Pension-scheme climate reporting: a mandatory trustee duty
Trustees of large occupational pension schemes must run TCFD-aligned climate governance and publish a report within seven months of each scheme year-end, under the Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021. It is a distinct statutory duty on the trustees — not the FCA's SDR, and not company-level TCFD.
TCFD-aligned governance, and a report within seven months
A mandatory duty on trustees, structured on the four TCFD pillars, published on a free public website.
516 Under SI 2021/839, in-scope trustees must establish governance of climate-related risks and opportunities, undertake scenario analysis, identify and manage climate risks, select metrics (greenhouse-gas emissions and, since 1 October 2022, a portfolio-alignment metric) and set a target, and publish a TCFD report on a publicly available website free of charge, notifying the Pensions Regulator via the scheme return. The report is due within seven months of the end of the scheme year.
- 1 OCT 2021£5bn+ schemes & authorised master trusts
- 1 OCT 2022£1bn+ schemes; portfolio-alignment metric
- +7 MONTHSReport due after each scheme year-end
Phased in by scheme size, plus every authorised master trust
Two asset thresholds, two start dates, a master-trust catch-all, and a £500m floor.
517A scheme is caught if its relevant assets are £5 billion or more (governance from 1 October 2021) or £1 billion or more (from 1 October 2022), measured at the relevant scheme year-end. All authorised master trusts and authorised collective money purchase (CDC) schemes are in scope regardless of size, from 1 October 2021 or authorisation. If a scheme’s relevant assets later fall below £500 million, the ongoing requirements cease, but trustees must still publish one final report.
The threshold most schemes watch
Schemes with £5 billion or more of relevant assets came into scope from 1 October 2021; those with £1 billion or more from 1 October 2022.
The thresholds are tested at a scheme year-end, and a scheme crossing £1 billion becomes subject the following scheme year.
Below £1 billion — and not an authorised master trust or CDC scheme — a scheme is outside this regime.
Which pension schemes must report on climate change?
Trustees of large occupational pension schemes, under the Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021 (SI 2021/839).
A scheme is caught if its relevant assets are £5 billion or more (governance from 1 October 2021) or £1 billion or more (from 1 October 2022), measured at the relevant scheme year-end.
All authorised master trusts and authorised collective money purchase (CDC) schemes are in scope regardless of size, from 1 October 2021 or authorisation.
Schemes below £1 billion that are not authorised master trusts or CDC schemes are not in scope.
What must trustees actually do?
In-scope trustees must establish governance of climate-related risks and opportunities, undertake scenario analysis, identify and manage climate risks, select metrics (greenhouse-gas emissions and, since 2022, a portfolio-alignment metric) and set a target, and publish a TCFD-aligned report.
The structure follows TCFD's four pillars: governance, strategy, risk management, and metrics and targets.
It is a mandatory duty for in-scope schemes, not comply-or-explain.
When is the pension climate report due?
Within seven months of the end of the scheme year.
The report must be published on a publicly available website, free of charge, and the Pensions Regulator must be notified of the web address via the scheme return.
Missing the deadline or failing to meet the requirements can lead to enforcement action by the Pensions Regulator.
Is this the same as the FCA's TCFD or SDR rules?
No.
Pension-scheme climate reporting is a distinct statutory regime for pension trustees under Department for Work and Pensions pensions law, not the FCA's Sustainability Disclosure Requirements and not company-level TCFD or the UK Sustainability Reporting Standards.
The obligated person is the scheme's trustees.
A company may separately face its own reporting duties, but those are a different regime with a different legal basis.
What happens if a scheme drops below the threshold?
If a scheme's relevant assets later fall below £500 million on a scheme year-end date, the ongoing governance and reporting requirements cease.
However, trustees must still publish one final report for the year in which they were last in scope.
The thresholds are tested on relevant net assets at a scheme year-end, and a scheme crossing £1 billion becomes subject the following scheme year.
Does the report have to cover Scope 3 and a Paris-alignment metric?
Trustees must select and disclose greenhouse-gas emissions metrics for the scheme's assets and, since 1 October 2022, also calculate and disclose a portfolio-alignment metric — a measure of how the scheme's investments align with climate goals such as the Paris Agreement.
Trustees must, as far as they are able, obtain the data to do this, and explain where they could not.
The precise metrics and any Scope 3 coverage depend on the data trustees can reasonably obtain for their asset classes.
Related guides & references
UK Sustainability Reporting by Sector
The directory of industry-specific reporting regimes, including the finance and pensions rules
The UK Stewardship Code 2026
The voluntary investor-stewardship code that asset owners such as pension schemes often sign up to
TCFD
The four-pillar climate disclosure framework the pension regime is built on
FCA Sustainability Disclosure Requirements
The separate FCA regime for regulated firms and products — not the pension trustee duty