TCFD · Climate-related disclosure
TCFD reporting in the UK: who reports, and what replaces it
TCFD reporting is still required in the UK, even though the Task Force itself disbanded on 12 October 2023.
Four regimes require disclosure in its four-pillar shape today: the FCA listing rule, the Companies Act climate disclosures, the FCA ESG sourcebook and the pensions regulations.
For listed companies, the FCA’s final rules in PS26/19 replace the TCFD-aligned disclosures with UK SRS, on a comply-or-explain basis, from 2027.
The framework
Four pillars and eleven disclosures
The TCFD published its recommendations in its June 2017 Final Report, and they have not changed since.
The October 2021 Annex updated the guidance, not the eleven disclosures.
| Pillar | Recommendation | Recommended disclosures |
|---|---|---|
| Governance | The organisation’s governance around climate-related risks and opportunities | (a) the board’s oversight · (b) management’s role |
| Strategy | Actual and potential impacts on the business, strategy and financial planning, where material | (a) risks and opportunities over the short, medium and long term · (b) their impact · (c) resilience under different scenarios, including a 2°C or lower scenario |
| Risk Management | How the organisation identifies, assesses and manages climate-related risks | (a) identifying and assessing · (b) managing · (c) integration into overall risk management |
| Metrics and Targets | The metrics and targets used, where material | (a) the metrics used · (b) Scope 1, Scope 2 and, if appropriate, Scope 3 emissions · (c) targets and performance against them |
The materiality qualifier is uneven, and deliberately so: Governance and Risk Management have no materiality gate.
Since October 2021 the guidance has asked for greenhouse gas emissions to be disclosed independent of a materiality assessment, while the Metrics and Targets recommendation above it still says “where such information is material”.
Scope 3 in the original text is “if appropriate”, which is weaker than anything in IFRS S2 and the source of much confusion about whether Scope 3 was ever optional.
Our sister site has a walkthrough of the four pillars as they carry into UK SRS.
The Task Force
The TCFD disbanded; its shape did not
The Task Force on Climate-related Financial Disclosures was set up by the Financial Stability Board in 2015.
Its own site now opens with a notice that it has “fulfilled its remit and disbanded”, concurrent with its 2023 status report on 12 October 2023.
The same notice says the fsb-tcfd.org site has not been updated or monitored since November 2023, so every document there is the last version, not the latest.
Monitoring of climate-related disclosure adoption transferred to the IFRS Foundation, home of the International Sustainability Standards Board, from 2024.
The Foundation’s own account is that IFRS S2 is consistent with the four core recommendations and eleven recommended disclosures.
The IFRS Foundation still hosts the TCFD’s climate change supplement, and the standards themselves sit in its Sustainability Standards Navigator.
So “TCFD-aligned” in 2026 describes a disclosure shape that several UK rules require, not adherence to a maintained standard.
- Dec 2015Task Force created by the FSB
- Jun 2017Final Report
Four recommendations, eleven disclosures.
- Oct 2021Guidance updated
The recommendations themselves unchanged.
- Jun 2023IFRS S1 and S2 issued
Consistent with the TCFD recommendations.
- 12 Oct 2023Task Force disbanded
Monitoring passed on from 2024.
- 25 Feb 2026UK SRS S1 and S2 published
For voluntary use.
- 30 Sep 2026FCA PS26/19
UK SRS replaces TCFD for listed companies from 2027.
TCFD reporting requirements UK
Who must make TCFD-aligned disclosures today
Four separate UK regimes, four different populations — and only one of them is comply-or-explain.
| Regime | Who | Basis | Where |
|---|---|---|---|
| FCA listing rule, UKLR 6.6.6R(8) | Listed commercial companies, and via parallel rules the secondary listing, depositary receipt, non-equity share and transition categories | Comply or explain against the TCFD recommendations | Annual financial report |
| Companies Act ss.414CA–414CB | Companies with more than 500 employees that are traded, banking, insurance or AIM companies, or have turnover over £500m | Mandatory; reasoned omission only for four of the eight disclosures | Strategic report |
| LLP regulations, reg 12B | LLPs with more than 500 employees and turnover over £500m | Mandatory | The LLP’s energy and carbon report |
| FCA ESG sourcebook | Asset managers and asset owners with £5bn or more in assets, as a three-year rolling average | Mandatory entity and product reports | Published TCFD reports |
| SI 2021/839 | Trustees of large occupational pension schemes | Mandatory governance and reporting | A public TCFD report within seven months of the scheme year-end |
Section 414CA(4) switches the Companies Act duty off for any company with no more than 500 employees.
So a bank or insurer with 400 staff is outside it, and a private company needs both more than 500 employees and turnover over £500 million.
Section 414CB(A1) imposes the duty; subsection (2A) defines the disclosures as eight items, (a) to (h).
A company may leave out only items (e) to (h), and only with a reasoned explanation under subsections (4A) and (4B).
The listing rule has applied since accounting periods beginning on or after 1 January 2021 for what were then premium-listed commercial companies, and now sits in the UK Listing Rules; the FCA’s TN/802.3 maps the categories it reaches.
The Companies Act duty was inserted by SI 2022/31 for financial years beginning on or after 6 April 2022, and the government must publish its first review before 6 April 2027.
Government guidance on the climate-related financial disclosures for companies and LLPs and the earlier consultation on mandatory disclosures by publicly quoted companies explain the policy.
The asset manager rules were made by PS21/24; the FCA’s CP26/17 proposes removing the product-level TCFD reports, which remains a proposal.
Banks and insurers also work under the PRA’s supervisory expectations: its 2019 supervisory statement was replaced in December 2025 by SS5/25, and the Bank of England’s 2021 report on climate-related financial risk and capital set out its thinking; these are supervisory expectations, not disclosure duties.
The FCA’s climate change hub links its rules together.
Scenario analysis
Scenario analysis, without the mystique
The Strategy pillar asks for the resilience of the strategy under different climate-related scenarios, including a 2°C or lower scenario.
The TCFD did not prescribe a scenario set, a model or a time horizon, and UK SRS S2, which requires scenario analysis, does not mandate any particular scenario set either.
Many preparers draw on the reference scenarios published by the Network for Greening the Financial System, a network of central banks and supervisors whose technical working groups produce them.
The NGFS is not a standard-setter, and its scenarios are republished in vintages, so a disclosure should say which vintage it used.
A useful scenario exercise tests at least one orderly transition, one disorderly or delayed transition, and one high-warming physical-risk case against the business’s own time horizons.
Industry-specific metrics for the Metrics and Targets pillar are easiest to find through the SASB materiality finder, which the ISSB now maintains.
From TCFD to UK SRS
What changes from 2027
On 30 September 2026 the FCA published PS26/19, its final rules on listed companies’ sustainability disclosures.
They require listed companies in UKLR 6, 14, 15, 16 and 22 to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reporting in 2028.
The policy statement says, at paragraph 1.10, that “these rules will replace the existing TCFD aligned disclosures”.
UK SRS S2 is not mandatory under the final rules; the consultation, CP26/5, had proposed mandatory S2, and the FCA chose comply-or-explain instead.
A company may take a one-year relief from Scope 3 emissions and a two-year relief from non-climate disclosures under UK SRS S1, stating that it is doing so.
The UK SRS standards themselves were published by the Department for Business and Trade on 25 February 2026, and UK SRS S2 keeps the four pillars.
For the Companies Act duty, the government has confirmed in its consultation response that UK SRS S2 is a national reporting framework, so a company reporting under it need not duplicate its disclosures.
The standards are explained in the UK SRS standards, and our sister site covers UK SRS S2 in detail; the full UK SRS picture is at uksrs.org.uk.
FCA PS26/19, in brief
| Point | Final rule |
|---|---|
| Basis | Comply or explain, across all of UK SRS — S2 included |
| Categories | UKLR 6, 14, 15, 16 and 22 |
| From | Accounting periods beginning on or after 1 Jan 2027 |
| First reports | 2028 |
| Scope 3 relief | One year |
| UK SRS S1 relief | Two years, non-climate matters |
| Transition plan | Say whether you have one, and where |
| Assurance | Not required; if obtained, name provider, scope and standard |
Getting ready
From a TCFD report to a UK SRS report
Map what you disclose now
Line up your current TCFD statement against UK SRS S2 paragraph by paragraph.
Fix the governance record
Board oversight, management’s role and how climate enters the risk process.
Refresh the risk assessment
Risks and opportunities across the value chain, over your own short, medium and long term.
Re-run the scenarios
Name the scenario set and vintage, and connect the results to strategy and finance.
Build the emissions data
Gross Scope 1 and 2 now; Scope 3 during the relief year, before comply-or-explain bites.
Decide what to explain
Where you will not comply in the first year, write the explanation the rules ask for.
Energy and emissions data that already feeds Streamlined Energy and Carbon Reporting is the natural starting point for the metrics.
Many companies also answer investors through CDP, whose climate questionnaire follows the same structure but carries no regulatory status.
SRS Report is an independent reference, not a regulated firm; if it would help to talk your position through, book a free 15-minute call.
Further reading
Context from outside the rulebook
These organisations publish research and campaigns that often come up alongside TCFD work; they are context, not sources for any requirement on this page.
The Climate Disclosure Standards Board, one of the initiatives the ISSB says it builds on, published TCFD implementation material.
The Glasgow Financial Alliance for Net Zero publishes financial-sector transition material.
The Climate Policy Initiative tracks climate finance flows.
Climate Action 100+ reports on investor engagement with high-emitting companies.
Carbon Tracker publishes transition-risk analysis on fossil fuel reserves and carbon budgets.
Frequently asked
Questions people ask
Is TCFD reporting mandatory in the UK?
TCFD-aligned disclosure is required today in several UK regimes: the FCA listing rule for listed companies (on a comply-or-explain basis), the Companies Act climate-related financial disclosures for large companies and LLPs, the FCA ESG sourcebook for larger asset managers and asset owners, and the pensions regulations for large occupational pension schemes. The Task Force itself no longer exists; what is required is disclosure in its shape.
Does the TCFD still exist?
No. The Task Force on Climate-related Financial Disclosures fulfilled its remit and disbanded on 12 October 2023, alongside its final status report. Its website has not been updated or monitored since November 2023, and monitoring of company disclosures passed to the IFRS Foundation from 2024.
What are the four pillars of TCFD?
Governance, Strategy, Risk Management, and Metrics and Targets. Under those four recommendations sit eleven recommended disclosures: two for governance and three for each of the other pillars. Only the Strategy and Metrics and Targets recommendations carry the qualifier "where such information is material".
Which companies must make climate-related financial disclosures under the Companies Act?
For financial years beginning on or after 6 April 2022, the duty applies to a company with more than 500 employees that is a traded company, a banking company, an authorised insurance company, a company carrying on insurance market activity, an AIM company, or a company with turnover of more than £500 million. For a parent, the employee and turnover tests are applied to the group. Large LLPs have a parallel duty.
What replaces TCFD for listed companies?
The FCA’s final rules in PS26/19, published on 30 September 2026, require listed companies in scope to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reports in 2028. The FCA says these rules will replace the existing TCFD-aligned disclosures.
Is UK SRS S2 mandatory from 2027?
No. The FCA’s final rules adopt a comply-or-explain approach across UK SRS, including S2. A listed company in scope must report against UK SRS or explain why it has not, with a one-year relief for Scope 3 emissions and a two-year relief for non-climate disclosures under UK SRS S1.
What is the difference between TCFD and UK SRS S2?
UK SRS S2 is the UK endorsement of IFRS S2, published by the Department for Business and Trade on 25 February 2026. The IFRS Foundation says IFRS S2 is consistent with the four TCFD recommendations and eleven recommended disclosures, and it adds more specific requirements, including gross Scope 1, 2 and 3 emissions and industry-based metrics.
Does TCFD require scenario analysis?
The Strategy recommendation asks an organisation to describe the resilience of its strategy under different climate-related scenarios, including a 2°C or lower scenario. The TCFD did not prescribe which scenarios to use; many preparers draw on reference sets such as those published by the Network for Greening the Financial System.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.
- TCFDRecommendations of the Task Force on Climate-related Financial Disclosures — Final Report (June 2017), Figure 4
The four recommendations and eleven recommended disclosures.
- TCFDImplementing the Recommendations — October 2021 Annex
Updated guidance; GHG emissions to be disclosed independent of a materiality assessment.
- TCFDfsb-tcfd.org — the disbanding notice
Disbanded 12 October 2023; site not updated since November 2023.
- IFRS FoundationTCFD — the successor owner’s account
IFRS S2 is consistent with the four recommendations and eleven disclosures.
- FCAUK Listing Rules, UKLR 6.6 — annual financial report
UKLR 6.6.6R(8): the TCFD-aligned compliance statement.
- FCAPrimary Market Technical Note TN/802.3 (January 2026)
The listing categories the TCFD-aligned rule reaches.
- legislation.gov.ukCompanies Act 2006, section 414CA — who must include the statement
The categories, the £500m turnover test and the 500-employee floor.
- legislation.gov.ukCompanies Act 2006, section 414CB — the climate-related financial disclosures
(A1) the duty, (2A)(a)–(h) the eight disclosures, (4A) the reasoned-omission relief.
- legislation.gov.ukSI 2022/31 — The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022
Financial years beginning on or after 6 April 2022; first review report before 6 April 2027.
- FCAESG sourcebook, ESG 2.3 — TCFD entity and product reports
The asset manager and asset owner rules and their metrics.
- FCAPS21/24: Enhancing climate-related disclosures by asset managers, life insurers and FCA-regulated pension providers
The policy statement that made the ESG sourcebook rules.
- FCACP26/17: Quarterly Consultation Paper No. 52, chapter 2
Proposes removing TCFD product reporting; closed 13 July 2026.
- legislation.gov.ukSI 2021/839 — Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021
Trustee duty; report within seven months of the scheme year-end.
- FCAPS26/19: Aligning listed issuers’ sustainability disclosures with international standards
Final rules, 30 September 2026.
- FCAPS26/19 (PDF), ¶¶1.2, 1.10, 3.6, 3.12, 3.14
Comply or explain; replaces the TCFD-aligned disclosures; scope, commencement and reliefs.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026, for voluntary use.
- Department for Business and TradeUK SRS exposure drafts — consultation response, chapter 3
UK SRS S2 is a national reporting framework under s.414CB(6).
- NGFSNetwork for Greening the Financial System
Publisher of reference climate scenarios; not a standard-setter.