TCFD Transitioning to UK SRS
FCA CP26/5 published 30 January 2026 proposes replacing TCFD listing rules with UK SRS from 1 January 2027. Listed companies should begin UK SRS preparation now.
Task Force on Climate-related Financial Disclosures (TCFD) is mandatory for UK listed companies and large financial institutions. Understand current requirements and the transition to UK SRS.
The Task Force on Climate-related Financial Disclosures (TCFD) was established by the Financial Stability Board in 2015. The TCFD itself was disbanded in 2023, with the ISSB taking over its work. However, TCFD requirements remain in force in the UK.
TCFD reporting remains mandatory for eligible companies in 2026. However, FCA CP26/5 proposes replacing TCFD listing rules with UK SRS from 1 January 2027. Companies should prepare for this transition while maintaining TCFD compliance.
All UK premium listed companies on London Stock Exchange Main Market
UK companies on standard listing segment of Main Market
FCA Rules: Policy Statement PS21/23 introduced mandatory TCFD disclosures from accounting periods beginning on or after 1 January 2022
PRA-regulated firms with £50bn+ total assets
PRA-regulated insurers with £25bn+ assets under management
FCA-regulated managers with £5bn+ assets under management
Threshold (2 of 3):
Note: Includes qualifying LLPs and UK-registered companies. Disclosure required under Companies Act 2006.
Occupational Pension Schemes:
DWP regulations require TCFD reporting for qualifying schemes.
Describe the organization's governance around climate-related risks and opportunities.
Disclose actual and potential impacts of climate risks and opportunities.
Disclose how the organization identifies, assesses, and manages climate risks.
Disclose metrics and targets used to assess and manage climate issues.
FCA CP26/5 was published on 30 January 2026, proposing to replace TCFD listing rules with UK SRS requirements from accounting periods beginning on or after 1 January 2027.
| Aspect | Current TCFD | Future UK SRS |
|---|---|---|
| Scope | Climate-related only | All sustainability topics + climate |
| Standards | TCFD recommendations | ISSB-based UK SRS S1 & S2 |
| Metrics | Limited prescribed metrics | Cross-industry + industry-specific metrics |
| Scope 3 Emissions | "If appropriate" | Mandatory where material |
| Assurance | Not required | Phased introduction expected |
| Transition Plans | High-level description | Detailed transition plan requirements |
A typical TCFD compliance engagement for a listed company involves:
Don't wait until 2027. Start preparing for UK SRS now while maintaining TCFD compliance.