Wells Fargo & Co: Disclose Material Financed Greenhouse Gas Emissions

BE IT RESOLVED: Shareholders request that Wells Fargo measure and disclose, at reasonable cost and omitting proprietary information, its material, financed greenhouse gas emissions.

WHEREAS: Banks play an important role in shaping the trajectory of the energy transition; their financing and investing decisions can either mitigate or exacerbate climate-related risk.[1] Financed emissions are the largest source of a bank’s greenhouse gas (GHG) emissions.[2] By assessing and disclosing such emissions, Wells can provide investors with information essential to understanding the bank’s material contribution to climate change, alignment with global net-zero goals, and approach to strategic risk mitigation and capital allocation.

Measuring and disclosing financed emissions is especially critical for Wells Fargo, which is the sixth largest fossil fuel financier globally[3] and has increased financing to companies that expanded fossil fuel projects by 60% from 2024 to 2025.[4]

Wells Fargo previously treated financed emissions as a material issue. In 2021, the Company set a target to achieve net-zero emissions, including financed emissions, by 2050,[5] outlined sector-specific interim 2030 financed emissions targets, and disclosed financed emissions in its annual sustainability reporting.[6] In February 2025, however, Wells Fargo withdrew its 2030 and 2050 financed emissions targets and ended its financed emissions reporting, which had provided crucial risk-related data to investors.[7],[8]

Without annual reporting, investors cannot track our Company’s high-carbon financing trends or accurately price its exposure to climate-related risk, including physical risk and the potential for stranded assets, litigation, and reputational damage. Litigation risk is of particular concern, as climate cases are ongoing against banks including ING and BNP Paribas for their financing of high-carbon business sectors.[9] Since climate cases are based on historical emissions, waiting to reduce financed emissions increases risk.[10]

Wells Fargo’s lack of financed emissions disclosures makes it a clear laggard among major U.S. banks. Bank of America,[11] Citigroup,[12] and Morgan Stanley[13] all disclose financed emissions for their high-emitting sectors using Partnership for Carbon Accounting Financials (PCAF) methodology. JPMorgan Chase[14] and Goldman Sachs[15] disclose financed emissions using slightly different methodologies. Wells Fargo's abandonment of its annual financed emissions disclosures is a discretionary retreat from an established industry practice, making it an outlier amongst its peers.

Investors require transparent information about whether and how Wells Fargo is managing its climate-related risk. Financed emissions disclosures, specifically for high-emitting sectors, serve as a valuable first step.

[1] https://www.oecd.org/en/publications/oecd-review-on-aligning-finance-with-climate-goals-2026_79415c38-en.html

[2] https://carbonaccountingfinancials.com/files/standard-launch-2025/PCAF-PartA-2025-Executive-Summary-Clean.pdf

[3] https://www.bankingonclimatechaos.org/wp-content/uploads/2026/06/BOCC_2026_vFINAL.pdf, p.10

[4] https://www.bankingonclimatechaos.org/wp-content/uploads/2026/06/BOCC_2026_vFINAL.pdf, p.32

[5] https://www08.wellsfargomedia.com/assets/pdf/about/investor-relations/annual-reports/2021-annual-report.pdf, XI

[6] https://www.banktrack.org/download/climate_report_2024_2/240809_wells_fargo_climatedisclosure.pdf

[7] https://www.reuters.com/sustainability/climate-energy/wells-fargo-drops-financed-emissions-target-amid-esg-rethink-2025-02-28/

[8] https://www.reuters.com/sustainability/climate-energy/wells-fargo-drops-financed-emissions-target-amid-esg-rethink-2025-02-28/

[9] https://greencentralbanking.com/2025/08/26/finance-on-trial-how-climate-litigation-against-banks-could-drive-systemic-change/

[10] https://sustainability.yale.edu/explainers/yale-experts-explain-climate-lawsuits

[11] https://about.bankofamerica.com/content/dam/about/report-center/esg/2025/SustainabilityatBofA2025_WCAG2.2_121625.pdf

[12] https://www.citigroup.com/rcs/citigpa/storage/public/global-sustainability-report-2025.pdf