2010; Peck, 2004, p. 394). Some have seen it as an ideologically hegemonic project, oriented towards
entrenching class power (Harvey, 2005, 2010). Others have seen it as a policy and programme (Beenson and Firth, 1998;
Peck, 2004) that has unevenly redrawn the boundaries between the state, markets and communities and has increasingly
naturalised the centrality of the market in decision making. And others have described neoliberal processes using Foucault’s
work on governmentality in order to explore the ‘‘way in which relations across and between peoples are imagined,
assembled and translated to create neo-liberal subjects’’ (Sadler and Lloyd, 2009, p. 614). Neoliberalism has continued to
emerge unevenly and despite its ‘successes’, it has been resisted, reworked and repositioned (Cahill, 2010). Like Peck (2001),
 J. Andrew, C. Cortese / Critical Perspectives on Accounting 24 (2013) 397–409 399

we see neoliberalism as both a coercive and a consent-driven project whereby the ability to see a role for the state beyond its
role within markets is made virtually impossible (Peck, 2001; Soederberg et al., 2006). In addition, few challenges to the
legitimacy of emerging self regulatory bodies can be mounted from within the logic of neoliberalism as the state’s role
appears redundant and unnecessary if private actors can mobilise to ‘do good’ (Reid and Toffel, 2009).
Despite the globally diverse appearance and uneven amplification of neoliberalism (Harvey, 2010), it has some ‘‘identifiable
dimensions’’ (McCarthy and Prudham, 2004, p. 276). In particular, neoliberalism is punctuated by the ‘‘self regulating market’’
which lies at the heart of Polanyi’s (1944) critique of capitalism and state/economy relationships. Much of the ideological vigour
associated with neoliberalism has promoted a view of efficient markets capable of regulating themselves out of most
conceivable problems and inefficiencies-including those associated with the environment (Sadler and Lloyd, 2009). According
to the theory, regulation that does anything more than create a space for capitalism is an unnecessary intrusion.
This reconfiguration of the role of the state under neoliberalism has led some to argue that global market economies rely
heavily on governments managing for markets rather than for constituents and communities (Cahill, 2010). Although clearly
a construct, this role is now seen as ‘natural’ and is too often unexplored and unexplained. Given the significant challenges
that environmental limits place on growth-oriented capitalism, it is unsurprising to find that the possibilities of
environmental policy are being contained within this neoliberalised policy context. Whilst we have seen a massive uptake in
voluntary and mandatory environmental regulation across the globe, central to these policies is an implied understanding of
the ‘appropriate’ role of the state and capitalist enterprise. As Peck (2001, p. 447) pointed out:
‘‘It is no coincidence that there have been attempts to establish these (pre)conditions as the taken-for-granted point of
departure for mainstream policy formulation, for they effectively lock in key structural features of the neoliberal
‘settlement’. The resultant policy debate is often a sterile and narrow one, for it renders so many fundamental policy
questions effectively beyond the scope of discussion or outside the ‘field of the visible’’’.

This presents a compelling argument to ensure neoliberalism is explored in the policy making process, not just in its
consequence. Like Peck (2001, p. 445), we argue that the ‘‘production of public policy’’ must be examined from the
perspective of an ‘‘increasingly neoliberalised system’’.
For the purposes of this work, we are particularly interested in the way governments, markets and communities have
changed through the mobilisation of actors and actions that are identifiably neoliberal, but are characterised as neutral and
reflective of a natural or rational order. Using the CDP and the CDSB as an example, this paper explores how coalitions of
interests have emerged to inform climate policy, encouraging policy responses to global problems to come from within the
architecture of capitalism as though this is an appropriate replacement of democratic engagement. The coupling of
capitalism and democracy through neoliberalised public policy belies the complex tensions between both.

2.2. Accounting and neoliberalism

Critical accounting researchers are familiar with the impact neoliberalism continues to have on accounting practice and the
visibilities and invisibilities this has afforded accounting knowledge (see, for example, Cooper et al., 2010; Ellwood and
Newberry, 2007; Newberry and Robb, 2008). In various ways, these researchers have demonstrated how the neoliberal project
has changed the nature and purpose of accounting information. They have also shown that accounting is an important part of
the technical architecture of neoliberalism. In addition, a growing number of accounting researchers have shown how
accounting operates to enable the logic of the market to permeate policy conversations as if the market is natural and value free
(see, for example, Arrington and Francis, 1989; Chwastiak and Lehman, 2008; Keller, 2007; Lehman, 2005; Miller, 1990).
Perhaps the most extensive discussion of these ideas can be found in Merino et al.’s (2010) work on neoliberalism, deregulation
and Sarbanes–Oxley. In essence, they for call accounting researchers to build a better understanding of how crises offer
opportunities to ‘‘reposition the shareholder at centre stage’’ and the processes through which neoliberals resist a reframing of
crises in terms that would require significant socio-political change (Merino et al., 2010, p. 777). As Judt (2010, p. 34) notes,
‘‘when asking ourselves whether we support a policy, a proposal or an initiative, we have restricted ourselves to issues of profit
and loss – economic questions in the narrowest sense. But this is not an instinctive human condition: it is an acquired taste’’.
The centrality of market economics within policy makes it difficult to reframe questions and offer alternative solutions.
Merino et al. (2010, p. 786) agree, arguing that ‘‘it will take a concerted effort by critics to reframe the issues in a manner that
highlights the growing contradictions between neoliberal theory and societal well-being’’. Even so, few critical
environmental accounting researchers have contextualised corporate social responsibility (CSR) research and practice
within this project and even fewer have examined the processes that are shaping environmental policy across the globe
(Sadler and Lloyd, 2009).

2.3. Neoliberalism and environmental debates

‘‘two of the most significant manifestations of corporate responsibility programmes–involve a displacement of core
regulatory functions (over issues such as working conditions and environmental sustainability) from the state to the
corporate sector. As yet, however, there has been relatively little sustained critical engagement with the wider
implications of CSR as a set of activities in its own right, in terms of the re-drawing of the boundaries between
corporate- and state-centred regulation that CSR represents’’ (Sadler and Lloyd, 2009, p. 613).
400 J. Andrew, C. Cortese / Critical Perspectives on Accounting 24 (2013) 397–409

Although explorations of neoliberalism and environmental debates are still fairly embryonic, many political geographers
are beginning to investigate the political economy of emergent environmental policy. Much of this has had a clear empirical
focus, with researchers investigating the impact of neoliberalism on water management (Sanganmeswaran, 2009); natural
resource management and governance (Higgins et al., 2008); land management (Higgins et al., 2012); forest policy
(Humphreys, 2009); trade agreements (McCarthy, 2004); environmental protection agencies (Holifield, 2004); ocean
management (Mansfield, 2004); and on conservation politics (Morris, 2008). Although this work has had diverse empirical
emphasis, all have identified a consistent neoliberalisation of policies and processes in relation to environmental
governance. According to McCarthy and Prudham (2004, p. 276) ‘‘even sustainable development, neoliberalism’s main
contender in challenging post-socialist development orthodoxy, could not seriously challenge the emerging free market
juggernaut, collapsing in policy circles into light-green capitalism’’.
In a variety of ways, the literature demonstrates how environmental challenges have presented opportunities to privatise
solutions; manage certain class expectations; offer market based instruments to support environmental change and provide
opportunities to demonstrate the capacity for ‘win-win’ environmental solutions. This mirrors the findings of Naomi Klein’s
2007 book, The Shock Doctrine, which found that crises of all descriptions – physical (such as the natural disaster in New
Orleans, the earthquake in Haiti), political (such as the interventions in Chile and more recently in Iraq), social (such as the
end of apartheid in South Africa) or economic (such as the collapse of the Soviet Union) – provided opportunities to further
the neoliberal agenda or what she described as ‘disaster capitalism’ (Klein, 2007).
In line with this, the environment has been both a real site for neoliberalisation (albeit uneven) and performative site to
demonstrate the rationality of neoliberal policy solutions (Castree, 2008a, 2008b). If we accept that securing access to the
natural world is integral to progress of global capitalism, then ‘‘what is largely absent is a recognition that neoliberalism is
also an environmental project, and that it is necessarily so’’ (McCarthy and Prudham, 2004, p. 277). The next section focuses
this discussion on the influence neoliberalism has had on climate disclosure practices.

2.4. Neoliberalism and climate disclosures

‘‘Climate change is an issue which business can ill afford to ignore. Those who do, risk getting a nasty surprise. . . and as
regulation increases, more and more companies will be affected by carbon pricing. But for those who get in ahead of
the crowd, there are huge commercial benefits in understanding the opportunities and risks associated with climate
change’’ (CDP and IBM, 2008, p. 3).
The far-reaching implications of climate change present a variety of challenges. It is a complex ethical, social, physical,
political and economic dilemma. Despite this, much emphasis has been placed on the impact climate change will have on
business. In 2007, KPMG conducted a survey into business leaders attitudes towards climate change revealing that 71
percent of those interviewed believe that the significance of climate change as a business issue would increase significantly
over time (KPMG, 2007). Even so, in 2008, 76 percent of S&P 500 companies failed to even mention climate change in their
annual report, despite an obligation to report information that is material to investor decision making (Doran et al., 2009).
Although there is widespread acknowledgement of climate change issues, the world’s largest firms have been slow to
disclose carbon related information. Whilst these firms have chosen to disclose little to the users of their annual reports,
many have played an active role in the formulation of business coalitions to develop disclosure standards. Many of the
world’s largest emitters of carbon have joined forces to define the parameters of carbon disclosures and support the
development of regulatory frameworks.1 There is a long history of lobbying the development of these kinds of public policy
instruments (Glachant, 2007; Gullberg, 2008), and businesses are particularly aware that the development of voluntary
initiatives may influence the government’s regulatory outcomes (Polk and Schmutzler, 2005; Southworth, 2009). Given that
private ‘self regulatory’ initiatives have influenced government policy in the past, these initiatives form an important part of
private sector strategy (Castree, 2008a, 2008b; Higgins et al., 2008, 2012; McCarthy, 2004; Sanganmeswaran, 2009).
Oftentimes they have held the need for mandatory regulations at bay.
A self-regulating approach to carbon has proven popular within the private sector, the government and the community
but it has met with some opposition (Lohmann, 2009). Many have argued that voluntary carbon disclosures enable a firm to
shape the appearance of their behaviour and limit the expectations of users to particular types of information and disclosure
(Bebbington et al., 2008; Laufer, 2003; Unerman, 2008). When Kim and Lyon (2011) compared the disclosure of emissions by
firms using the Department of Energy’s Voluntary Greenhouse Gas Registry to their ‘actual emissions’ their research showed
that larger companies under increasing regulatory pressure used the registry strategically and that these firms were
reporting their emissions data selectively. In addition, there is still little external verification of carbon disclosures (Andrew
and Cortese, 2011a) and the differing approaches to carbon accounting within organisations makes the data difficult to
compare (Andrew and Cortese, 2011b). In addition to the perceived strategic benefits of self regulated carbon disclosures, the
private sector, governments and the community have begun to identify broader market related business ‘risks and
opportunities’ as central concerns (Andrew et al., 2010; Blyth et al., 2009; Sullivan, 2006). Articulating carbon in terms of
business ‘risks and opportunities’ reinforces the idea that an informed market will allocate capital efficiently with

1
These organisations will be discussed later in the paper but include groups such as the Carbon Disclosure Project, the Greenhouse Gas Protocol, the
Climate Disclosure Standards Board, and the Global Reporting Initiative.
 J. Andrew, C. Cortese / Critical Perspectives on Accounting 24 (2013) 397–409 401

consideration to carbon related information. Much of this has served to reinforce the perception that environmental
problems should be managed with businesses at the core, rather than the reverse (Busch and Hoffman, 2007).
For the most part, a ‘business case’ for carbon disclosures has become commonplace and, for many, this reinforces the
virtues of market-based approaches to social, economic and environmental dilemmas (Reid and Toffel, 2009). Although
obscured, the self-regulated disclosure-based approach to climate change is an undeniably ideological project with
significant implications for the natural environment (as argued by McCarthy and Prudham, 2004). The business orientation
of climate change solutions should not be underestimated, nor should its impact (Beder, 1997, 2001, 2002b, 2008) and we
need to know more about how this project is advanced (Peck, 2001; Klein, 2007; Merino et al., 2010). In order to do this, we
have chosen to focus on emergent climate disclosure governance regimes–in particular the CDSB.

3. Neoliberalism and climate disclosure regulation

‘‘Carbon disclosure, in the context of financial and capital markets, is useful to inform shareholders of significant risks
and opportunities raised by climate change. . .We cannot afford to continue to be afraid of profit motivated business
driving the solutions to climate change’’ (CDSB, 2009b, p. 9, 11).
Many organisations have begun to see value in disclosing climate-related information to users, as such they are keen to
see the development of appropriate disclosure practices for producers and users of climate information. This is unsurprising
as contemporary CSR practice rests heavily on the idea that information disclosures enhance accountability and produce
more socially and environmentally sensitive decision making both internally and externally (Bebbington and Larrinaga-
Gonzales, 2008; O’Dwyer, 2003). Although this is a view held by many CSR researchers, there are some who are critical of the
approach (Sadler and Lloyd, 2009) and some who suggest that issues of social and environmental responsibility cannot be
solved by providing capital markets (and other users) with more information (Bebbington et al., 1999; Bebbington and
Larrinaga-Gonzales, 2008). It has also been suggested that the slow, emergent nature of voluntary corporate disclosures
stunts questions about the appropriateness of the market mechanism in issues of global social and environmental
significance and more worryingly, disclosure practices have become the ‘common sense’ currency for CSR driven change
with limited identifiable environmental benefits.
As a result, there has been a rise in the number of carbon disclosures registries, methodologies, and protocols in the last five
years. A recent KPMG survey of 30 countries revealed the existence of 142 country standards and/or laws that contain some
form of sustainability-related reporting requirement or guidance (KPMG, 2011). Many corporations have adopted one or other
of these in an attempt to stay abreast of emerging carbon related information demands. In simple terms, as users of climate-
related information have grown, so have the demands on the standard of this information. Like users of financial information,
users of climate information want timely, consistent, comparable, reliable information and they have been frustrated by its
current inadequacies (CDSB, 2009b; Sullivan, 2006). There is no doubt that capital markets want better information to support
decision making, but the link between this market-oriented information and climate change abatement is still unresolved.
Although there are important challenges to ensure useful information is made available to decision makers, the focus of much of
the debate around contemporary disclosure practices reinforces the market as the only viable mechanism available to policy
makers to address the climate challenge. In effect, the emphasis on disclosure practices has made climate change policy a
technical challenge that can be overcome with better technical regimes governing disclosure. Whilst this may be part of the
story, it assumes that policy and regulation should focus on resolving these technicalities and avoids the possibility that climate
change is a result of broader problems within capitalism itself. It also marginalises discussion of the important ethical
challenges that constitute a global environmental problem of this magnitude.
Again, it is not surprising that many carbon disclosure requirements are voluntary and have been developed by coalitions
of interested parties, with significant representation from industry (Kolk et al., 2008). In Sadler and Lloyd’s (2009, p. 618)
analysis of CSR, they noted that voluntary regulations have ‘‘a recurrent theme that left to their own devices, global corporate
citizens can evolve and broaden the sphere of what is seen as being appropriately beneficial behaviour for the greater social
and environmental good’’. In many ways, these emerging voluntary disclosure regimes allow further demonstration
neoliberalism’s virtues because the ‘the market’ is seen to respond to social and/or environmental problems without the
need for a heavy handed regulator (Eberlein and Matten, 2009; Kolk et al., 2008; Reid and Toffel, 2009). This reinforces the
view that climate change should be seen as an extended challenge to the adaptive capacity of the market, and that a crisis can
be averted with minor adjustments to the status quo. The process has also meant that governments have begun to create
regulatory spaces for a new era of market economies sensitive to climate related ‘risks and opportunities’ (in Australia, these
include the Clean Energy Act, 2011; Climate Change Authority Act 2011 and the National Greenhouse and Energy Reporting
Act 2007). In addition, although climate change policy is contested, the community has little opportunity to think outside a
neoliberal framework to evaluate proposed solutions (Pearse, 2011). According to Pearse (2011, p. 175):
Neoliberal hegemony is evident in the architectures of climate governance. . .Market based policies for emissions
mitigation are infused into the Kyoto Protocol, Copenhagen Accord and all national legislation already installed and
currently debated.
Initially, much of these emerging voluntary carbon disclosure regimes were developed in a particular place or within a
particular community to address specific information needs (such as the CDP, which emerged to support institutional
investor’s allocation decisions). This has many advantages, and presents significant regulatory opportunities – it presents an
402 J. Andrew, C. Cortese / Critical Perspectives on Accounting 24 (2013) 397–409

opportunity to develop a comprehensive set of guidelines or regulatory practices and also the opportunity to set the agenda
through self regulation (Sadler and Lloyd, 2009). There is no doubt that these efforts have been highly strategic and we know
from previous research that the appearance of high quality self regulation can often delimit the grounds for more
interventionist regulatory approaches (Glachant, 2007; Gullberg, 2008). There is also evidence to suggest that if there are to
be mandatory guidelines, a coherent voluntary guideline will heavily influence the outcome of any regulatory process (Craig
and Amernic, 2004; Goddard, 2002; Haswell and McKinnon, 2003).
The existence of several different carbon disclosure regimes across the globe has presented significant challenges to
producers and users of information. More recently, there has been an effort to harmonise these into one all encompassing,
universal standard that could be adopted as best practice (CDSB, 2009b). The use of a single global standard has the capacity
to enhance the perception that carbon disclosures are credible within capital markets, governments and the community
more broadly. With this in mind, the CDSB emerged from the 2007 Annual Meeting of the World Economic Forum (WEF)
with the aim of developing a consistent approach to the reporting of climate change-related data (WEF, 2007). This attempt
by the WEF to oversee a harmonised carbon disclosure standard remains significant and is an ongoing project attached to the
largest repository of carbon disclosure data in the world (the CDP). The size of the community associated with the CDP and
the CDSB make it a project of significance, and as a result it provides an empirical focus for the remainder of the paper. In
order to understand the CDSB, knowledge of the organisational structure of the WEF is critical.

3.1. The WEF

Although the ideological orientation of the WEF is well known, the connections between business and policy architects
produced through the WEF require ongoing attention. This is particularly true as organisations and governments across the
globe grapple with global environmental concerns such as climate change. The WEF’s commitment to ‘‘entrepreneurship in
the global public interest’’ has proven resilient despite widespread knowledge of the WEF’s exclusive membership and the
lack of diverse representation on its governance board.2 The membership of the Board has been scrutinised because of its
clear connections to global political and economic power brokers, and its independence has been questioned especially
when compared to organisations with a more democratic charter, such as the UN (Public Citizen, 2002). Although the Board
is not completely made up of corporate heads, its demographic is still very limited and, significantly, it does not include a
representative from an environmental NGO (WEF, 2010). The WEF has a long established history to:

‘‘open third world economies further to imports and foreign investment; to re-shape third world domestic economic
policies, including replacing public expenditure with privatisation; to remove various legal protections for labor in the
industrialised countries, and reduce its social claims; and to sort out the disputes among the leading industrialised
countries in this process’’ (Research Unit for Political Economy, 2007, p. 507).
The ability to continue to achieve these goals in the context of these climate challenges has emerged as a central concern
for the WEF more recently. To this aim, Hartwick and Peet (2003) and Sadler and Lloyd (2009) have argued that over the last
ten years the WEF has committed considerable resources to ensure economic growth and sustainability are seen as
complimentary forces – thereby muting the likelihood that the issues inspire vocal and oppositional public reactions. The
CDSB has emerged within this context. It would be inappropriate to suggest that this has happened without contest (Pearse,
2011), but despite challenges to the authority of institutions like the WEF, projects like the CDSB have considerable, high-
level support (CDSB, 2012a). In the following section we explore the CDSB in more detail. Our discussion demonstrates how
‘neoliberalisation’ is made possible through institutions like the CDSB. We focus on two key issues: first, we map the
interconnectedness of the CDSB’s Board members to suggest that the ongoing process of neoliberalisation occurs through
such coalitions and successfully embeds itself in the imagination of government and the community; and second, we
consider the production of the CDSB’s identity as a mediator for carbon disclosure ‘best practice’.

3.2. The CDSB

3.2.1. Creating a coalition of interest?

‘‘When a corporation wants to oppose environmental regulations, or support an environmentally damaging

development, it may do so openly and in its own name. But it is far more effective to have a group of citizens or experts
– and preferably a coalition of such groups – which can publicly promote the outcomes desired by the corporation
whilst claiming to represent the public interest’’ (Beder, 1997, p. 27).
The CDSB is made up of seven organisations that have a stated commitment to developing a generally accepted
framework for climate related corporate reporting. The organisations include The Climate Registry, the Carbon Disclosure
Project (CDP), the Coalition for Environmentally Responsible Economies (Ceres), The Climate Group, International Emissions

2
Membership of the WEF is made up largely of representatives from Europe, the United States and industrialised Asia and the governance board is made
up of 20 members who have senior roles within organisations such as the Deutsche Bank, Arcadia Treuhand, Nestle, Dell, Renault, Goldman Sachs, and the
UN as well as prominent individuals such as the President of MIT, Queen Rania of Jordan, and former Prime Minister Tony Blair (WEF, 2010).
 J. Andrew, C. Cortese / Critical Perspectives on Accounting 24 (2013) 397–409 403

Trading Association (IETA), World Economic Forum (WEF), and the World Resources Institute (WRI) (CDSB, 2009a). Each of
these organisations represented on the Board are supported by members that sponsor or donate significant, and mostly
financial, resources to fund their activities. These members are often major corporations that have the economic resources
and political wherewithal to be active players in the climate change debate. Some of these entities are actually represented
on the CDSB Advisory Committee and Technical Working Group, which serve to guide the Board’s work programme, develop
content, and advocate the work of the CDSB (CDSB, 2009a).
The degree of interconnectedness between Board members and Advisory Committee and Technical Working Group
members highlights the powerful business coalition that has formed a regulatory architecture around climate change to
ensure the ongoing, if not expanded, role of markets. The networks of overlapping interests have been mapped and are
shown in Fig. 1. While the interconnectedness among key players is interesting, also notable is the concentration of power.
The same entities appear again and again in membership lists, providing financial support to assist in arriving at a solution
that they will ultimately be governed by.
The coalition of interests that exist within the CDSB structure can be illustrated by considering the International
Emissions Trading Association (IETA). The ITEA is one of the seven Board members of the CDSB and comprises over 180
members from around the globe that pay an annual membership fee of US $18,000 to participate in the Association’s
development of a market-oriented climate change solution (IETA, 2010). The IETA commenced in 1999 as an initiative of the
United Nations Conference on Trade and Development and the World Business Council for Sustainable Development. The
current Chairman of the IETA is a Senior Climate Change Advisor for the Royal Dutch Shell Group and one of the Vice
Chairman is from Rio Tinto (IETA, 2010). Both Royal Dutch Shell and Rio Tinto serve on the Advisory Committee of the CDSB.
Other members of the IETA that are also members of the CDSB Advisory Committee and Technical Working Group include
Duke Energy, APX Power Markets, JP Morgan Chase, Deloitte, Ernst & Young, KPMG, and PricewaterhouseCoopers (IETA,
2010).
This one example illustrates that although the formal, consultative regulatory structures appear to be in place, it is
undeniable that contributors are aligned in such a way that the preferred solution will be one that is weighted heavily in
favour of corporate participants.

World Business
Council f or Sustainable
Develop ment
The CDSB Board Members
Respo nsible f or leading and managing the develop ment of generally acc epted glob al
carbo n standards in conjucntion with strategic partners and stakeholders Jointly
World develop ed
Ceres
Resources the GHG
World Institute
Carbo n Economic
The Climate Disclosure International The Forum
Group Project Emiss ions Climate
(CG) (WEF)
(CDP) Trading Registry (CDSB
(CDSB Ass ociation (TCR)

THE CLIMATE DISCLOSURE STANDARDS BOARD

The CDSB Advisory Com m ittee & Technical Working Group
Assists the Board w ith carbon standard guidance, content development, and advocacy

Royal Duke Big 4: Swiss Re JP Morgan Tokyo Pacif ic

Dutch Energy Deloitte (CG, WEF, Chase Electric Gas &
Shell (CG, GHG (CG, IETA, Power Co
KPMG Protocol) WEF, WRI)
Energy
Rio Tinto (IETA, WBCSD, (WBCSD,
PwC, E&Y Corp
(IETA, WBCSD,
(ICGP, IETA,
WEF, GHG
(TCR, WRI)
Protocol)
WBCSD, WEF, SUN
American
Group
International Group The Carbo n International
Trust Federation of
Marsh Praxair UK Dept of UN
APX
McLennan Environment,
Power Environment
Cravath, Swaine & Food , & Rural
Markets Prog ram
(CDP, ACCA Canadian Insitute
of Chartered Investor Group
Japanese UN on Climate Climate
Institute of Foundation Change Counts
Calif ornia State Institutional
Confederation GHG Investors
of British Mgmt Group on
Institute of Chartered Haskell & Industry Institute
Acc ountants England and Skadden et al Climate
White LLP
(Acronyms in brack ets indicate those Board members with which Advisory Committee members have an association
e.g. through sponsorship, donation, membership, or partnership)

Fig. 1. The structure and make up of the Climate Disclosures Standards Board.
404 J. Andrew, C. Cortese / Critical Perspectives on Accounting 24 (2013) 397–409

The Framework also requires that greenhouse gas emissions (GHG) information be disclosed in accordance with rules
specified in ‘‘recognised GHG emissions reporting schemes’’ (CDSB, 2010, p. 23). The first global GHG reporting scheme
specified by the Framework is the GHG Protocol, developed by the World Resources Institute (WRI) and the World Business
Council for Sustainable Development (WBCSD) (CDSB, 2010). Interestingly, the relationship between the CDSB and the
participants involved in the formation of the GHG Protocol results in still more interconnectedness between key players (see
Fig. 1). The WRI is on the board of the CDSB, is a member of the IETA and has hundreds of donors including CDSB Advisory
Committee members Royal Dutch Shell Group, the Big 4 accounting firms, JP Morgan Chase, Duke Energy, Rio Tinto, and
Pacific Gas and Energy Corporation (WRI, 2010). The WBCSD is a CEO-led association of 200 companies from around the
world (WBCSD, 2010). Key members include CDSB Board and Committee members IETA, BP, Shell, the Big 4 accounting firms,
Duke Energy, Swiss Re, and Tokyo Electric Power Company (see Fig. 1). As noted, the CDSB proposes the use of the GHG
Protocol, developed jointly by the WRI and the WBCSD, however many of the WRI and WBCSD members are also members of
the CDSB. Again there is a circular relationship; those interest groups that contributed to the creation of the voluntary GHG
Protocol are the same ones that are mandating its use through the CDSB Framework. This supports Pearse’s (2011, p. 178)
findings that:
‘‘(a) cohort of carbon entrepreneurs have nested into the architectures of climate governance, realising their political
project by rolling out often pre-emptive institutional arrangements’’.
Although the comparability and uniformity of carbon information can be improved, it is questionable whether the
perfection of these reporting issues will lead to better environmental outcomes when the broader economic imperatives of
capital markets are yet to be significantly challenged (Beder, 1997, 2001; Spence, 2007). Spence (2007, p. 856) has argued
that social and environmental reporting is driven more by concerns with legitimacy, stakeholder management and masking
conflict than by accountability – much less climate change abatement. Enhancing and improving corporate carbon
disclosures may appear to be a very natural response to the challenging environmental pressures presented by climate
change, but this connection is poorly articulated within the emerging disclosure regimes.
As Ruggie (2004) has pointed out, the context in which such solutions emerge is significant and, as yet, there has been
very little analysis of new, largely private institutions that are developing strategies to govern climate change. The political
issues that arise in the carbon standard development process are similar to those that have plagued the more traditional
aspects of financial reporting and measurement for decades and corporate engagement in the process of standard setting has
become a well-accepted notion in the accounting literature (Cortese et al., 2010; Solomons, 1983; Van Riper, 1994; Zeff,
2002). What is important in the story of the CDSB and its counterparts, the WEF and the CDP, is that they provide us with
further insight into how neoliberalism is sustained despite significant challenges like those presented by climate change.
Along with many other critiques of neoliberalism (such as Cahill, 2010; Harvey, 2010) the story of the CDSB suggests that the
power of neoliberalism to influence policy comes not just from private sector sources, but also lies in the power to mobilise
neoliberal ideas within governments and the community.

3.2.2. The CDSB as market advocate?

According to the WEF, the formation of the CDSB was largely a response to increased corporate and financial market
pressure to develop a consistent approach to the reporting of carbon related data (WEF, 2007). This push gained momentum
as a result of growing interest in the voluntary carbon disclosures regime, the Carbon Disclosure Project (CDP). When the CDP
was launched in 2000 it aimed to collect and distribute high quality carbon information for decision making (CDP, 2010). By
2010, the CDP was responsible for requesting carbon information from 3000 companies on behalf of institutional investors
worth US$71 trillion (CDP, 2010). The sheer volume of data generated as a result of the CDP, as well as the substantial interest
in the disclosures, led to calls for a more standardised disclosure process. In effect, representatives of the world’s largest
corporations and institutional investors wanted to ensure that the kind of carbon data entering the market was as uniform as
possible and that it was oriented towards strategic allocation decisions (CDSB, 2010). Given the history of the WEF, they
quickly began to fill this gap with the formation of the CDSB, which has since joined forces with the CDP (CDSB, 2009a).
Although the CDP had separate origins, the CDP now manages the work programme of the CDSB, acts as its Secretariat, and is
a member of the Board itself (CDSB, 2009a).
The mission of the CDSB is to promote the inclusion of climate change-related disclosure into mainstream financial
reports by developing a globally accepted framework for corporate reporting on climate change (CDSB, 2010). There is an
explicit recognition that the information should meet the criterion of ‘‘decision-usefulness’’ as understood by investors, and
that this criterion can be met by the creation of a Climate Change Reporting Framework that aligns its principles to the
existing financial reporting principles and objectives that govern market transactions (CDSB, 2009b). They write (CDSB, 2012
emphasis added):
‘‘About us: CDSB develops resources for transformative climate disclosure for honest and effective markets’’
Specifically, they argue that through improved information for ‘‘investor analyses’’, the CDSB will enhance the ‘‘efficiency
of capital allocation’’, improve the ‘‘value creation potential’’ of organisations, provide ‘‘conceptual and practical input into
deliberations by regulatory agencies, and ‘‘assist policy makers’’ (CDSB, 2012d). The intention is explicit: the goal of the
Board is to facilitate a market and influence regulation around climate change. When describing the benefits of their work,
the CDSB suggest that along with efforts to consolidate best reporting practice, they’ll provide ‘‘support for global carbon
 J. Andrew, C. Cortese / Critical Perspectives on Accounting 24 (2013) 397–409 405

markets’’, help produce ‘‘effective and stable markets’’ and they’ll have ‘‘global policy influence’’ (CDSB, 2012b). The benefits
are clearly framed in terms of market outcomes. Rhetorically, climate change does not represent a global ethical dilemma
with material consequences but rather, an opportunity to ‘make a market’ (Pearse, 2011). On face value, the CDSB is an
organisation that will address carbon reporting issues and propose an acceptable disclosure framework. In so doing, the
Board is defining itself as a mediator of ‘best practice’ within narrowly defined sets of existing practices anchored within the
logic of the market. The work programme of the Board has centred on the development of a Climate Change Reporting
Framework which would be used as a model for the disclosure of climate change-related issues in mainstream financial
reports (CDSB, 2010).
So far, there has only been limited application of the Framework in practice which makes any study of its impact difficult
(Cotter et al., 2011) but it is apparent that the CDSB is well placed to influence global reporting practices and is very present
within international policy discussions. Examples of this influence have been growing over the last three years. In 2009,
when the Draft Reporting Framework was released by the CDSB at the World Business Summit on Climate Change in
Copenhagen it was labelled an ‘‘innovative and visionary business response’’ to the problem of carbon disclosure (CDSB,
2009b). After a period of public consultation, during which only 23 submissions were received, the CDSB’s Climate Change
Reporting Framework – Edition 1.0 was released in September 2010 (CDSB, 2010). As Haigh and Shapiro (2011, p. 120) noted,
respondents to the draft framework ‘‘approved of the rigour of using principles of decision-usefulness to guide carbon
reports’’ but it remained difficult to produce consensus on the detail of the framework. In December 2011, John Elkington, a
leader in the field of ‘triple bottom line’ reporting identified the CDSB as a ‘superstar’ in his list of the 50 leading organisations
of the future indicating the success of the organisation to position itself as the ‘future’ of carbon reporting (Elkington et al.,
2011). And in June 2012, the CDSB commented on the UK’s decision to introduce mandatory carbon reporting requirements
saying they will ‘‘encourage the UK Government to adopt CDSB’s Climate Change Reporting Framework as the standard for
compliance with UK climate change reporting requirements’’ (CDSB, 2012c). The CDSB has been clear that they will seek
high-level discussions with the regulators to ensure their framework is mandated into law.
The long run aim is to ensure reporters subscribe voluntarily to a global set of reporting ‘best’ practices around carbon –
what they now call their Consistency Project. Currently the CDSB is working on a joint ‘inter agency’ project with the GRI,
OECD and UNCTAD to map global reporting practices in order to develop the framework. Given this, the CDSB has
successfully represented itself as a neutral arbiter of ‘technical best practice’ and for many, the CDSB represents an excellent
example of how complex and diverse reporting regimes can be brought into alignment by bringing together ‘‘communities of
practice’’ to develop the Framework (Ascui and Lovell, 2011). Notably, the CDSB sees the CDP, GRI and the GHG Protocol as
creating the reporting architectures required to promote carbon reporting – but the precise content of these disclosures is
still contested and one that the CDSB is keen to ‘win’.
Although perhaps implicit in the nature of the proposed Framework, the absence of direct comment on environmental
outcomes that should result from companies adopting the reporting model proposed by the CDSB is notable. In effect, this
absence directs thinking to the capital market allocation advantages that would result and not the environmental
benefits. This is significant as these critical environmental outcomes, by virtue of their absence, may appear redundant
and unnecessary. While the Reporting Framework reiterates the CDSB’s commitment to the integration of climate
change-related information into mainstream corporate reporting, it is significant that there is no mention of the climate
change mitigation outcomes among the aims and objectives of the CDSB. Instead, the objectives are to provide
information about the way in which climate change ‘‘affects strategy, performance and prospects of organisations’’ and
how organisations are placed to manage the ‘‘risks, opportunities, and financial impacts association with climate change’’
(CDSB, 2010, p. 4). Throughout both the Draft and final Reporting Framework’s, there is a clear signal that the climate
change-related information is important because it will facilitate capital allocation decisions, value creation and the
management of risks and opportunities (CDSB, 2009b, 2010). Although these terms of reference appear unproblematic,
they clearly reinforce the underlying assumptions of neoliberalism. Knowledge of the structure of the CDSB provides
some insight into the reasons this has been possible and the strategies mobilised to ensure outcomes that conform to the
ideals of neoliberalism.

4. Conclusion
‘‘So called ‘free’ markets are becoming the new organising principle for the global order. The idea that governments
should protect citizens against the excesses of free enterprise has been replaced with the idea that governments
should protect business activities against the excesses of democratic regulation’’ (Beder, 2008).
Over the last thirty years, the significance of global environmental issues has risen to prominence, culminating in
organised global efforts to deal with the significant climate crisis we now face. At the same time, ideologies that promote
smaller governments and market deregulation have increased in global popularity and public policy has been heavily
influenced by this broader context. The challenges presented by climate change and global warming are being handled
within this broader socio-political context, a context that presupposes the legitimacy of carbon related regulation that relies
heavily on accurate ‘price signals’. According to Beder (2002a, p. 22) corporations and their various coalitions have
‘‘successfully placed neoliberal remedies to environmental problems on the policy agenda’’ and these ‘‘appeal to certain
‘deep core beliefs’ associated with the need for reduced government intervention and an increased dependence on the
market’’. Given that the market and its latest neoliberal manifestations have been heavily implicated in the current climate
406 J. Andrew, C. Cortese / Critical Perspectives on Accounting 24 (2013) 397–409

crisis, the proposed market solutions should be critiqued and resisted. Despite this, ‘‘policy entrepreneurs’’ (Beder, 2002a, p.
22) have provided a powerful framing of the problem and its potential solution. The CDSB presents an example of this.
The findings of this paper provide further support for McCarthy and Prudham’s (2004, p. 279) argument that ‘‘neoliberal
ventures have increasingly assimilated environmentalism through key discursive shifts, such as the growing convergence of
sustainable development with green capitalism. . .such incorporation of environmentalism in the heart of neoliberalism
central institutions has done more to smooth the ‘roll out’ of neoliberalisation than attempts to dismiss or reject
environmental concerns outright’’. They reinforce the role of the ‘free market’ at a time when the presence of significant
environmental challenges holds out the possibility of some form of direct intervention to foster sustainability and avert a
crisis. We have shown that large institutions are strategising to delimit the boundaries of their climate responsibilities in the
hope of influencing the regulatory outcome of climate policies. Faced with regulatory uncertainty, many corporations and
environmental groups sympathetic to corporate environmental solutions have formed ‘‘advocacy coalitions’’ (Beder, 2002a,
p. 22) to influence climate regulation. Although capitalist economies promote competition, the threat of externally imposed
restraint on behaviour has forced these very entities to work together to create an acceptable solution to the climate
dilemma. This solution, as promoted by the CDSB, is one that keeps the key structures of a market economy intact, sending
‘price signals’ to users through carbon related disclosures. This works in two ways, it serves to inform what we think about
and how we can think about it. It constitutes the discursive space in which public policy can emerge and an understanding of
this provides some insight into the public policy making process (Peck, 2001) and how the narrowing of the policy arena has
been possible.
We have not commented on the efficacy of the solutions being proposed by the CDSB, we have however drawn attention
to the process through which regulatory strategies are emerging (Peck, 2001). Within this context policy makers should
consider that the CDSB’s approach to carbon disclosure is just one of many possibilities. Its popularity lies in its unspoken
ideological commitments to neoliberal markets and its success lies in the significant economic and political power mobilised
to support it.
The accounting profession is also heavily implicated in the broader socio-political shift from ‘climate change as a policy
dilemma’ to ‘climate change as a technical dilemma’. This shift has seen the profession uncritically support the development
of climate disclosures that revolve around the market to ensure entities better position themselves to maximise the
‘‘opportunities’’ and minimise the ‘‘risks’’ associated with climate change. Accountants have participated in this process,
providing technical support and guidance to the CDSB. Accounting practitioners and the professional bodies find themselves
again supporting the seamless expansion of markets, even in the face of significant environmental constraints. This forms
part of the silent, unspoken architecture of neoliberal capitalism and it requires continuous exploration in order to bring
visibility to the ideological nature of the discussion and to challenge the idea that the market is the most appropriate forum
for all social and environmental negotiations. As the case of the CDSB has shown, the market logic that underpins climate
policy is not a self evident truth – but an actively constructed ideological project requiring the mobilisation of significant
economic interests and resources, some of which we have revealed in this paper. In addition, the CDSB provides little insight
into the environmental outcomes of their proposed disclosure regime and appears under little pressure to do so. It would be
unwise to assume this relationship. The absence of articulated environmental drivers, ambitions or outcomes within
emergent disclosure regimes is of concern. It is important to imagine that policy could be centred on the environment and
that this may require us to rethink the centrality of the market – but to do this, we must first be able to see the market as an
option and not a fait accompli.

Acknowledgements

We would like to gratefully acknowledge the financial support provided by the Faculty of Commerce at the University of
Wollongong and the Institute of Chartered Accountants Australia.

Appendix. CDSB Advisory Committee and Technical Working Group: Members

Advisory Committee
American International Group
APX
Climate Counts
Confederation of British Industry
Cravath, Swaine & Moore LLP
Duke Energy
Haskell & White LLP
Marsh McLennan
Royal Dutch Shell
JP Morgan Chase
 J. Andrew, C. Cortese / Critical Perspectives on Accounting 24 (2013) 397–409 407

PG&E Corporation
Praxair Inc
Rio Tinto
Swiss Re
Tokyo Electric Power Company
SUN Group
Skadden, Arps, Slate, Meagher & Flom LLP
Institutional Investors Group on Climate Change
Investor Group on Climate Change
UK Department of Environment, Food and Rural Affairs
California State Assembly
The Carbon Trust
The Greenhouse Gas Management Institute
United Nations Environment Program Finance Initiative
United Nations Foundation

Technical Working Group

Deloitte
Ernst & Young
KPMG
PricewaterhouseCoopers
Association of Chartered Certified Accountants
Canadian Institute of Chartered Accountants
International Federation of Accountants
Institute of Chartered Accountants in England and Wales
Japanese Institute of Certified Public Accountants

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