Climate reporting · compliance · evidence
Climate disclosure software: start with the rule you report under
Climate disclosure software turns emissions data, risk assessments, scenarios and transition plans into a disclosure a UK rule will accept.
In the UK that usually means one of three rules: the Companies Act climate-related financial disclosures, UK SRS S2 under the FCA's final rules, or pension trustee climate reporting.
This guide sets out what each rule needs a tool to produce, what nobody certifies, and what to test before signing.
Which rule
Which UK climate disclosure rule is the software for?
Each rule asks for a different output, so the first question for any climate reporting software is which one the company reports under.
| Rule | Who reports | Basis | What the software has to produce |
|---|---|---|---|
| Companies Act ss.414CA–414CB | Traded, banking and insurance companies and AIM companies with more than 500 employees, and high-turnover companies (turnover over £500m and more than 500 employees); LLPs have a parallel duty | Law | The eight climate-related financial disclosures in s.414CB(2A)(a)–(h), in the strategic report |
| FCA PS26/19, UK SRS S1 and S2 | Listed companies in UKLR 6, 14, 15, 16 and 22 | Comply or explain, periods beginning on or after 1 January 2027 | UK SRS S2 governance, strategy, risk and metrics disclosures, or an explanation of what is missing |
| SI 2021/839 | Trustees of occupational schemes with £5bn+ (from October 2021) or £1bn+ (from October 2022) relevant assets, and authorised master trusts and CDC schemes | Law | A published climate report, scenario analysis and at least four metrics |
| IFRS S2 (voluntary in the UK) | Any company choosing to apply it, or reporting under another jurisdiction that adopts it | Depends on jurisdiction | IFRS S2 disclosures, often digitally tagged |
The detail of each rule is on the climate-related financial disclosures guide, the UK SRS S2 reporting requirements and the pension scheme climate reporting guide.
UK SRS S2
What does UK SRS S2 need climate reporting software to produce?
UK SRS S2 asks for absolute gross Scope 1, 2 and 3 emissions, measured under the 2004 GHG Protocol Corporate Standard (UK SRS S2 ¶29(a)).
"Gross" matters: carbon credits are never deducted from the reported figure, so a tool that nets offsets against the inventory produces the wrong number.
Scope 2 must be location-based, with information about contractual instruments; the standard does not require dual reporting.
The GHG Protocol's Scope 2 Guidance does require both methods where contractual instruments exist, so software serving both audiences needs to produce both figures (GHG Protocol).
Beyond emissions, the standard asks for information about any climate-related transition plan, including its key assumptions and dependencies (¶14(a)(iv)).
It also asks for the resilience of the strategy to climate change (¶22), and for current and anticipated financial effects (¶¶15–16).
Those are judgements, not calculations, so the software's job is to hold the reasoning, the inputs and the review trail behind each one.
For the scenario element see IFRS S2 scenario analysis, and for the emissions layer see GHG reporting software and Scope 3 emissions software.
PS26/19
How should software handle comply or explain?
Under PS26/19 a listed company that does not make a UK SRS disclosure must say what is missing, why, and what it is doing about it (FCA).
Climate compliance software should therefore track each disclosure requirement as one of three states: made, omitted with an explanation, or relying on a relief.
The reliefs give one year without Scope 3 under S2 and two years without non-climate S1 matters, and a company using one states that it is doing so.
A tool that only knows "complete" and "incomplete" cannot produce the explanation the rule asks for.
The full position is on the FCA sustainability disclosure requirements page and the UK SRS reporting software guide.
Pension trustees
What do pension trustees need from climate reporting software?
Trustees in scope must run TCFD-aligned climate governance and publish a report within seven months of each scheme year-end (SI 2021/839).
DWP's statutory guidance asks for scenario analysis in the first scheme year and at least every three scheme years after that (DWP).
It also asks for at least four metrics: absolute emissions, an emissions intensity measure, a portfolio alignment metric and one additional climate metric.
Most of that data comes from fund managers, so trustee software is judged on how it collects, checks and dates third-party data, not on its own calculations.
For the financed-emissions method behind those metrics, see financed emissions software.
Approvals
Does anyone certify climate disclosure software?
No UK regulator approves or certifies climate disclosure software: the FCA, DBT and the Pensions Regulator set the disclosure, not the tool.
The GHG Protocol's Built on GHG Protocol review service is closed until further notice, and the GHG Protocol warns that older listings may not conform with later guidance (GHG Protocol).
CDP publishes its own list of accredited solutions providers, which covers CDP disclosure and nothing else (CDP).
A vendor badge is a claim about one programme, on one date.
Ask which programme, which version and when, then check the owner's own list.
TCFD
What happened to TCFD reporting software?
The TCFD was disbanded on 12 October 2023, having fulfilled its remit (FSB).
Its recommendations live on inside IFRS S2 and UK SRS S2, and the Companies Act and pension rules were written in TCFD-aligned terms.
A product still sold as TCFD software should be tested against UK SRS S2 or the Companies Act disclosures, whichever the company actually reports under.
See the TCFD reporting software guide for the legacy framework and the ISSB reporting software guide for the global standard.
Digital reporting
Does climate disclosure software need to tag the report?
The IFRS Sustainability Disclosure Taxonomy provides tags for IFRS S1 and S2 disclosures, but it does not itself create a duty to tag (IFRS Foundation).
Whether a company must tag depends on its jurisdiction's filing rules, so ask the vendor to show a tagged S2 extract only if the company needs one.
The XBRL tagging software guide and the IFRS sustainability taxonomy page cover the detail.
The demonstration
What should you test in a climate disclosure software demo?
Bring the company's real data for one site and one supplier category, and ask the vendor to take it all the way to a draft disclosure.
Software demo · evidence check
Climate disclosure demo coverage
Tick a test only when the vendor has demonstrated it with a representative record and shown the evidence or export.
0 of 6 tests demonstrated (0%). This is a checklist result, not a score for the vendor.
Still to test: Produce gross Scope 1, 2 and 3 with no credits netted off; Show location-based Scope 2, and market-based alongside it; Name the conversion factor set and year behind each figure; Record each S2 requirement as made, explained or relying on a relief; Hold the scenario assumptions and transition plan dependencies with their owners; Export the evidence trail an assurance provider would ask for.
Compare platforms with the ESG software comparison, and weigh the tool against outside help with software versus a consultant.
Frequently asked
Climate disclosure software, answered
What is climate disclosure software?
Software that collects the data behind a climate-related disclosure, calculates the emissions and other metrics, holds the judgements on risks, scenarios and transition plans, and produces the report in the shape a specific rule requires.
Which UK rules does climate disclosure software need to cover?
For most UK companies, one of three: the Companies Act climate-related financial disclosures in sections 414CA and 414CB; UK SRS S1 and S2 on a comply-or-explain basis for listed companies under FCA PS26/19, for periods beginning on or after 1 January 2027; or, for occupational pension trustees, the 2021 climate governance and reporting regulations.
Is UK SRS S2 mandatory for listed companies?
No. Under FCA PS26/19 listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS on a comply-or-explain basis: disclose, or say what is missing, why, and what is being done about it.
Is there approved climate disclosure software?
No UK regulator approves software.
The GHG Protocol closed its Built on GHG Protocol review service until further notice, and CDP publishes its own list of accredited solutions providers for CDP disclosure only.
Is TCFD software still relevant?
The TCFD was disbanded on 12 October 2023.
Its recommendations live on inside IFRS S2 and UK SRS S2, so a tool sold as TCFD software should be tested against those standards.
Does climate disclosure software need to report market-based Scope 2?
UK SRS S2 requires location-based Scope 2 and information about contractual instruments; it does not require dual reporting.
The GHG Protocol requires both methods where contractual instruments exist, so a tool should be able to produce both.
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.
- FCAPS26/19: aligning listed issuers’ sustainability disclosures with international standards
- FCAPS26/19 (PDF)
- DBTUK SRS S2 Climate-related Disclosures
- DBTUK SRS S1 General Requirements
- LegislationCompanies Act 2006, section 414CA
- LegislationCompanies Act 2006, section 414CB
- LegislationSI 2022/31, Climate-related Financial Disclosure Regulations
- DBTClimate-related financial disclosures for companies and LLPs
- LegislationSI 2021/839, pension scheme climate governance and reporting
- DWPStatutory guidance for trustees on climate change risk
- IFRS FoundationIFRS S2 Climate-related Disclosures (2026 edition)
- IFRS FoundationIFRS Sustainability Disclosure Taxonomy
- FSBAnnual progress report on climate-related disclosures, October 2023
- GHG ProtocolCorporate Standard
- GHG ProtocolScope 2 Guidance
- GHG ProtocolGuidance Built on GHG Protocol
- CDPFind accredited solutions providers
- DESNZGreenhouse gas conversion factors 2026
Continue reading
Read next
UK SRS reporting software
Software for UK SRS S1 and S2 under PS26/19.
ISSB reporting software
IFRS S1 and S2, and the digital taxonomy.
GHG reporting software
The emissions inventory under the GHG Protocol.
Net zero software
Targets, transition plans and progress tracking.
Climate-related financial disclosures
The Companies Act rules in full.
Pension scheme climate reporting
The trustee duty under SI 2021/839.