Climate transition plans · UK position at 1 October 2026
Climate transition plans: nobody has to have one, many are asked for one
No UK law requires a company, a bank, an insurer or a pension scheme to have a climate transition plan — the government’s 2025 consultation on mandating them is still unanswered.
What is now law is a statement: from accounting periods beginning on or after 1 January 2027, listed companies in UKLR 6, 16 and 22 say whether they have published a plan, and where, or why not (FCA PS26/19).
This page is about the plan itself: who asks for one, what goes in it, how the numbers have to add up, and why publishing one creates a claim.
The answer first
Is a transition plan mandatory in the UK? No
As at 1 October 2026 no UK entity is under a legal duty to have, implement or publish a climate transition plan.
That covers listed companies, banks, insurers, asset managers, pension schemes and the FTSE 100.
Three things are true at once, and running them together is what produces the opposite answer.
First, a political commitment: the government has committed to mandating “UK-regulated financial institutions (including banks, asset managers, pension funds and insurers) and FTSE 100 companies to develop and implement credible transition plans that align with the 1.5°C goal of the Paris Agreement” (DESNZ, implementation routes).
Second, a conditional disclosure duty for anyone applying UK SRS S2: describe the plan you have, if you have one.
Third, from 2027, a listing-rule statement for some listed companies about whether a plan has been published.
None of the three is a duty to have a plan, and the consultation that would create one has not been answered.
Voluntary does not mean pointless: investors, lenders, procurement teams and customers ask, and the reason to write one is commercial rather than legal.
The disclosure duties themselves, and a drafting aid for the listing-rule statement, are on transition plans under UK SRS.
Who asks
Eight audiences, eight different requests
“Do we need a transition plan?” has a different answer for each of these, and most organisations sit in more than one row.
| Who you are | What is asked | Is a plan required? | Source |
|---|---|---|---|
| Any entity reporting under UK SRS S2 or IFRS S2 | Information about any transition plan you have, with key assumptions and dependencies | No | UK SRS S2 ¶14(a)(iv) |
| Listed company in UKLR 6, 16 or 22 | Whether you have published a plan, where, or why not — periods beginning on or after 1 January 2027 | No | UKLR 6.6.6R(8)(e) |
| Listed company in UKLR 14 or 15 | UK SRS reporting on comply or explain, but no transition-plan statement | No | PS26/19 |
| Pension scheme trustees in scope | Climate governance, scenario analysis, metrics, a target and a published report | No | SI 2021/839 |
| Bank or insurer | The PRA’s supervisory expectations on climate-related risk | No rule requires one | PRA SS5/25 |
| EU company in CSRD scope | Transition-plan reporting under the ESRS | The CSDDD duty to adopt one is deleted | Dir (EU) 2026/470 |
| Bidder for a major central government contract | A Carbon Reduction Plan in a prescribed form, as a condition of participation | A different document — and asked for | Procurement Policy Note |
| Supplier asked by a customer or lender | Whatever their questionnaire asks | Contractual, not legal | — |
A questionnaire asking for “your transition plan” is a commercial requirement, and the audience is a buyer rather than a regulator.
That changes how it is written: what you will do for them, by when, and what you need from them.
ESG questionnaires covers how those requests arrive.
If a public-sector buyer asks for a plan, establish whether it means the procurement document.
That one has a set format and is covered on Carbon Reduction Plans.
The promise
Committed to, consulted on, not answered
The Department for Energy Security and Net Zero ran Climate-related transition plan requirements from 25 June to 17 September 2025.
When re-checked on 28 September 2026 the page still read “Visit this page again soon to download the outcome to this public feedback”, with no response attached.
The consultation had not settled the basic question.
Option 1 was to “require entities to explain why they have not disclosed a transition plan or transition plan-related information”; Option 2 was to “require entities to develop and disclose transition plans”.
The first is a disclosure regime; the second is a duty to build something, and nobody yet knows which, if either, is coming.
The FCA has meanwhile done the Option 1 shape for some listed companies through its own rules, which is why the listing-rule statement arrived before any legislation.
The consultation’s own document is the place to read both options in full, and the department that owns it is DESNZ.
How the UK SRS consultation that ran beside it turned out is on UK SRS consultation.
- 25 Jun 2025Consultation opens
Climate-related transition plan requirements, alongside the UK SRS and assurance consultations.
- 17 Sep 2025Consultation closes
11:59pm.
- 25 Feb 2026UK SRS published
S2 asks about the plan you have; it creates no duty.
- 30 Sep 2026FCA final rules
A statement for UKLR 6, 16 and 22 from 2027.
- 28 Sep 2026Page re-checked
“Visit this page again soon to download the outcome.”
The listing rule
From 2027, a statement — not a plan
The FCA’s consultation, CP26/5 (its consultation page still describes the proposals), put the boundary in one sentence at ¶1.7: “Mandating that companies have transition plans is a matter for Government.”
Its final rules, PS26/19 of 30 September 2026, kept that line: “We are not requiring listed companies to produce transition plans.
Nor are we introducing requirements for the location of transition plans.”
The made rule is UKLR 6.6.6R(8)(e): a statement of whether the listed company has published a climate-related transition plan, in its annual financial report or elsewhere, where it is, or why the company has not published one.
It applies to the commercial companies, non-equity and non-voting equity shares, and transition categories — UKLR 6, 16 and 22 — for accounting periods beginning on or after 1 January 2027.
Secondary listings and depositary receipts, UKLR 14 and 15, now report against UK SRS on a comply-or-explain basis, but they do not make the transition-plan statement.
The FCA also proceeded with its guidance as consulted, which points a company that publishes a plan to the IFRS Foundation’s guidance document on transition disclosures.
How the statement is worded, and how it sits beside the S2 disclosure, is drafted step by step on transition plans under UK SRS; the wider rules are on UK SRS and the FCA, and how the consultation became the rule is tracked on the CP26/5 tracker.
Commentary written during the consultation, such as Ashurst’s note on CP26/5 and ICAEW’s February 2026 piece, describes the proposals; the final rules above are what apply.
What it is
A plan is the route, a target is the destination
The standard’s definition is deliberately light: targets, actions or resources, as part of strategy.
The useful distinction in practice is between a target and a plan.
A target says where you will be; a plan says what you will do, who will do it, what it depends on and how anyone will know whether it is working.
Three things separate them: actions, with owners and dates; dependencies, meaning what the plan needs other people to do; and governance, meaning who reviews it and what happens when it slips.
UK SRS S2 ¶14(a)(iv) asks for two of those by name — “key assumptions used in developing its transition plan, and dependencies on which the entity’s transition plan relies”.
A plan with no stated dependencies is rarely a more confident plan; it is usually a less complete one.
The targets inside a plan are often set against the Science Based Targets initiative criteria, and how to set them is on how to set science-based targets.
The definition in the standard
A climate-related transition plan is “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”.
Source: UK SRS S2, Appendix A, matching IFRS S2
The structure
Five Elements, nineteen Sub-Elements
The archived TPT Disclosure Framework of October 2023 remains the most complete public description of what a plan contains.
In its own words, the Framework “is organised across five Elements … which are consistent with the transition planning components proposed by GFANZ”.
Foundations sets out the Strategic Ambition; Implementation Strategy, the actions across operations, products and policies; Engagement Strategy, how the entity works with its value chain, peers, government and civil society.
Metrics & Targets covers what is measured and aimed at; Governance, how the plan is embedded in the organisation.
The five divide into 19 Sub-Elements, and three guiding principles run through them: Ambition, Action and Accountability.
The final Framework says “1.
Foundations”, plural; a pre-final draft still in circulation says “Foundation”, which is a quick way to tell which document someone is quoting.
Tick the Sub-Elements your plan already covers: the builder shows where it is thin and produces an outline with the gaps marked.
Element 3 is the one most plans skip, and the one that separates a plan from a target, because for most businesses that is where the emissions are.
Your plan against the five Elements
Tick each Sub-Element your plan already covers. 3 of 19 ticked.
Engagement Strategy is empty: the plan says nothing about the value chain, where most emissions usually sit.
Governance is empty: nobody owns the plan, so nothing happens when it slips.
Key assumptions and external factors (1.3) is missing: this is where the dependencies UK SRS S2 ¶14(a)(iv) asks about belong.
Only ambition and targets are covered: that is a target with a preamble, not a plan.
Outline
Headings: TPT Disclosure Framework, October 2023, Figure 3 (archived, hosted by the IFRS Foundation).
The prompts are ours.
A structure, not a legal requirement.
The template
A transition plan template, Sub-Element by Sub-Element
The headings are the Framework’s Figure 3.
The prompts are ours, a drafting aid rather than the Framework’s text.
The government says UK SRS S2 does not “set out what information is expected to be included within a transition plan”, so this is a structure, not a requirement.
| Element | Sub-Elements | Write |
|---|---|---|
| 1. Foundations | 1.1 Strategic Ambition · 1.2 Business model and value chain · 1.3 Key assumptions and external factors | The objective and its date; how the business model changes; the assumptions and outside factors the plan relies on |
| 2. Implementation Strategy | 2.1 Business operations · 2.2 Products and services · 2.3 Policies and conditions · 2.4 Financial planning | Named actions with owner, date and tonnage; what changes in what you sell; the policies that make it stick; how it is paid for |
| 3. Engagement Strategy | 3.1 Value chain · 3.2 Industry · 3.3 Government, public sector, communities and civil society | Which suppliers and customers, asked for what, by when; the sector and policy work the plan needs |
| 4. Metrics & Targets | 4.1 Governance, engagement, business and operational · 4.2 Financial · 4.3 GHG · 4.4 Carbon credits | Base year and boundary; a target per scope; whether credits are used, for what, reported each year |
| 5. Governance | 5.1 Board oversight and reporting · 5.2 Management roles, responsibility and accountability · 5.3 Culture · 5.4 Incentives and remuneration · 5.5 Skills, competencies and training | The committee, the executive owner, the review date, whether pay is linked, and the capability needed |
Elements 1 and 4 filled, Elements 3 and 5 a sentence each.
That is a target with a preamble: Ambition without Action or Accountability.
Sub-Element 4.4 asks how credits are used and reported.
A carbon neutrality claim brings its own conditions, set out on PAS 2060 and ISO 14068.
The arithmetic
Make the numbers add up before you publish
A plan is a set of numbers that have to reconcile: the cut the target implies, the actions that deliver it, and the year-by-year path between.
The planner is preloaded with an invented manufacturer: a 2024 baseline of 12,000 tCO2e across Scope 1 and 2, and an ambition to halve it by 2030.
12,000 × 50% = 6,000 tCO2e to remove.
The listed actions — electrifying process heat (3,200), the fleet (1,100), on-site solar (700) and an efficiency programme (1,000) — sum to 6,000.
Spread over the six years from 2024 to 2030, that is 1,000 tCO2e a year, the milestone a board reviews against.
Now the dependency: electrifying process heat needs a grid connection the company does not control, and it carries 3,200 ÷ 6,000 = 53% of the planned cut.
That is the sentence ¶14(a)(iv) asks for, and the one most plans leave out.
A halving target is not by itself a science-based target; the baseline underneath should be measured on the GHG Protocol Corporate Standard with the current government conversion factors, a stated Scope 2 method and the material Scope 3 categories.
Check the plan adds up
Actions (tonnes removed by the target year; tick if it depends on someone else)
Cut needed: 12,000 × 50% = 6,000 tCO2e by 2030.
Evenly over 6 years: 1,000 tCO2e a year — the milestone a board can review against.
Actions listed: 6,000 tCO2e. The actions cover the target exactly.
Depends on others: 3,200 tCO2e, 53% of the listed cut.
Name each dependency — UK SRS S2 ¶14(a)(iv) asks for them by name.
Arithmetic on your own numbers, with an invented example preloaded.
A percentage cut is not by itself a science-based target.
How to write one
Eight steps, in a sensible order
No rule prescribes a method, and the IFRS Foundation’s 2025 guidance says it “does not provide guidance on the transition planning process—for example, how to develop a transition plan”.
The TPT’s process guidance went to the International Transition Plan Network; what follows is a provisional sequence on the TPT structure.
One: establish your position — S2 reporter, listed company, bidder, trustee or a supplier being asked — because it decides the audience.
Two: fix the baseline — boundary, base year, Scope 1, Scope 2 and material Scope 3 — on the GHG Protocol, and reconcile it with any SECR figures you already publish.
Three: set the Strategic Ambition and the targets, and if you want them validated, check which version of the SBTi standard applies — Corporate Net-Zero Standard V2.0 was published on 11 June 2026, while V1.3.1 governs submissions until V2.0 takes effect; SBTi Net-Zero Standard V2 has the dates.
Four: list the actions, each with an owner, a date and the tonnes it removes.
Five: cost them, and say how they are funded and where they appear in the financial plan.
Six: plan the engagement with suppliers, industry and government, with specific asks and dates.
Seven: write down the key assumptions and the dependencies.
Eight: put governance around it — board oversight, an executive owner, a review date — then publish it, and if you apply UK SRS S2, describe it under ¶14(a)(iv).
Measurement and accounting choices are covered on carbon accounting, and a readiness check for the wider UK SRS report is the UK SRS readiness assessment.
Steps four and five are where most buyers bring in help, and the guide to decarbonisation consultancy sets out what a decarbonisation consultant does.
The archive
The TPT disbanded in 2024; its framework is archived
The Transition Plan Taskforce was created by the UK government, published its Disclosure Framework in October 2023 and its sector material in April 2024.
In October 2024 it “completed its work and disbanded”, and the IFRS Foundation “assumed responsibility for the disclosure-specific materials authored by the TPT (13 resources)”.
The Knowledge Hub carries them under a notice: “This content was authored by the Transition Plan Taskforce.
The IFRS Foundation is not responsible for its accuracy.”
That notice is the status: archived third-party guidance, not a standard, and never law.
The Sector Summary covers 30 financial and real-economy sectors; an earlier figure of 40 described the October 2023 draft.
The IFRS Foundation’s own June 2025 guidance says IFRS S2 “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”, and that it “does not add to or otherwise change the requirements in IFRS S2”.
A supplier describing a deliverable as “TPT-aligned” is naming a real document from a body that no longer exists, so it is fair to ask which version and who maintains it now.
The international standard behind all of this is on IFRS S2, its issuer on the ISSB framework, and the global picture on global sustainability standards.
| Material | Where it went |
|---|---|
| Disclosure Framework, Explore the Disclosure Recommendations, Sector Summary, 7 sector guidances, 3 mappings | IFRS Foundation Knowledge Hub — 13 resources, under an accuracy disclaimer |
| Guidance on the transition-planning process | International Transition Plan Network |
| IFRS Foundation’s own guidance on disclosure under IFRS S2 | Published 23 June 2025; changes no requirement |
The EU
The European duty to adopt a plan has been deleted
If you have read that EU law requires companies to adopt and put into effect a transition plan, that was true and is not.
Directive (EU) 2026/470, Article 4, point (16), reads: “Article 22 is deleted”.
Article 22 of the Corporate Sustainability Due Diligence Directive was the transition-plan duty, and the consolidated text now runs from Article 21 to Article 23.
The reported 2025 compromise was to soften the duty; the adopted outcome went further and removed it, so a summary that says it was softened is wrong.
What survives is reporting: transition-plan disclosure under the CSRD and the ESRS, for undertakings above the revised thresholds of more than 1,000 employees and €450 million turnover.
The Commission’s revised ESRS E1 asks an undertaking without a plan to say so and to indicate whether and, if so, when it expects to adopt one.
A UK group with EU subsidiaries should keep the reporting duty and the deleted duty apart; conflating them is how most of the wrong advice is produced.
The EU standards are on ESRS and ESRS and UK SRS, the reporting directive from a UK view on CSRD for UK groups and CSRD and UK SRS, and the due diligence directive on CSDDD; the standard-setter is EFRAG.
Pensions and financial firms
Climate duties, but no plan duty
Pension schemes appear by name in the government’s commitment, which is why trustees ask this question so often.
What is law for them is SI 2021/839: climate governance, scenario analysis, metrics including a portfolio alignment metric, a target and a published report, for schemes with £1 billion or more of relevant assets and for authorised master trusts and CDC schemes.
The Pensions Regulator must issue a penalty of at least £2,500 where the report is not published on a free public website, under regulation 9.
None of that is a duty to have a transition plan; the full trustee position is on pension scheme climate reporting.
For banks and insurers, the PRA’s Supervisory Statement SS5/25, which replaced SS3/19 on 3 December 2025, sets supervisory expectations covering governance, risk management, scenario analysis, data and disclosures.
A supervisory statement is a set of expectations, not a rule, and it creates no duty to publish a plan.
Asset managers and asset owners above £5 billion publish TCFD entity reports under the FCA’s ESG sourcebook, which are covered with the rest of the FCA’s regime on FCA sustainability disclosure requirements.
The risk
Publishing a plan creates a claim
You are not required to have a transition plan; you are required not to mislead about one you publish.
The CMA’s Green Claims Code applies to environmental claims generally, and the CMA runs an open programme on misleading environmental claims.
For FCA-authorised firms, the anti-greenwashing rule in ESG 4.3.1R requires references to sustainability characteristics to be consistent with the product or service and fair, clear and not misleading — see the anti-greenwashing rule.
A plan is unusually exposed because it is dated and forward-looking: a 2030 target published in 2026 becomes a testable statement in 2030, and the progress reports in between are the evidence.
That is why the assumptions and dependencies matter — they are what make a forward-looking statement honest rather than merely optimistic.
If a published plan has slipped, revising it with a stated reason is ordinary governance; leaving a superseded plan on the website is what turns into a claims problem.
The FCA’s 2027 rules also ask listed companies whether they have obtained assurance over their sustainability disclosures, and if so from whom, at what level and to which standard — disclosure of the fact, not a requirement to obtain it.
An assurer can check the basis of a plan — baseline, boundary, method, whether the actions exist and whether the governance operates — but not whether 2030 arrives as forecast; more on sustainability assurance and GHG verification standards.
The neighbours
Four things a plan is not
A net zero target
A destination, and one Sub-Element of nineteen.
Advice on getting from one to the other is covered on net zero advisers.
A Carbon Reduction Plan
A procurement document in a set format, asked for by in-scope authorities from bidders for major contracts above the threshold.
It overlaps in content and is a different document.
SECR or a TCFD report
SECR is backward-looking energy and carbon disclosure in the accounts.
A TCFD-shaped report is about climate risk; a plan is one input to its strategy pillar.
A certification
Schemes such as Planet Mark or the Carbon Trust Standard are a third party’s statement about you.
A transition plan is your own statement about yourself.
Test yourself
Seven claims about transition plans, true or false
Each of these circulates in professional advice, and two of them changed on 30 September 2026.
The answers cite the instrument that decides each one.
The pair most likely to catch a reader out are the FCA ones: the 2027 rule is a statement about a plan, and it does not reach secondary listings.
Where UK SRS reporting sits overall in 2026 is on UK SRS in 2026, and how the comply-or-explain test works on UK SRS compliance.
Seven claims about transition plans
“From 2027 every UK listed company must have a transition plan.”
“A company with a secondary listing makes the transition-plan statement.”
“UK SRS S2 requires you to describe a transition plan if you have one.”
“The EU softened its transition-plan duty to “adopt” rather than “put into effect”.”
“The TPT Disclosure Framework is a live standard.”
“Large pension schemes must publish a climate report, but not a transition plan.”
“Publishing a voluntary plan carries no regulatory exposure.”
7 claims.
Choose true or false for each.
What is moving
One rule now made, one answer still owed
The listing-rule statement is made and applies to accounting periods beginning on or after 1 January 2027, with first reports in 2028.
The FCA is consulting on its draft guidance for comply-or-explain statements until 28 October 2026, which is guidance on explanations generally rather than on plans.
The government’s response to the 2025 consultation has no date, and the difference between its two options is the difference between explaining yourself and building something.
SBTi’s Corporate Net-Zero Standard V2.0 changes what “science-based” means inside a plan once validations against it open.
The EU deletion will not reverse: deletion is not a pause.
Every dated item is kept on the UK sustainability regulation timeline, and the wider reporting picture on ESG reporting and UK SRS reporting.
Before you start, decide which of the eight positions you are in, read ¶14(a)(iv) of UK SRS S2 if you report under it, and check whether your size puts you near any of the regimes on UK SRS thresholds.
The regulators’ own pages remain the place to check: the FCA and its climate change and sustainable finance hub and reporting requirements page, the FRC, the Department for Business and Trade, the Department for Work and Pensions, with its statutory guidance for trustees, and The Pensions Regulator’s climate guidance and penalties policy.
Filed reports, including any published plan cross-referenced from them, are on Companies House, and the IFRS standards are at ifrs.org; the SBTi, the government’s environmental reporting guidelines, the TCFD’s archived site and the 2022 pension amendment regulations, which added the portfolio alignment metric, complete the set.
Frequently asked
Climate transition plans, answered
Are transition plans mandatory in the UK?
No. No UK company, bank, insurer, pension scheme or FTSE 100 company is under a legal duty to have, implement or publish a climate transition plan.
The government has committed to mandating them for UK-regulated financial institutions and FTSE 100 companies and consulted on how in 2025, but that consultation had no published response when re-checked on 28 September 2026.
From accounting periods beginning on or after 1 January 2027, listed companies in UKLR 6, 16 and 22 must say whether they have published a plan, and where, or why not — a statement, not a duty to have one.
What is a climate transition plan?
UK SRS S2 and IFRS S2 define it in Appendix A 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.
The fullest public description of its contents is the archived Transition Plan Taskforce Disclosure Framework: five Elements — Foundations, Implementation Strategy, Engagement Strategy, Metrics and Targets, and Governance — divided into 19 Sub-Elements.
What does the FCA require on transition plans from 2027?
Under UKLR 6.6.6R(8)(e), made by PS26/19, a listed company in the commercial companies, non-equity and non-voting equity shares, or transition categories must state whether it has published a climate-related transition plan, in its annual financial report or elsewhere, and where; or, if it has not, why not.
The FCA said it is not requiring listed companies to produce transition plans, nor introducing requirements for their location.
Secondary listings and depositary receipts do not make this statement.
Does UK SRS S2 require a transition plan?
No. Paragraph 14(a)(iv) asks an entity to disclose information about any climate-related transition plan it has, including key assumptions and dependencies.
The government’s own consultation document says UK SRS S2 will not require an entity to have a transition plan or to set climate targets in line with a particular climate goal.
What are the components of a transition plan?
There is no official list of four.
The archived TPT Disclosure Framework organises a plan into five Elements: Foundations (the strategic ambition, business model and key assumptions), Implementation Strategy (operations, products, policies and financial planning), Engagement Strategy (value chain, industry and government), Metrics and Targets (including GHG targets and carbon credits) and Governance (board oversight, management accountability, culture, incentives and skills).
Does the TPT still exist?
No. The Transition Plan Taskforce completed its work and disbanded in October 2024.
The IFRS Foundation took responsibility for its 13 disclosure resources, which it hosts with the notice that it is not responsible for their accuracy, and the International Transition Plan Network took over the guidance on the transition-planning process.
How do you write a climate transition plan?
No rule prescribes a method, and the IFRS Foundation’s 2025 guidance says it does not cover the planning process.
A workable order is: establish who is asking and why; fix a GHG baseline on the GHG Protocol; set the ambition and targets; list the actions with an owner, date and tonnage; cost them; plan the engagement with suppliers and others; write down the assumptions and dependencies; and put board governance around it before publishing.
Did the EU drop its transition plan requirement?
Yes for the duty to have one.
Directive (EU) 2026/470, Article 4, point (16), deleted Article 22 of the Corporate Sustainability Due Diligence Directive, which required companies to adopt and put into effect a climate transition plan.
Transition-plan reporting survives under the CSRD and the ESRS for companies above the revised thresholds.
Do pension schemes have to have a transition plan?
No. Trustees of schemes with £1 billion or more of relevant assets, and of authorised master trusts and CDC schemes, have climate governance and reporting duties under SI 2021/839, including scenario analysis, metrics, a target and a published report.
None of those is a duty to have a transition plan.
Is a net zero target the same as a transition plan?
No. A target is a destination; a plan is the route.
In the TPT structure GHG targets are one Sub-Element of nineteen.
What turns a target into a plan is the actions, the dependencies on others, and the governance that owns delivery.
Is a transition plan the same as a Carbon Reduction Plan?
No. A Carbon Reduction Plan under the Cabinet Office procurement policy note is a document in a prescribed format that in-scope authorities ask bidders for as a condition of participation in major contracts.
It overlaps in content with a transition plan but is a different document, and it is the one a UK customer most often means.
Can you give an example of a transition plan?
An illustrative one: a manufacturer with a 2024 baseline of 12,000 tCO2e across Scope 1 and 2 aims to halve it by 2030, a cut of 6,000 tCO2e.
Its actions are electrifying process heat (3,200), switching the fleet (1,100), on-site solar (700) and an efficiency programme (1,000), giving a milestone of 1,000 tCO2e a year.
The plan names its main dependency — a grid connection it does not control, carrying 53% of the cut — and the board committee that reviews progress.
The figures are invented to show the arithmetic.
Should a transition plan be approved by the board?
No UK rule says so, but every framework that describes a credible plan puts it under board oversight.
The TPT Disclosure Framework’s Governance Element starts with board oversight and reporting, followed by management accountability, culture, incentives and skills.
Who looks after transition-plan guidance now that the TPT has gone?
Two bodies.
The IFRS Foundation hosts the TPT’s 13 disclosure resources and published its own guidance on transition disclosures under IFRS S2 on 23 June 2025.
The International Transition Plan Network took over the TPT’s guidance on the transition-planning process.
If a transition plan is voluntary, is there any risk in publishing one?
Yes.
A published plan is an environmental claim.
The CMA’s Green Claims Code applies to it, and for FCA-authorised firms so does the anti-greenwashing rule in ESG 4.3.1R.
Because a plan is dated and forward-looking, its stated assumptions and dependencies are what keep it honest.
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.
- GOV.UK (DESNZ)Climate-related transition plan requirements — consultation page
Ran 25 June – 17 September 2025; still “Visit this page again soon” when re-checked on 28 September 2026.
- GOV.UK (DESNZ)Transition plan requirements: implementation routes
The manifesto commitment, Option 1 and Option 2, and “UK SRS S2 will not require an entity to have a transition plan”.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (PDF), ¶14(a)(iv) and Appendix A
The conditional disclosure duty and the definition of a climate-related transition plan.
- GOV.UKUK Sustainability Reporting Standards — guidance and documents
The collection the standards sit in.
- Department for Business and TradeGovernment response to the UK SRS consultation (web version)
The final standards of 25 February 2026.
- Financial Conduct AuthorityPS26/19 (PDF) — the response after ¶2.44 and Appendix 1 (UKLR 6.6.6R(8)(e))
“We are not requiring listed companies to produce transition plans.”
- Financial Conduct AuthorityCP26/5 (PDF), ¶¶1.7, 6.9–6.11
“Mandating that companies have transition plans is a matter for Government.”
- IFRS FoundationDisclosing information about an entity’s climate-related transition, including transition plans, in accordance with IFRS S2 — 23 June 2025
Does not require an entity to have or publish a plan; does not change IFRS S2.
- IFRS FoundationTransition Plan Taskforce resources — IFRS Sustainability Knowledge Hub
“The IFRS Foundation is not responsible for its accuracy.”
- Transition Plan Taskforce (archived)TPT Disclosure Framework, October 2023, Figure 3
Five Elements, 19 Sub-Elements, three guiding principles.
- Transition Plan Taskforce (archived)Explore the Disclosure Recommendations, April 2024
What each Sub-Element asks for.
- Transition Plan Taskforce (archived)Sector Summary, April 2024
Guidance for 30 financial and real-economy sectors.
- International Transition Plan Networkitpn.global
Took over the TPT’s guidance on the transition-planning process.
- EUR-LexDirective (EU) 2026/470, Article 4, point (16)
“Article 22 is deleted” — the CSDDD transition-plan duty.
- EUR-LexDirective (EU) 2024/1760 (CSDDD)
The due diligence directive as amended.
- EUR-LexDirective (EU) 2022/2464 (CSRD)
Where transition-plan reporting survives in the EU.
- legislation.gov.ukSI 2021/839 — Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021
Climate governance and reporting for trustees; no transition-plan duty.
- Bank of England (PRA)Supervisory Statement SS5/25, 3 December 2025
Supervisory expectations for banks and insurers on climate-related risk; not a reporting rule.
- Cabinet OfficeProcurement Policy Note on Carbon Reduction Plans
The one plan a bidder may be asked for as a condition of participation.
- Competition and Markets AuthorityGreen Claims Code
Applies to what a published plan says.
- Science Based Targets initiativeCorporate Net-Zero Standard V2.0
Published 11 June 2026; V1.3.1 governs submissions until V2.0 takes effect.
- GHG ProtocolCorporate Accounting and Reporting Standard
The baseline underneath any plan.
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