Carbon Disclosure and Climate Change Mitigation in the European Union: Diffusion and Dominance of Transparency Frames

This paper investigates the rise of governance-by-disclosure in the global climate regime, examining how the framing of carbon disclosure evolved into an effective governance norm within the European Union (EU). Employing discourse network analysis, we analyse the evolution of carbon disclosure frames in the EU between 2000 and 2020. The analysis is based on over 12,000 statements from Financial Times and New York Times articles, coded by actor type and frame to capture the evolution of discourse coalitions and dominant narratives across four key periods defined by major global climate events. We show that debates on carbon disclosure were initiated by non-state actor coalitions that framed transparency as a risk moderator and an economic opportunity for businesses and investors. These findings confirm the expectations of stakeholder and economic theories of transparency, emphasising privatisation and marketisation as pivotal drivers of the disclosure regimes. Additionally, since early 2010s, we observe an increasing trend towards institutionalisation/diffusion. Especially after the Paris Agreement, European actors, including the European Commission, have increasingly converged around regulatory frames, in addition to the existing dominant discourse on financial benefits. Reflecting the growing consensus around these frames, this period also saw a significant expansion of policy initiatives within the EU advocating for mandatory disclosures. This paper makes a significant contribution by not only offering an empirical evaluation of existing theories on disclosure but also introducing a novel temporal dimension to analyse the dynamics of frame diffusion and dominance. Beyond carbon disclosure, our findings show how market-driven frames gain traction, diffuse, and converge within regulatory frameworks. This reveals the dominance of private governance logics in EU climate policy and the resulting tensions over democratic legitimacy in disclosure regimes.