Pension schemes · SI 2021/839 · DWP and The Pensions Regulator

Pension scheme climate reporting: a mandatory trustee duty

Pension scheme climate reporting is a statutory duty on trustees of large occupational schemes under SI 2021/839, in force since 1 October 2021.

It follows the TCFD’s four pillars, ends in a report published free of charge within seven months of each scheme year end, and carries the only mandatory penalty in UK climate reporting.

It is a DWP regime enforced by The Pensions Regulator, and the FCA’s PS26/19 of 30 September 2026 does not touch it.

Work out your dates The penalty, precisely

The regime

A DWP instrument, enforced by The Pensions Regulator

The Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021 were made on 13 July 2021 and came into force on 1 October 2021.

They put duties on the trustees of the scheme, not on the sponsoring employer, which may have its own reporting under the Companies Act or the listing rules.

The regime is TCFD-structured — governance, strategy, risk management, and metrics and targets, the pillars of the TCFD recommendations — and it is mandatory for schemes in scope, not comply-or-explain.

It runs on a different track from the FCA’s rules: trust-based occupational schemes are outside the listing rules and outside UK SRS, and PS26/19 applies only to listed companies.

Contract-based pension providers regulated by the FCA have their own TCFD reporting under the FCA’s ESG sourcebook, which FCA 2026/59 simplified at product level from 25 September 2026 — see FCA sustainability disclosure requirements.

The Pensions Regulator’s 2025 climate adaptation report says around 300 DB, DC and hybrid schemes have had to prepare TCFD reports.

How the trustee duty sits among the other TCFD-shaped rules is on TCFD, and how stewardship expectations sit beside it on the UK Stewardship Code.

Who is in scope

Two tests: relevant assets, or authorisation

Sources: SI 2021/839 regs 3–5 · TPR Appendix 2
Test	Threshold	Governance duties start	Provision
First wave	£5bn or more at the first scheme year end on or after 1 March 2020	1 October 2021 (or when audited accounts are obtained, if later)	reg 3(1)
Second wave	£1bn or more at the first scheme year end on or after 1 March 2021	1 October 2022 (or when audited accounts are obtained, if later)	reg 3(2)
Ongoing entry	£1bn or more at any scheme year end on or after 1 March 2022	The scheme year beginning one scheme year and a day after that year end	reg 3(3)
Authorised master trust	Any size, while authorised	1 October 2021, or authorisation if later	reg 4
Authorised CDC scheme	Any size, while authorised	1 October 2021, or authorisation if later	reg 5
Exit	Relevant assets below £500m at a later scheme year end	Governance stops; one final report still due	reg 3(5)

“Relevant assets” is a defined term

For a scheme that obtains audited accounts, it is net assets in those accounts less the value of any relevant contract of insurance — a buy-in that guarantees specified non-money-purchase benefits.

A scheme with a large buy-in can sit below £1 billion of relevant assets with far more on its balance sheet.

The £500m and £1bn figures in regs 4 and 5

For master trusts and CDC schemes they are exit and re-entry tests after authorisation lapses, not a size gate.

A scheme that is authorised is in scope at any size.

The £5 billion and £1 billion waves were both in the 2021 Regulations as made.

SI 2022/733 is often said to have lowered the threshold; it did not — it inserted the portfolio alignment metric.

The Regulator’s 2025 report records 220 DB and hybrid schemes, 4% of them, with more than £1 billion of assets.

Dates

When your duties start and when each report is due

The planner applies the Regulator’s Appendix 2 to the dates you enter.

A scheme that first reports £1 billion or more of relevant assets at a scheme year end on or after 1 March 2022 does not start at once.

Its governance duties apply from the beginning of the scheme year that is one scheme year and a day after that year end.

For a scheme with a 31 March year end that first crossed £1 billion on 31 March 2026, that is 1 April 2027, and the first report is due by 31 October 2028.

After that, a report is due within seven months of every scheme year end while the duties apply, under regulation 6(1).

The report must be on a publicly available website, accessible free of charge, and the scheme return tells the Regulator where it is.

A master trust or CDC scheme authorised after 1 October 2021 starts on authorisation and reports for the first scheme year end that follows.

Trustee dates

Scheme year end at which relevant assets were £1bn or more

Governance duties begin

1 April 2027

SI 2021/839 reg 3(3); TPR Appendix 2

First scheme year under the duty ends

31 March 2028

one scheme year and a day after the measuring year end

First climate report published by

31 October 2028

SI 2021/839 reg 6(1): seven months

Scenario analysis

In the scheme year ending 31 March 2028, then at least every three scheme years

DWP statutory guidance ¶84; Sch Part 1

A reading aid.

Ear-marked schemes and schemes awaiting audited accounts have their own start rules in the Regulations; check TPR’s Appendix 2 for your case.

The duties

What trustees do, pillar by pillar

Sources: SI 2021/839 · DWP statutory guidance · TPR guidance
Pillar	What the Regulations and guidance ask	Where
Governance	Establish and maintain oversight of climate-related risks and opportunities	SI 2021/839 Schedule Part 1
Strategy	Identify and assess the climate-related risks and opportunities relevant to the scheme	Schedule Part 1
Scenario analysis	At least two scenarios, one within 1.5°C to 2°C above pre-industrial levels; in the first scheme year, then reviewed annually and redone at least every three scheme years	Schedule Part 1 ¶¶6, 8–11; DWP guidance ¶84
Risk management	Processes to identify, assess and manage climate-related risks	Schedule Part 1
Metrics	At least four: absolute emissions, emissions intensity, portfolio alignment and one additional climate metric	Schedule ¶15; SI 2022/733; DWP guidance ¶118
Targets	Set a target for the scheme	Schedule Part 1
Report	Published free of charge within seven months of the scheme year end, signed by the chair	reg 6(1)

Statutory guidance

DWP’s guidance is something trustees must have regard to; the duties themselves are in the Regulations.

Signed and notified

The report is signed by the chair of trustees, and the scheme return tells the Regulator where it is published.

The Regulator’s guide

TPR’s climate governance guidance explains how it reads the duties and what it expects to see.

Scenario analysis

Two scenarios, on a three-year cycle

Scenario analysis is not annual, which surprises trustees who read the TCFD framework first.

The Schedule requires it in the first scheme year the duties apply, then a review each year of whether new analysis is needed.

New analysis is required if the review says so, or if none has been done in the previous two scheme years — so at least every three scheme years, which is how DWP’s guidance puts it at ¶84.

At least two scenarios are needed, and one must be within the range of 1.5°C to 2°C above pre-industrial levels.

No rule names a provider; the central banks’ NGFS scenarios are a common reference set, and naming the vintage used is what makes the analysis repeatable.

How scenario analysis is written up for a company rather than a scheme is on TCFD disclosures.

Enforcement

The penalty is mandatory, and the trigger is publication

Regulation 9(2) reads: “the Authority must issue a penalty notice” where a person fails to publish the report on a publicly available website, accessible free of charge.

That penalty “must be at least £2,500”, and every other contravention is discretionary.

The Regulator’s monetary penalties policy says: “We have no discretion not to issue a penalty notice in these circumstances.”

It adds: “The penalty relates to the publication of the report, not its content.”

Its stated approach is that all breaches attract at least the minimum, a consecutive penalty will normally be at least £5,000, and where a professional trustee is in place the minimum is generally £5,000.

The first fine went to the trustees of the ExxonMobil Pension Plan: the report was due by 31 July 2022 and “a faulty URL meant the report was not published on a publicly available website until 10 August”, ten days late (TPR intervention report).

The Regulator issued a £5,000 penalty in May 2023, above the minimum because the trustee was a corporate body, and it was paid in July 2023.

Its penalty notices list climate reporting penalties of £5,000 for the University of Oxford Staff Pension Scheme and £4,000 for the J.P. Morgan UK Pension Plan in the second half of 2024.

The lesson is mechanical: check the link works, from outside the scheme’s own network, on the day the report is due.

Source: SI 2021/839, regulation 9
Limb	Rule	Amount
Failure to publish the report free of charge on a public website	TPR must issue a penalty notice — reg 9(2)	At least £2,500
Any other contravention, or a compliance notice	TPR may issue a penalty notice — reg 9(1)	No floor
Cap, either limb	reg 9(4)(a)	£5,000 individual · £50,000 body corporate
Who pays	Notice to all trustees, jointly and severally — reg 9(5)(a)	—

What the regime is not

No transition plan, no UK SRS, no listing rule

The Regulations require a target, but not a transition plan.

The government’s commitment to mandate transition plans names pension funds, and its 2025 consultation has had no response; the position is on climate transition plans.

UK SRS does not apply to trust-based schemes, and neither does PS26/19.

The government’s June 2025 UK SRS exposure draft said DWP would review the Regulations and “consider the role of UK SRS” in reporting by pension schemes; no outcome of that review has been published.

The Local Government Pension Scheme in England and Wales has its own climate reporting consultation, which closed on 24 November 2022 and still reads “We are analysing your feedback”.

Sector-by-sector, the duties an employer and its scheme may each carry are set out on UK sustainability reporting by sector.

Dates

The regime in dates

The regime has not changed since the 2022 metric amendment.

The developments around it — the FCA’s product-level changes and the listing-rule changes — affect neighbouring regimes, not trustees.

The DWP review promised in 2025 is the item to watch, because it is where the role of UK SRS for schemes will be decided.

13 Jul 2021
SI 2021/839 made
1 Oct 2021
First wave
£5bn+ schemes, authorised master trusts and CDC schemes.
1 Oct 2022
Second wave
£1bn+ schemes; portfolio alignment metric added.
31 Jul 2022
ExxonMobil report due
Published 10 August; £5,000 penalty in May 2023.
24 Nov 2022
LGPS consultation closes
No response published.
25 Sep 2026
FCA 2026/59 in force
For FCA-regulated pension providers, not trust-based schemes.

Test yourself

Six claims about trustee reporting, true or false

Each of these appears in trustee briefings, and two of them confuse the threshold history.

The answers cite the regulation that decides each one.

The penalty pair matter most: the mandatory penalty is for publication, and the £2,500 floor does not apply to every breach.

Six claims about pension climate reporting

“A scheme with £800 million of relevant assets must publish a TCFD report.”
“An authorised master trust is in scope whatever its size.”
“A report that exists but sits behind a broken link can attract a mandatory penalty.”
“The minimum penalty is £2,500 for any breach of the Regulations.”
“SI 2022/733 lowered the asset threshold to £1 billion.”
“Scenario analysis must be redone every year.”

6 claims.

Choose true or false for each.

Frequently asked

Pension scheme climate reporting, answered

Which pension schemes must report on climate change?

Trustees of occupational pension schemes with relevant assets of £1 billion or more at a scheme year end, and of every authorised master trust and authorised collective money purchase (CDC) scheme, under the Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021.

Schemes with £5 billion or more came in first, from 1 October 2021, and schemes with £1 billion or more from 1 October 2022.

What must trustees do under the climate regulations?

Establish and maintain oversight of climate-related risks and opportunities, carry out scenario analysis, identify, assess and manage climate risks, select and calculate metrics, set a target, and publish a report on a publicly available website, free of charge, within seven months of the end of each scheme year.

When is the pension scheme TCFD report due?

Within seven months of the end of each scheme year in which the governance duties applied.

For a scheme year ending on 31 March, that is 31 October.

What happens if trustees do not publish the report?

The Pensions Regulator must issue a penalty notice under regulation 9(2) where trustees fail to publish the report on a publicly available website, free of charge.

The penalty must be at least £2,500 and cannot exceed £5,000 for an individual or £50,000 for a body corporate.

The Regulator says it has no discretion not to issue one, and the penalty relates to publication, not content.

Has the Pensions Regulator fined any scheme?

Yes.

Its first climate reporting fine was £5,000 for the trustees of the ExxonMobil Pension Plan, issued in May 2023 and paid in July 2023.

The report was due by 31 July 2022 but a faulty URL meant it was not on a publicly available website until 10 August.

The Regulator has since published penalties for the University of Oxford Staff Pension Scheme and the J.P. Morgan UK Pension Plan.

How often must trustees carry out scenario analysis?

In the first scheme year the duties apply, then at least every three scheme years, reviewing each year whether new analysis is needed.

The Regulations require at least two scenarios, one of them within the range of 1.5°C to 2°C above pre-industrial levels.

What metrics must pension schemes report?

At least four: an absolute emissions metric, an emissions intensity metric, a portfolio alignment metric (added from 1 October 2022) and one additional climate change metric.

Do pension schemes have to have a transition plan?

No. The 2021 Regulations require climate governance and reporting, including a target, but no transition plan.

The government has committed to mandating transition plans for pension funds among others, but its 2025 consultation has had no published response.

Does UK SRS or PS26/19 apply to pension schemes?

No. PS26/19 changes the FCA listing rules for listed companies.

Trust-based occupational schemes sit under the DWP and Pensions Regulator regime.

The government said in 2025 that DWP would review the 2021 Regulations and consider the role of UK SRS, and no outcome has been published.

What if a scheme’s assets fall below £500 million?

If relevant assets fall below £500 million at a later scheme year end, the governance duties stop from that date, but the trustees must still publish a report for the scheme year that has just ended, unless an exception in regulation 6(2) applies.

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.

Checked against 17 sources fromlegislation.gov.ukThe Pensions RegulatorDepartment for Work and PensionsGOV.UK (MHCLG)Department for Business and TradeFinancial Conduct Authority

legislation.gov.uk
SI 2021/839 — Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021, as made
The duties: regs 3–6 and the Schedule.
legislation.gov.uk
SI 2021/839 — instrument page
Regs 1, 3, 4, 5, 6 and Schedule Part 1.
legislation.gov.uk
SI 2021/839, regulation 9 — penalties
“Must issue” for a publication failure; at least £2,500; caps of £5,000 and £50,000.
legislation.gov.uk
SI 2022/733 — the portfolio alignment amendment
Inserted the fourth metric; changed no asset threshold.
The Pensions Regulator
Climate change governance and reporting — detailed guidance
Scope, deadlines and how the regulator applies the duties.
The Pensions Regulator
Appendix 2: when schemes are subject to the requirements
The start date for each test, and the £500 million exit.
The Pensions Regulator
Monetary penalties policy, Appendix 3
“We have no discretion not to issue a penalty notice.”
The Pensions Regulator
ExxonMobil Pension Plan — regulatory intervention report
The first climate reporting fine: £5,000, a report published ten days late after a faulty URL.
The Pensions Regulator
Penalty notices
Published enforcement, including climate reporting penalties in 2024.
The Pensions Regulator
Climate adaptation report 2025
Around 300 schemes have had to prepare TCFD reports.
Department for Work and Pensions
Statutory guidance: governance and reporting of climate change risk, ¶¶84 and 118
Scenario analysis at least every three scheme years; at least four metrics.
Department for Work and Pensions
Governance and reporting of climate change risk: guidance for trustees
The trustee guidance on GOV.UK.
GOV.UK (MHCLG)
Local Government Pension Scheme (England and Wales): governance and reporting of climate change risks — consultation
Closed 24 November 2022; still “analysing your feedback”.
Department for Business and Trade
Exposure draft of UK SRS S1 and S2, June 2025
DWP to review the 2021 Regulations and consider the role of UK SRS.
Financial Conduct Authority
Handbook Notice 144 — FCA 2026/59
Simplified product-level TCFD reporting for FCA-regulated pension providers, from 25 September 2026.
Financial Conduct Authority
PS26/19 — listed issuers’ sustainability disclosures
A listing-rule change; trust-based schemes are outside it.
Task Force on Climate-related Financial Disclosures
Recommendations
The four pillars the trustee duties follow.