TCFD reporting · UK duties

TCFD reporting in the UK: who still reports, and until when

TCFD reporting outlived the Task Force: it disbanded in October 2023, but four UK instruments still require climate disclosure built on its framework.

For listed companies that ends with accounting periods beginning on or after 1 January 2027, when the FCA’s final rules replace the TCFD listing rule with UK SRS.

For companies under the Companies Act, asset managers and pension trustees, it continues.

Who still reports →The eleven disclosures

The framework

Four recommendations, eleven disclosures

The Final Report nests eleven recommended disclosures under four recommendations. The wording below is the Task Force’s, shortened only where marked.

Source: TCFD Final Report, Figure 4, p. 14 · fsb-tcfd.org/recommendations
Pillar	Recommendation	Recommended disclosures
Governance	Disclose the organisation's governance around climate-related risks and opportunities	a) the board's oversight · b) management's role in assessing and managing them
Strategy	Disclose actual and potential impacts on businesses, strategy and financial planning "where such information is material"	a) risks and opportunities over the short, medium and long term · b) their impact on businesses, strategy and financial planning · c) resilience of the strategy "taking into consideration different climate-related scenarios, including a 2°C or lower scenario"
Risk management	Disclose how the organisation identifies, assesses and manages climate-related risks	a) processes for identifying and assessing · b) processes for managing · c) integration into overall risk management
Metrics and targets	Disclose the metrics and targets used "where such information is material"	a) metrics used in line with strategy and risk management · b) Scope 1, Scope 2 and, "if appropriate", Scope 3 emissions · c) targets and performance against them

Two plus three plus three plus three makes eleven, and people who quote “eleven recommendations” mean these disclosures.

Our sister site has a plain-English explainer of the four pillars of sustainability reporting that grew out of this structure.

The materiality qualifier is deliberately uneven: it sits on strategy and on metrics and targets, not on governance or risk management.

The Task Force’s October 2021 Annex changed the guidance, not the eleven, and asked organisations to disclose GHG emissions independent of a materiality assessment.

It published separate guidance on metrics, targets and transition plans in the same month.

The ISSB’s climate standard carries the same four pillars forward, which is why the line-by-line map on TCFD vs UK SRS finds a home for every disclosure.

Who reports

Four UK duties built on TCFD

None of these duties comes from the Task Force. Each is a UK instrument that borrowed its structure.

Sources: FCA PS26/19 · CA 2006 s.414CA · ESG 1A.1 · SI 2021/839
Duty	Who	Instrument	Status from 2027
Listing rule statement	Listed companies in UKLR 6, 14, 15, 16 and 22	UKLR 6.6.6R(8) and equivalents	Replaced by UK SRS, comply or explain, for periods beginning on or after 1 Jan 2027
Climate-related financial disclosures	Large traded, banking, insurance and AIM companies, and companies with turnover over £500m — all with more than 500 employees; large LLPs	CA 2006 ss.414CA–414CB; SI 2022/31 and SI 2022/46	Continues; under post-implementation review
TCFD entity report	FCA asset managers and asset owners at or above £5bn	ESG sourcebook, ESG 1A and ESG 2	Continues; product-level rules simplified on 25 Sep 2026
Pension scheme TCFD report	Occupational schemes with £1bn or more, master trusts and CDC schemes	SI 2021/839	Continues; DWP review to consider UK SRS

When the Companies Act duty was announced on 29 October 2021, the government estimated that “over 1,300 of the largest UK-registered companies and financial institutions” would have to disclose.

That is the government’s estimate at announcement, not a count of reporters today.

Banks and insurers are not caught by an asset threshold: they come in through the banking-company and insurance-company limbs of section 414CA, subject to the same 500-employee floor.

The £5bn figure belongs to a different regime, the FCA’s exemption for asset managers and asset owners in ESG 1A.1.2R.

The PRA’s expectations of banks and insurers are about managing climate risk, not publishing a TCFD report: SS5/25 replaced the 2019 statement, SS3/19, in its entirety on 3 December 2025.

The wider map of what UK companies must report, beyond climate, is on ESG reporting requirements in the UK and carbon reporting requirements in the UK.

The statutory duty

The eight Companies Act disclosures, pillar by pillar

The statutory version of TCFD reporting is eight disclosures in section 414CB(2A) of the Companies Act 2006.

They apply for financial years beginning on or after 6 April 2022, under SI 2022/31, with a parallel regime for LLPs in SI 2022/46.

Unlike the TCFD framework, the eight disclosures do not name Scope 1, 2 or 3 emissions; for many of the same companies, greenhouse gas figures are reported through SECR instead.

Directors may omit all or part of disclosures (e) to (h) if they reasonably believe it is not necessary for an understanding of the business, but they must give “a clear and reasoned explanation” (s.414CB(4A)–(4B)).

Disclosures (a) to (d) have no such route.

Section 414CB(6) lets a company meet the requirements through a national, EU-based or international framework, and the government has confirmed UK SRS S2 is one.

The government’s guidance on the 2022 Regulations remains the official explainer for in-scope companies and LLPs.

SECR, which carries the energy and emissions numbers, is covered on streamlined energy and carbon reporting.

Source: CA 2006 s.414CB(2A), as inserted by SI 2022/31 reg 4
s.414CB(2A)	Disclosure	TCFD pillar
(a)	Governance arrangements for climate risks and opportunities	Governance
(b)	How they are identified, assessed and managed	Risk management
(c)	Integration into overall risk management	Risk management
(d)	Principal risks and opportunities and the time periods used	Strategy
(e)	Actual and potential impacts on business model and strategy	Strategy
(f)	Resilience analysis under different climate-related scenarios	Strategy
(g)	Targets and performance against them	Metrics and targets
(h)	KPIs used to assess progress, and their calculations	Metrics and targets

Asset managers, life insurers, pensions

TCFD in the investment chain after 25 September 2026

The FCA brought asset managers and asset owners into TCFD reporting through PS21/24, published on 17 December 2021.

Its rules applied from 1 January 2022 for the largest firms and a year later for smaller firms above the £5bn threshold, with first disclosures due by 30 June 2023.

The entity-level TCFD report survives in ESG 2.2.1R.

The product-level regime changed on 25 September 2026, when FCA 2026/59 came into force.

The five-metric requirement for product reports is gone; firms now consider whether climate risk is materially relevant to each product and put identified risks into retail communications, and supply Scope 1, 2 and 3 data to clients on request (ESG 2.3.1BR and 2.3.5AR).

No financed-emissions method is mandated by the FCA; PCAF publishes one such accounting standard, and the financial services guide sets out how UK SRS S2 treats it.

Occupational pension trustees are on a separate statutory footing: SI 2021/839 requires TCFD-aligned governance, scenario analysis, metrics and a published report.

Its penalty for failing to publish is mandatory, with a floor of £2,500 (reg 9(2) and (4)).

£5bn

ESG sourcebook exemption, 3-year rolling average (ESG 1A.1.2R)

30 Jun 2023

first entity-level disclosures due (PS21/24)

£1bn

pension scheme threshold from 1 Oct 2022 (SI 2021/839)

7 months

to publish a pension TCFD report after scheme year-end

Preparing a TCFD-aligned report

What each pillar needs in practice

A working order for a first report. Each card links to the page on this site that goes deeper.

Governance

Name who oversees climate risk

Board oversight and management’s role are the two governance disclosures; board oversight under UK SRS shows the more detailed version UK SRS S2 asks for.

Strategy

Test resilience with scenarios

Strategy c) asks for resilience “including a 2°C or lower scenario”; how to run climate scenario analysis walks through the method, using public sets such as the NGFS scenarios.

Metrics

Measure emissions under the GHG Protocol

The GHG Protocol is the measurement basis, applied with the government conversion factors; see UK emission factors and Scope 3 emissions reporting.

Targets

Set and track targets

Targets can be validated by the Science Based Targets initiative; science-based targets explains the route, and transition plans in the UK covers the plan behind them.

Industry-specific metrics can be drawn from the SASB Standards, which the ISSB now maintains.

The former Climate Disclosure Standards Board, whose TCFD guidance many first reports used, was consolidated into the IFRS Foundation on 31 January 2022.

CDP’s 2026 disclosure cycle is a separate, voluntary disclosure route, covered on CDP reporting.

GRI is a different framework again, and UK SRS S1 lists it only as a source an entity may consult (Appendix C).

Software that pulls the data together is compared on carbon reporting software, and the frameworks side by side on carbon reporting frameworks.

Boundaries

What a TCFD report does not cover

A TCFD-aligned report is a disclosure about climate risk to the business, so it does not discharge operational duties that sit beside it.

It is not an energy audit: large undertakings still need ESOS, covered on ESOS Phase 4.

It is not the SECR energy and emissions disclosure, which follows the government’s environmental reporting guidelines and is set out on SECR thresholds.

It is not a nature disclosure; biodiversity net gain is a planning duty, and nature-related reporting is on biodiversity reporting.

It is not a management-system certificate such as ISO 14001, and it is not a carbon neutrality claim, which is the subject of ISO 14068 carbon neutrality.

It is also not a UK SRS report, though the two share their architecture; see UK SRS S2 climate disclosures.

Until when

The TCFD duties and their review dates

The listing rule has an end date; the other three duties have review dates, and no decision has been published on any of them.

PS26/19 ¶1.10 says the new listing rules “will replace the existing TCFD aligned disclosures”.

For the Companies Act duty, SI 2022/31 reg 5(2) requires the first review report to be published before 6 April 2027.

The Modernising corporate reporting consultation says it makes no proposals on the CFD requirements and that the post-implementation review is due by spring 2027.

The same consultation says the government will consider how UK SRS should be reflected in the Companies Act 2006, without a proposal or a date (¶¶154–155).

For pensions, the government said in June 2025 that DWP would review the regulations and consider the role of UK SRS; we hold no record of an outcome.

For your own listing-rule date by year-end, see the UK SRS deadline, and for every milestone, the UK SRS timeline.

Dates that move the picture

25 Sep 2026
FCA 2026/59 in force
Product-level TCFD reporting simplified.
30 Sep 2026
PS26/19 published
UK SRS to replace the TCFD listing rule.
30 Nov 2026
MCR consultation closes
Makes no proposal on the CFD duty.
1 Jan 2027
UK SRS rules in force
For accounting periods beginning on or after this date.
Before 6 Apr 2027
CFD review report due
SI 2022/31 reg 5(2).
Spring 2027
CFD post-implementation review
Due to be completed, per the MCR consultation.

Help, consultants and certification

Getting help with TCFD reporting

No organisation can certify a report as “TCFD compliant” on the Task Force’s behalf, because the Task Force issued recommendations and has disbanded.

What exists is third-party assurance over disclosures, and under the FCA’s new rules a listed company says whether it obtained any; see sustainability assurance in the UK.

Consultancy support for TCFD and UK SRS work is available from a network of independent specialists, compared on sustainability consultancy and ESG consulting.

The UK’s route from TCFD to ISSB-based standards ran through the UK Sustainability Disclosure Technical Advisory Committee, whose secretariat the FRC provides, and the ISSB.

The standards themselves are on GOV.UK’s UK SRS guidance and the publication page, and the consultation that led to the FCA rules is CP26/5.

You can book a free 15-minute call to talk through which of these duties applies to you.

Frequently asked

TCFD reporting — frequently asked

What is TCFD reporting?

TCFD reporting is climate-related disclosure structured on the recommendations of the Task Force on Climate-related Financial Disclosures: four pillars (governance, strategy, risk management, and metrics and targets) and eleven recommended disclosures, published in the Task Force's June 2017 Final Report. The Task Force disbanded in October 2023, but UK law and regulation still require several kinds of organisation to report on this basis.

Is TCFD reporting mandatory in the UK?

For some organisations, yes, through UK instruments rather than the TCFD itself. Large companies and LLPs make climate-related financial disclosures under section 414CB of the Companies Act 2006; FCA-regulated asset managers and asset owners above a £5bn threshold publish an entity-level TCFD report; large occupational pension schemes publish TCFD reports under SI 2021/839. Listed companies make a TCFD-aligned comply-or-explain statement until their accounting periods beginning on or after 1 January 2027, when UK SRS replaces it.

Who must report TCFD in the UK?

Under the Companies Act, traded companies, banking companies, authorised insurance companies, companies carrying on insurance market activity, AIM companies and companies with turnover of more than £500 million, in each case with more than 500 employees and not small or medium-sized. Under the FCA ESG sourcebook, asset managers and asset owners with £5bn or more of in-scope assets on a three-year rolling average. Under SI 2021/839, trustees of occupational pension schemes with £1bn or more of relevant assets, and authorised master trusts and CDC schemes. When the rules were announced in October 2021 the government estimated that over 1,300 of the largest UK-registered companies and financial institutions would be caught by the Companies Act and related duties.

What are the 11 TCFD recommendations?

Strictly, there are four recommendations and eleven recommended disclosures beneath them. Governance: board oversight; management's role. Strategy: risks and opportunities over the short, medium and long term; their impact on businesses, strategy and financial planning; resilience of the strategy under different climate-related scenarios, including a 2°C or lower scenario. Risk management: processes for identifying and assessing risks; processes for managing them; integration into overall risk management. Metrics and targets: the metrics used; Scope 1, Scope 2 and, if appropriate, Scope 3 emissions; the targets used and performance against them.

Is there a TCFD certification?

The Task Force issued voluntary disclosure recommendations, not a certifiable standard, and it disbanded in October 2023, so no status can be conferred by it. What an organisation can obtain is third-party assurance over its climate disclosures, against an assurance standard such as ISSA (UK) 5000. Listed companies must say whether they obtained assurance under the FCA's new rules, but assurance itself is not required.

Do banks and insurers have to report TCFD?

Banking companies and authorised insurance companies with more than 500 employees are within the Companies Act climate-related financial disclosure duty. Separately, the PRA's supervisory statement SS5/25, which replaced SS3/19 on 3 December 2025, sets expectations for how banks and insurers manage climate-related risks. Life insurers are also asset owners under the FCA ESG sourcebook in respect of their investment products.

Does TCFD require Scope 3 emissions?

The Final Report asks for Scope 1, Scope 2 and, "if appropriate", Scope 3 greenhouse gas emissions. The October 2021 update asked organisations to disclose GHG emissions independent of a materiality assessment. UK SRS S2, which replaces the TCFD listing rule from 2027, requires Scope 3 measured under the GHG Protocol, subject to a relief that the FCA limits to one year for listed companies.

When does TCFD reporting end for listed companies?

The TCFD-aligned listing rule governs accounting periods beginning before 1 January 2027. For periods beginning on or after that date, listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS on a comply-or-explain basis, with first reports in 2028. A company may adopt UK SRS early and keep the transitional reliefs.

When is the TCFD report due?

It depends on the regime. Companies Act disclosures sit in the strategic report, so they follow the annual report; a listed issuer must publish its annual financial report within four months of year-end under DTR 4.1.3R. Pension trustees publish within seven months of the scheme year-end. FCA asset managers and asset owners publish their entity report annually under the ESG sourcebook.

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.

Checked against 19 sources fromTCFDlegislation.gov.ukDepartment for Business, Energy & Industrial StrategyGOV.UKFinancial Conduct AuthorityFCA Handbook

TCFD
Recommendations of the TCFD — Final Report (June 2017), Figure 4
The four recommendations and eleven recommended disclosures, verbatim.
TCFD
fsb-tcfd.org (frozen archive)
"The TCFD has fulfilled its remit and disbanded"; not updated since November 2023.
TCFD
Implementing the Recommendations — October 2021 Annex, §A.1
Recommendations and disclosures unchanged; GHG emissions to be disclosed independent of materiality.
TCFD
Guidance on Metrics, Targets, and Transition Plans (October 2021)
The Task Force's guidance on metrics, targets and transition plans.
legislation.gov.uk
Companies Act 2006, section 414CA (who is in scope)
s.414CA(1), (1A), (2A), (3), (4): the company types, the £500m turnover limb and the 500-employee floor.
legislation.gov.uk
Companies Act 2006, section 414CB(2A), (4A)–(4B), (6)
The eight climate-related financial disclosures, the omission route for (e)–(h) and the national-framework route.
legislation.gov.uk
SI 2022/31 — Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022
Commencement for financial years beginning on or after 6 April 2022; review report before 6 April 2027 (reg 5(2)).
Department for Business, Energy & Industrial Strategy
Climate-related financial disclosures for companies and LLPs — guidance
The government's guidance on the 2022 Regulations for companies and LLPs.
GOV.UK
UK to enshrine mandatory climate disclosures for largest companies in law (29 October 2021)
"over 1,300 of the largest UK-registered companies and financial institutions" — the government's estimate at announcement.
Financial Conduct Authority
PS21/24 — climate-related disclosures by asset managers, life insurers and FCA-regulated pension providers
Rules from 1 January 2022 for the largest firms and a year later above the £5bn threshold; first disclosures by 30 June 2023.
FCA Handbook
ESG 1A.1 — application and the £5bn exemption
ESG 1A.1.2R: exempt below £5bn on a three-year rolling average.
FCA Handbook
ESG 2.2 — TCFD entity report
ESG 2.2.1R, last updated 25 September 2026.
Financial Conduct Authority
Handbook Notice 144 (September 2026)
FCA 2026/59, in force 25 September 2026, simplified product-level TCFD reporting.
Financial Conduct Authority
PS26/19: Aligning listed issuers' sustainability disclosures with international standards (PDF)
¶1.10 (replaces the TCFD-aligned disclosures), ¶3.19 (periods beginning before 1 January 2027), Appendix 1.
FCA Handbook
UKLR 6.6 — annual financial report (commercial companies)
UKLR 6.6.6R(8): the TCFD-aligned statement for commercial companies, live until the new rules apply.
legislation.gov.uk
SI 2021/839 — Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021
Scheme thresholds, the seven-month publication deadline and the reg 9 penalties.
Bank of England (PRA)
PS25/25 and SS5/25 — managing climate-related risks
SS5/25 replaced SS3/19 in its entirety on 3 December 2025.
Climate Disclosure Standards Board
CDSB (consolidated into the IFRS Foundation)
CDSB was consolidated into the IFRS Foundation on 31 January 2022.
FCA Handbook
DTR 4.1 — annual financial report
DTR 4.1.3R: annual financial report public within four months of year-end.