Climate transition plans · UK position
Climate transition plans in the UK: who must have one, and what to disclose
No UK law requires a company to have a climate transition plan, and the FCA’s final rules of 30 September 2026 say in terms that they do not require listed companies to produce one.
What they require, from accounting periods beginning on or after 1 January 2027, is a statement: whether a plan is published, where, or why not.
This page covers that statement, what UK SRS S2 asks about a plan you have, the archived TPT framework, and the government’s unanswered consultation.
The short answer
Three disclosure hooks, no duty to plan
The FCA’s response in PS26/19 is unambiguous: “We are not requiring listed companies to produce transition plans. Nor are we introducing requirements for the location of transition plans.”
UK SRS S2 ¶14(a)(iv) asks for information about “any climate-related transition plan the entity has”, including key assumptions and the dependencies the plan relies on.
That is a conditional duty: it describes a plan that exists, and creates none.
The IFRS Foundation’s own June 2025 guidance says the same of IFRS S2, which “does not require an entity to have a transition plan nor require an entity to publish a transition plan as long as the requirements in IFRS S2 are met”.
Pension trustees are the sharpest contrast: SI 2021/839 imposes a mandatory reporting duty with a floored penalty, and no duty to plan.
The one live proposal to change this is the government’s 2025 consultation, covered below.
| Instrument | What it asks | A duty to have a plan? |
|---|---|---|
| UK SRS S2 ¶14(a)(iv) | Information about any transition plan the entity has | No |
| UKLR 6.6.6R(8)(e) | Whether a plan is published, where, or why not | No |
| CA 2006 s.414CB(2A) | Eight climate disclosures; none names a transition plan | No |
| SI 2021/839 (pensions) | TCFD-aligned governance and reporting | No |
Listed companies from 2027
The UKLR 6.6.6R(8)(e) statement, line by line
The made rule asks “whether the listed company has published a climate-related transition plan (in its annual financial report or elsewhere)”.
If it has, the statement gives the location of the plan.
If it has not, the statement explains “why the listed company has not done so”.
It applies to accounting periods beginning on or after 1 January 2027, with first reports in 2028, alongside the UK SRS comply-or-explain limbs in UKLR 6.6.6R(7A) and (7B).
It is not one of the transitional reliefs: a company using the Scope 3 or climate-first relief must still meet the requirements on location, transition plans and assurance (PS26/19 ¶3.20).
The FCA also confirmed its guidance as consulted on, which points a company that publishes a plan to the IFRS Foundation’s transition-disclosure guidance as a resource it may wish to use.
The statement sits beside two others in UKLR 6.6.6R(8): where the disclosures are, and whether assurance was obtained, which is covered on sustainability assurance in the UK.
How the new rules work as a whole is on UK SRS and the FCA, and how to write the “why not” is close kin to a UK SRS explanation.
Listed companies in UKLR 6 (commercial companies), UKLR 16 (non-equity and non-voting equity shares) and UKLR 22 (transition).
Not secondary listings (UKLR 14) or depositary receipt issuers (UKLR 15), which the FCA left out of scope for this statement.
FCA PS26/19, response to Questions 8–9 and Appendix 1
Definitions
What counts as a transition plan
UK SRS S2 defines a climate-related transition plan as “an aspect of an entity’s overall strategy that lays out the entity’s targets, actions or resources for its transition towards a lower-carbon economy, including actions such as reducing its greenhouse gas emissions” (Appendix A).
Two things follow from that wording.
A plan is part of strategy, not a separate sustainability document, which is why UK SRS S2 places it in the strategy pillar at ¶14.
And the definition uses “or”: targets, actions or resources, so a set of targets with no costed actions still falls to be described.
The IFRS Foundation’s guidance adds a limit on its own scope: it “does not provide guidance on the transition planning process—for example, how to develop a transition plan”.
The TCFD’s 2021 guidance on metrics, targets and transition plans remains a reference, and the FCA tells ESG sourcebook firms that the TCFD guidance “makes recommendations on transition plans”.
If you have a plan
What UK SRS S2 asks you to say about it
These paragraphs apply to an entity reporting against UK SRS S2, and for listed companies from 2027 they sit inside the comply-or-explain limb.
| UK SRS S2 | Disclosure |
|---|---|
| ¶14(a)(i)–(iii) | Current and anticipated changes to the business model, and direct and indirect mitigation and adaptation efforts |
| ¶14(a)(iv) | Any climate-related transition plan, with its key assumptions and dependencies |
| ¶14(a)(v) | How the entity plans to achieve its climate-related targets, including GHG targets |
| ¶14(b) | How the entity is resourcing, and plans to resource, those activities |
| ¶14(c) | Quantitative and qualitative progress on plans disclosed in previous periods |
| ¶33 | Each target: metric, objective, scope, period, base period, milestones, absolute or intensity, and how the latest international agreement informed it |
| ¶34 | Whether the target and its methodology were validated by a third party; review process; revisions |
| ¶36 | For GHG targets: gases, scopes, gross or net, sectoral decarbonisation approach, and the planned use of carbon credits |
The carbon-credit questions are specific: how far a net target relies on credits, which scheme verifies them, whether they are nature-based or technological removals, and whether they come from reduction or removal (¶36(e)).
A net target must be accompanied by the associated gross target (¶36(c)).
A plan’s key assumptions should be the ones the scenario analysis tests; see climate scenario analysis under UK SRS S2 and, for method, the scenario analysis guide.
The emissions baseline a plan starts from is built on Scope 3 reporting and the UK emission factors.
The proposed mandate
The government’s consultation, still unanswered
The consultation on climate-related transition plan requirements ran from 25 June to 17 September 2025.
Its implementation routes document records the government’s manifesto commitment to mandate UK-regulated financial institutions and FTSE 100 companies to develop and implement credible transition plans aligned with the 1.5°C goal.
It then “seeks views on how” that could be done, and sets out two options.
Option 1 would require entities to explain why they have not disclosed a transition plan or transition plan-related information.
Option 2 would require entities to develop and disclose transition plans.
The same document says UK SRS S2 “will not require an entity to have a transition plan”.
When re-checked on 28 September 2026 the page still said “We are analysing your feedback”, with no outcome document.
The FCA’s earlier consultation drew the line the final rules keep: mandating that companies have transition plans “is a matter for Government” (CP26/5 ¶1.7).
Where it stands
- 25 Jun 2025Consultation opens
Alongside the UK SRS exposure drafts and the assurance consultation.
- 17 Sep 2025Consultation closes
Two options on the table.
- 28 Sep 2026Last check of GOV.UK
"We are analysing your feedback" — no outcome.
- 30 Sep 2026FCA final rules
"Not requiring listed companies to produce transition plans."
The TPT framework
The Transition Plan Taskforce, archived
The TPT framework is the most cited structure for a UK transition plan. It is voluntary, it is archived, and its authors no longer exist as a body.
Ambition · Action · Accountability
The guiding principles the Disclosure Framework applies; the 2022 draft defined the same words differently, so quote the final.
Foundations · Implementation Strategy · Engagement Strategy · Metrics & Targets · Governance
Divided into 19 sub-elements, each with an "an entity shall disclose" statement.
IFRS Foundation Knowledge Hub · ITPN
The IFRS Foundation hosts 13 disclosure resources under an accuracy disclaimer; the ITPN holds the process guidance.
The TPT Disclosure Framework was published in October 2023, and the Taskforce completed its work and disbanded in October 2024.
Its disclosure materials are on the IFRS Sustainability Knowledge Hub, which states: “The IFRS Foundation is not responsible for its accuracy.”
The Hub also carries the final Sector Summary, covering 30 financial and real-economy sectors, sector guidance and mappings to TCFD, IFRS S2 and ESRS.
The International Transition Plan Network took on the TPT’s other legacy content, including guidance on the planning process.
“TPT-aligned” is therefore a voluntary self-description, and the IFRS Foundation’s guidance “does not add to or otherwise change the requirements in IFRS S2”.
Easily confused
Carbon reduction plans, SBTi and the EU
| Instrument | What it is | Relation to a transition plan |
|---|---|---|
| PPN 006 carbon reduction plan | A condition of participation for central government contracts over £5m a year (VAT-inclusive, averaged over the contract) | A narrower document: Scope 1, 2 and five Scope 3 categories, and a net zero by 2050 commitment |
| SBTi Corporate Net-Zero Standard V2.0 | Published 11 June 2026; validations open 1 February 2027 | Target validation, which UK SRS S2 ¶34(a) asks you to disclose if obtained |
| CSDDD Article 22 | The EU duty to adopt and put into effect a transition plan | Deleted by Directive (EU) 2026/470 |
| ESRS E1 (revised) | Climate disclosure for undertakings in CSRD scope | No plan: disclose that fact and whether and when one is expected |
PPN 006 binds contracting authorities, not companies at large: a supplier needs a carbon reduction plan only when bidding for an in-scope contract above the threshold.
The SBTi’s V2.0 standard is published but not yet usable for validation, and V1.3.1 remains open to 31 January 2028.
For UK groups with EU operations, the substantive EU transition-plan duty has gone: Directive (EU) 2026/470 provides that “Article 22 is deleted”.
Reporting survives in ESRS E1 for undertakings in CSRD scope.
Targets are covered on science-based targets, and the wider route to net zero on net zero consultancy.
Consultancy capability exists to draft or review a plan, and you can book a free 15-minute call to talk through yours.
Frequently asked
Transition plans — frequently asked
Is a climate transition plan mandatory in the UK?
No. No UK law requires a company to have, implement or publish a climate transition plan. The government consulted on transition plan requirements from 25 June to 17 September 2025, and as last checked on 28 September 2026 it had published no outcome. The FCA's final rules say in terms: "We are not requiring listed companies to produce transition plans."
What must listed companies disclose about transition plans from 2027?
Under UKLR 6.6.6R(8)(e), made by PS26/19, a listed company states whether it has published a climate-related transition plan, in its annual financial report or elsewhere. If it has, it says where the plan can be found; if it has not, it says why not. The statement applies to accounting periods beginning on or after 1 January 2027 for companies in the commercial companies, non-equity and non-voting shares and transition categories (UKLR 6, 16 and 22), not to secondary listings or depositary receipts.
Does UK SRS S2 require a transition plan?
No. UK SRS S2 paragraph 14(a)(iv) requires information about "any climate-related transition plan the entity has", including its key assumptions and dependencies. It is a duty to describe a plan you have, not a duty to have one.
What is a climate transition plan?
UK SRS S2 defines a climate-related transition plan as "an aspect of an entity's overall strategy that lays out the entity's targets, actions or resources for its transition towards a lower-carbon economy, including actions such as reducing its greenhouse gas emissions".
What is the TPT framework?
The Transition Plan Taskforce Disclosure Framework, published in October 2023, organises transition plan disclosure around three guiding principles (Ambition, Action and Accountability) and five elements (Foundations, Implementation Strategy, Engagement Strategy, Metrics and Targets, and Governance), divided into 19 sub-elements. The TPT disbanded in October 2024. Its disclosure materials are hosted by the IFRS Foundation, which says it is not responsible for their accuracy, and its process guidance passed to the International Transition Plan Network.
Is the Transition Plan Taskforce still active?
No. The TPT completed its work and disbanded in October 2024. The IFRS Foundation assumed responsibility for 13 of its disclosure resources, and the International Transition Plan Network took on its other legacy content, including guidance on the transition planning process. The framework is archived voluntary guidance, not a standard and not law.
What is the difference between a transition plan and a carbon reduction plan?
A carbon reduction plan is a procurement document: under PPN 006, central government bodies ask bidders for contracts worth more than £5 million a year for one, covering Scope 1 and 2 emissions, five Scope 3 categories and a commitment to net zero by 2050. A transition plan is part of an entity's overall strategy and is described in its annual report where it exists.
Does a transition plan need Science Based Targets validation?
No. Nothing in UK law or UK SRS requires validation. UK SRS S2 paragraph 34(a) asks whether each target and its methodology has been validated by a third party, so a company says whether it has, not that it must. The SBTi's Corporate Net-Zero Standard V2.0 was published on 11 June 2026 and validations under it open on 1 February 2027.
Does the EU require transition plans from UK companies?
The CSDDD's transition-plan duty, Article 22, has been deleted by Directive (EU) 2026/470. Transition-plan reporting survives inside CSRD for undertakings in its scope, where the revised ESRS E1 asks a company without a plan to say so and whether, and when, it expects to adopt one.
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.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (PDF)
¶14(a)(iv) (any transition plan the entity has), ¶14(b)–(c) (resourcing and progress), ¶¶33–36 (targets, validation, carbon credits), Appendix A (definition).
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards (PDF)
Appendix 1: UKLR 6.6.6R(8)(e); the response after ¶2.44 ("We are not requiring listed companies to produce transition plans"); response to Q8–9 (UKLR 14 and 15 out of scope for this statement).
- Financial Conduct AuthorityPS26/19 landing page
First published 30 September 2026: comply or explain across UK SRS; Technical Note feedback by 28 October 2026; FCA webinar on 19 October 2026; supervisory information in the second half of 2027.
- GOV.UK (DESNZ)Climate-related transition plan requirements — consultation
Ran 25 June – 17 September 2025; "We are analysing your feedback" when re-checked on 28 September 2026.
- GOV.UK (DESNZ)Transition plan requirements: implementation routes
The manifesto commitment, and Option 1 (explain why not) versus Option 2 (develop and disclose).
- IFRS FoundationDisclosing information about an entity's climate-related transition… in accordance with IFRS S2 (June 2025)
IFRS S2 "does not require an entity to have a transition plan"; the guidance "does not add to or otherwise change the requirements in IFRS S2".
- Transition Plan Taskforce (archived by the IFRS Foundation)TPT Disclosure Framework (October 2023)
Three guiding principles, five elements, 19 sub-elements.
- IFRS FoundationTransition Plan Taskforce resources — Knowledge Hub
"The IFRS Foundation is not responsible for its accuracy"; Sector Summary (30 sectors), sector guidance and mappings.
- International Transition Plan NetworkITPN
Holds the TPT's legacy guidance on the transition planning process.
- TCFDGuidance on Metrics, Targets, and Transition Plans (October 2021)
Section E on transition plans; referred to by the FCA for ESG sourcebook firms.
- Financial Conduct AuthoritySustainability reporting requirements
ESG sourcebook firms take reasonable steps to reflect TCFD guidance, "which makes recommendations on transition plans".
- Cabinet OfficePPN 006 — Carbon Reduction Plans in major government contracts
Over £5m a year per contract; Scope 1, 2 and five Scope 3 categories; net zero by 2050 commitment.
- Science Based Targets initiativeCorporate Net-Zero Standard V2.0 — criteria
Published 11 June 2026; validations open 1 February 2027; V1.3.1 open to 31 January 2028.
- EUR-LexDirective (EU) 2026/470 (Omnibus I), Article 4(16)
"Article 22 is deleted" — the CSDDD transition-plan duty.
- EFRAGSimplified ESRS E1 — delegated act rendering
An undertaking without a transition plan discloses that fact and whether, and when, it expects to adopt one.
- legislation.gov.ukSI 2021/839 — pension scheme climate governance and reporting
A mandatory TCFD reporting regime for trustees with no duty to have a transition plan.