Climate-related financial disclosures (CFD)
The Companies Act climate regime: eight TCFD-shaped disclosures, mandatory in the strategic report since April 2022 — including for large private companies the Listing Rules never touched. Who is in scope, what must be disclosed, and how CFD fits with UK SRS S2.
What the CFD Regulations require
Two 2022 statutory instruments hard-coded TCFD-style reporting into UK company law.
Climate-related financial disclosures are required by the Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 and the parallel LLP regulations, for accounting periods beginning on or after 6 April 2022. The eight disclosures — governance, risk processes, risk integration, principal risks and opportunities, business-model impact, scenario resilience, targets, and KPIs — map directly onto the four TCFD pillars. BEIS non-binding guidance explains how to apply them.
- CFDCompanies Act
- Climate-related financial disclosures — the statutory strategic-report requirement, distinct from the FCA’s TCFD-aligned Listing Rules despite sharing the TCFD architecture.
- Strategic reportWhere CFD lives
- The Companies Act narrative report approved by directors; CFD failures carry the same consequences as other defective strategic-report content.
- Scenario resilienceDisclosure (f)
- An analysis of business-model and strategy resilience under different climate scenarios — qualitative analysis is acceptable where proportionate.
CFD — frequently asked questions
What are climate-related financial disclosures (CFD)?
Climate-related financial disclosures (CFD) are a statutory reporting requirement under the Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022, with a parallel instrument for LLPs.
In-scope companies must include eight climate disclosures — covering governance, risk management, strategy, scenario resilience, and metrics and targets — in the strategic report, for accounting periods beginning on or after 6 April 2022.
The structure follows the TCFD framework, but CFD is a Companies Act legal requirement, not a voluntary framework.
Who must comply with CFD?
CFD applies to UK companies with more than 500 employees that are traded, banking or insurance companies (and AIM companies over the threshold), and to other UK-registered companies and LLPs with more than 500 employees and more than £500m annual turnover.
This deliberately captures large private companies that were never covered by the FCA’s TCFD-aligned Listing Rules.
How is CFD different from TCFD?
TCFD is the (now-disbanded) global framework that defined the four-pillar architecture for climate reporting.
CFD is UK law that hard-codes eight TCFD-shaped disclosures into the Companies Act strategic report.
A company can be caught by CFD, by the FCA’s listing-rule requirements, or both — the content overlaps heavily but the legal instruments, scope tests and enforcement routes differ.
Does UK SRS replace CFD?
Not yet.
The FCA’s CP26/5 proposals replace the TCFD-aligned Listing Rules with UK SRS S2 for listed companies from 2027, but the Companies Act CFD regime continues to apply in parallel.
The Government has said it will consider streamlining overlapping requirements — including CFD and SECR — as part of the Modernising Corporate Reporting programme, but until legislation changes, in-scope companies must keep making CFD disclosures.
Where do CFD disclosures go, and who enforces them?
CFD disclosures sit in the strategic report (for LLPs, the energy and carbon report).
They form part of the annual report filed at Companies House, and the FRC reviews compliance through its corporate reporting review function — CFD has featured in FRC thematic reviews of climate reporting.
Directors approve the strategic report, so defective disclosure carries the same consequences as other strategic-report failures.
Related guides & references
TCFD
The framework CFD is built on — four pillars and eleven recommendations
TCFD UK requirements
Which UK instrument requires what, for whom
UK SRS S2
The climate standard replacing TCFD-aligned listing rules from 2027
SECR reporting guide
The parallel energy-and-emissions regime in the directors’ report
UK SRS thresholds
Who the UK standards catch now — and may catch next