TCFD vs UK SRS: what changes, and who keeps TCFD

For listed companies, yes. The FCA's final rules in PS26/19, published on 30 September 2026, say the new rules "will replace the existing TCFD aligned disclosures". Listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027. The TCFD-aligned statement still governs their accounting periods beginning before that date. Other TCFD-based duties, such as the Companies Act climate-related financial disclosures and the FCA's entity-level reports for asset managers, are not replaced by PS26/19.

Several UK duties are still built on TCFD. Large companies and LLPs make eight climate-related financial disclosures under section 414CB of the Companies Act 2006. FCA-regulated asset managers and asset owners above the £5bn exemption produce an entity-level TCFD report under the ESG sourcebook. Trustees of large occupational pension schemes publish TCFD reports under SI 2021/839. Listed companies keep the TCFD-aligned listing rule only for accounting periods beginning before 1 January 2027.

TCFD is the Task Force's 2017 framework of four recommendations and eleven recommended disclosures, published as voluntary recommendations. CFD, climate-related financial disclosure, is the UK statutory duty in section 414CB of the Companies Act 2006, which lists eight disclosures closely modelled on the TCFD pillars. CFD is law for the companies it catches; TCFD is the framework behind it.

No. The TCFD published its final status report on 12 October 2023 and disbanded. The FSB asked the IFRS Foundation to take over monitoring of companies' climate-related disclosures from 2024. Its website remains online as a frozen archive that is no longer updated.

Yes, as a structure. IFRS S2, and so UK SRS S2, keeps the four TCFD pillars and is consistent with the eleven recommended disclosures, and the IFRS Foundation says companies applying IFRS S1 and S2 will meet the TCFD recommendations. Several UK statutory and regulatory duties are still expressed in TCFD terms. What has ended is the Task Force itself and, from 2027, the TCFD-aligned listing rule.

From accounting periods beginning on or after 1 January 2027, a listed company in scope either makes climate disclosures in accordance with UK SRS S2 or explains which requirements are not met, why, and what steps it is taking. It also reports against UK SRS S1 for wider sustainability matters, with a two-year relief, and has a one-year Scope 3 relief. The basis is comply or explain throughout; nothing becomes mandatory.

A TCFD report is a strong start, because the four pillars carry over. The gaps usually sit where UK SRS S2 is more specific: the per-risk classification of physical and transition risk, time horizons tied to planning horizons, current and anticipated financial effects, the scenario-analysis inputs listed in paragraph 22(b), Scope 3 measured under the GHG Protocol, the seven cross-industry metric categories, and target detail including any planned use of carbon credits.

The government confirmed in February 2026 that UK SRS S2 is a national reporting framework for section 414CB(6) of the Companies Act 2006. A company reporting in accordance with UK SRS S2 therefore does not need to duplicate its disclosures to meet section 414CB(2A). The statement must name the framework used.