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.

TCFD Reporting UK: Requirements, Transition to UK SRS and 2026 Guide

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.

What is TCFD and Does it Still Apply in 2026?

TCFD Background

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.

  • • Created framework for voluntary climate-related financial disclosures
  • • Became mandatory in UK for listed companies from 2022
  • • Four pillars: Governance, Strategy, Risk Management, Metrics & Targets
  • • Being superseded by UK SRS from 2027

Status in 2026

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.

Who Must Report Under TCFD in the UK?

Listed Companies

Premium Listed Companies

All UK premium listed companies on London Stock Exchange Main Market

Standard Listed Companies

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

Financial Institutions

Banks & Building Societies

PRA-regulated firms with £50bn+ total assets

Insurers

PRA-regulated insurers with £25bn+ assets under management

Asset Managers

FCA-regulated managers with £5bn+ assets under management

Large UK Companies

Threshold (2 of 3):

  • • More than 500 employees
  • • More than £500 million turnover
  • • More than £500 million balance sheet total

Note: Includes qualifying LLPs and UK-registered companies. Disclosure required under Companies Act 2006.

Pension Schemes

Occupational Pension Schemes:

  • • 100+ members (relevant schemes)
  • • £1bn+ total assets
  • • Master trusts with 100+ members

DWP regulations require TCFD reporting for qualifying schemes.

The Four TCFD Pillars: Governance, Strategy, Risk, Metrics

1. Governance

Describe the organization's governance around climate-related risks and opportunities.

  • • Board oversight of climate issues
  • • Management role in assessment and management
  • • Relevant board expertise and training
  • • Integration with executive remuneration

2. Strategy

Disclose actual and potential impacts of climate risks and opportunities.

  • • Climate risks and opportunities (short, medium, long-term)
  • • Impact on business, strategy and financial planning
  • • Climate scenario analysis
  • • Resilience of strategy under different scenarios

3. Risk Management

Disclose how the organization identifies, assesses, and manages climate risks.

  • • Process for identifying climate risks
  • • Process for assessing climate risks
  • • Process for managing climate risks
  • • Integration into overall risk management

4. Metrics & Targets

Disclose metrics and targets used to assess and manage climate issues.

  • • Metrics used by organisation
  • • Scope 1, 2 and (if appropriate) Scope 3 GHG emissions
  • • Climate-related targets and performance
  • • Methodologies for calculating metrics

TCFD to UK SRS Transition: What FCA CP26/5 Means for You

Critical Timeline

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.

AspectCurrent TCFDFuture UK SRS
ScopeClimate-related onlyAll sustainability topics + climate
StandardsTCFD recommendationsISSB-based UK SRS S1 & S2
MetricsLimited prescribed metricsCross-industry + industry-specific metrics
Scope 3 Emissions"If appropriate"Mandatory where material
AssuranceNot requiredPhased introduction expected
Transition PlansHigh-level descriptionDetailed transition plan requirements

Preparation Actions for 2026

  • • Begin gap analysis between current TCFD reporting and UK SRS requirements
  • • Assess Scope 3 emissions data availability and quality
  • • Review governance processes for broader sustainability topics
  • • Consider early adoption of UK SRS voluntary elements
  • • Evaluate assurance provider relationships and capabilities

How Carbon Legal Supports TCFD Compliance

A typical TCFD compliance engagement for a listed company involves:

Current TCFD Support

  • Four pillars disclosure development
  • Climate scenario analysis
  • Risk and opportunity mapping
  • Metrics and targets framework

UK SRS Transition Support

  • Gap assessment: TCFD to UK SRS
  • Scope 3 enhancement program
  • Sustainability governance expansion
  • Assurance readiness preparation

Ready for the TCFD to UK SRS Transition?

Don't wait until 2027. Start preparing for UK SRS now while maintaining TCFD compliance.