£5bn or more
At the first scheme year end on or after 1 March 2020: governance from 1 October 2021, or from audited accounts if later.
reg 3(1)Pension schemes · SI 2021/839 · Requirements
Pension scheme climate reporting requirements in the UK: every trustee duty, with its paragraph
The pension scheme climate reporting requirements in the UK are set by SI 2021/839, and they bind the trustees of occupational schemes with £1 billion or more of relevant assets and every authorised master trust and CDC scheme.
Trustees must govern climate risk on the TCFD pattern, publish a report within seven months of each scheme year end, and point members and the regulator to it.
Failing to publish carries a penalty The Pensions Regulator has no discretion to waive.
In brief
The pension scheme climate reporting requirements, in brief
The pension scheme climate reporting requirements in the UK are a statutory duty on trustees, made by the Department for Work and Pensions under the Pensions Act 1995 and in force since 1 October 2021.
They are mandatory for schemes in scope, not comply-or-explain, and they fall on the trustees rather than the sponsoring employer.
The duties follow the four pillars of the TCFD recommendations, and the report trustees publish is usually called the scheme’s TCFD report.
The Pensions Regulator supervises the regime, and its detailed guidance sets out how it reads each duty.
The regime explained as a narrative, with a planner for your own dates, is on pension scheme climate reporting; this page lists each requirement against its provision.
How it sits among every other UK duty is on the UK sustainability reporting requirements hub.
In one table
Every requirement, with its provision
Each line is a duty in SI 2021/839, its amending instruments or the disclosure rules they inserted.
“As far as they are able” means taking all reasonable and proportionate steps, weighing cost and time, under Schedule ¶25.
| Requirement | When | Provision |
|---|---|---|
| Maintain oversight of climate-related risks and opportunities | Continuously | Sch ¶1 |
| Check that people running or advising on governance take adequate steps on climate | Continuously | Sch ¶2 |
| Identify climate risks and opportunities over short, medium and long terms you define | Ongoing | Sch ¶¶3–4 |
| Assess their impact on the investment strategy and any funding strategy | Ongoing | Sch ¶5 |
| Scenario analysis in at least two scenarios, one between 1.5°C and 2°C | First year; then at least every three scheme years | Sch ¶¶6–11 |
| Processes to identify, assess and manage climate risks, integrated into overall risk management | Continuously | Sch ¶¶12–14 |
| Select an absolute emissions, an emissions intensity, a portfolio alignment and an additional metric | First scheme year; review from time to time | Sch ¶¶15–17 |
| Obtain Scope 1, 2 and 3 emissions of the assets and calculate the metrics | Each scheme year (no Scope 3 in year one) | Sch ¶¶18–21, 19A |
| Set a target on one metric and measure performance against it | First year; then each year | Sch ¶¶22–24 |
| Produce a report with the fifteen statements in Part 2 | Within 7 months of scheme year end | reg 6(1)(a); Sch ¶27 |
| Have the chair sign the report | Before publication | reg 6(3) |
| Publish it on a public website, free of charge | Within 7 months | reg 6(1)(b) |
| Give the website address in the annual report | With the annual report | SI 2021/857; Disclosure Regs Sch 3 ¶34A |
| Tell members where the report is, in benefit and funding statements | Next statement | SI 2021/857 reg 4 |
| Give the regulator the address in the scheme return | Next scheme return | SI 2021/857 reg 3 |
Who is in scope
Two routes in: relevant assets or authorisation
Scope turns on “relevant assets”: net assets in the scheme’s audited accounts, less the value of any relevant contract of insurance, as TPR’s Appendix 2 sets out.
A scheme with a large buy-in can therefore sit below £1 billion of relevant assets with far more on its balance sheet.
A scheme that first crosses £1 billion does not start at once: under regulation 3(3) its duties begin with the scheme year that starts one scheme year and a day after the year end at which it crossed.
Authorised master trusts and authorised collective money purchase schemes are in scope whatever their size, while they stay authorised.
The Regulations extend to England and Wales and Scotland, under regulation 1(2).
The Regulator’s 2025 climate adaptation report says around 300 DB, DC and hybrid schemes have had to prepare TCFD reports.
An occupational trust scheme
tested at each scheme year end
tested at each scheme year end
£1bn or more
At the first year end on or after 1 March 2021: from 1 October 2022. At any later year end: from the scheme year starting one year and a day after it.
reg 3(2)–(3)Authorised master trust or CDC
In scope at any size, from 1 October 2021 or authorisation if later.
regs 4–5Below £500m later
The duties cease from that year end, but one final report is still due.
reg 3(5); reg 6Pillar one
Governance: oversight, and checking the people you rely on
Paragraph 1 of the Schedule requires trustees to establish and maintain oversight of the climate-related risks and opportunities relevant to the scheme.
Paragraph 2 adds processes to satisfy themselves that anyone who undertakes governance activities, and any adviser other than a legal adviser, takes adequate steps on climate risk.
In practice that reaches investment managers, investment consultants and actuaries, and the report must describe each person’s role and how the trustees check it, under ¶27(b) and (c).
The trustees remain responsible for the duties when work is delegated.
Board-level oversight of climate in companies follows a similar pattern, set out on ESG governance.
Pillar two
Strategy and scenario analysis: two scenarios, on a three-year cycle
Trustees must identify, on an ongoing basis, the climate-related risks and opportunities that will affect the investment strategy and any funding strategy over the short, medium and long term, under Schedule ¶3.
They choose the length of each period themselves, taking account of the scheme’s liabilities and its obligation to pay benefits, under ¶4.
They must then assess the impact of those risks and opportunities on the investment strategy and any funding strategy, under ¶5.
Scenario analysis must cover at least two scenarios of global temperature rise, one of them between 1.5°C and 2°C above pre-industrial levels, under ¶6.
It must assess the potential impact on assets and liabilities and the resilience of the investment and funding strategies, under ¶7.
It is required in the first scheme year, then reviewed every year, and redone if the review says so or if none was done in the two previous scheme years, under ¶¶8–11 — which DWP’s statutory guidance at ¶84 describes as at least every three scheme years.
No provision names a scenario provider; the central banks’ NGFS scenarios are a common reference set.
How companies write up the same pillar is on TCFD disclosures.
Pillar three
Risk management: three process duties
Trustees must establish and maintain processes to identify and assess climate-related risks relevant to the scheme, under Schedule ¶12.
They must establish and maintain processes to manage those risks effectively, under ¶13.
Both sets of processes must be integrated into the trustees’ overall risk management, under ¶14.
The report describes each process and the integration, under ¶27(k)–(m).
Pillar four
Metrics and targets: four metrics and one target
| Metric type | What it is | Provision |
|---|---|---|
| Absolute emissions | Total greenhouse gas emissions attributable to the scheme’s assets | Sch ¶¶15(a), 26 |
| Emissions intensity | Emissions attributable to the assets per unit of currency | Sch ¶¶15(b), 26 |
| Portfolio alignment | Alignment of the assets with limiting warming to 1.5°C above pre-industrial levels | Sch ¶¶15(ba), 19A, 26 (SI 2022/733) |
| Additional climate change metric | Any other climate metric the trustees choose | Sch ¶¶15(c), 20 |
| Target | Set on one selected metric; performance measured each year; retained or replaced | Sch ¶¶22–24 |
Each scheme year, trustees must obtain the Scope 1, 2 and 3 emissions attributable to the scheme’s assets as far as they are able, and use them to calculate the emissions metrics, under Schedule ¶18.
Scope 3 is not required in the first scheme year the duties apply, under ¶19.
The portfolio alignment metric was inserted by SI 2022/733, in force on 1 October 2022, and did not change any asset threshold.
Where data cannot be obtained for all assets, the report must say why, under ¶27(n).
How “attributable” emissions and Scope 3 work in a portfolio is set out on Scope 3 reporting requirements and GHG reporting requirements.
The report
The TCFD report: fifteen statements, signed and published
Part 2 of the Schedule lists what the report must contain, at ¶27(a) to (o): oversight, the roles of others, the risks and time horizons, their impact, the scenarios and their results, any decision not to redo scenario analysis, the risk processes, the metrics, and the target with performance against it.
The report must be produced and published within seven months of the end of each scheme year in which the governance duties applied, under regulation 6(1).
It is signed by the chair of trustees, or an interim chair appointed to sign it, under regulation 6(3).
SI 2021/857 then requires the website address in the annual report, the location of the report in members’ annual benefit statements and, for defined benefit schemes, annual funding statements.
The address also goes in the scheme return, and its Explanatory Memorandum says this lets the regulator monitor and enforce publication without searching scheme websites.
The same scheme return now records where the Statement of Investment Principles and the implementation statement are published, where those must be published.
- 1
Produce the report
The fifteen statements in Schedule Part 2, for the scheme year — reg 6(1)(a).
- 2
Chair signs
On behalf of the trustees; the handwritten signature need not be published — reg 6(3).
- 3
Publish within seven months
On a publicly available website, free of charge — reg 6(1)(b).
- 4
Annual report
Gives the website address of the report — SI 2021/857.
- 5
Members told
Annual benefit statements, and annual funding statements for DB — SI 2021/857.
- 6
Scheme return
Gives TPR the address, or says the publication period has not ended — SI 2021/857.
Beside the report
The implementation statement is a separate duty
The implementation statement is not part of the climate regime: it is a requirement of the Disclosure Regulations 2013 for schemes that must have a Statement of Investment Principles.
It must state how the SIP’s voting and engagement policies were followed, describe voting behaviour including the most significant votes, and record any use of a proxy voter, according to DWP’s June 2022 guidance at ¶67.
For DC and hybrid schemes it must also say how SIP policies on financially material considerations, including climate change, were followed, under ¶112 of that guidance.
A TCFD report does not discharge the implementation statement, and the implementation statement does not discharge the TCFD report.
Trustees often cross-refer between them, and the scheme return links both, which is the practical connection between the two.
Stewardship reporting under the voluntary FRC code sits beside both; see Stewardship Code reporting requirements.
Dates
Deadlines worked from the scheme year end
| Scheme year end | Report published by | Basis |
|---|---|---|
| 31 March | 31 October | Seven months — reg 6(1) |
| 30 June | 31 January | Seven months — reg 6(1) |
| 30 September | 30 April | Seven months — reg 6(1) |
| 31 December | 31 July | Seven months — reg 6(1) |
A scheme with a 31 March year end that first reported £1 billion of relevant assets on 31 March 2026 starts governance on 1 April 2027 and publishes its first report by 31 October 2028, applying regulation 3(3).
A scheme that drops below £500 million at a year end stops the duties from that date but still publishes the report for the year just ended.
Every TCFD-shaped deadline from one year end, for companies as well as schemes, is on TCFD reporting requirements.
Enforcement
A penalty the regulator must issue, triggered by publication
Regulation 9(2) says the regulator “must issue a penalty notice” where trustees fail to publish the report on a publicly available website, accessible free of charge.
That penalty must be at least £2,500, and the caps are £5,000 for an individual and £50,000 for any other person.
The regulator’s monetary penalties policy says it has no discretion not to issue the notice, and that “the penalty relates to the publication of the report, not its content”.
Its stated approach is that a consecutive penalty will normally be at least £5,000, and so will a penalty where a professional trustee is in place.
The first fine went to the ExxonMobil Pension Plan, whose report sat behind a faulty URL for ten days after its 31 July 2022 deadline (TPR intervention report).
Later climate reporting penalties appear on the regulator’s penalty notices list.
| Limb | Rule | Amount |
|---|---|---|
| Report not published on a public website, free of charge | TPR must issue a notice — reg 9(2) | At least £2,500 |
| Any other contravention | TPR may issue a notice — reg 9(1) | No floor |
| Cap on either limb | reg 9(4)(a) | £5,000 individual; £50,000 body corporate |
| Who is liable | All trustees, jointly and severally — reg 9(5)(a) | — |
Myths
What the requirements do not ask for
The Regulations require a target, but not a transition plan, and not a net zero commitment.
They contain no audit or assurance requirement for the report.
They do not require the full report inside the annual report and accounts, only its website address.
They do not apply to schemes under £1 billion that are neither authorised master trusts nor CDC schemes.
They do not require scenario analysis every year.
Claims still circulating that are wrong
“SI 2022/733 lowered the threshold to £1 billion” — both waves were in the 2021 Regulations; 2022 added the alignment metric.
“The fine is £2,500” — £2,500 is a floor on the mandatory penalty, not a tariff and not a maximum.
“A report that exists cannot be penalised” — a broken link was enough in the first case.
Other regimes
How it sits beside the other UK reporting requirements
The FCA’s PS26/19 puts listed companies on comply or explain against UK SRS for periods from 1 January 2027, and does not touch trust-based schemes; see UK SRS reporting requirements.
Contract-based pension providers regulated by the FCA report under its ESG sourcebook, which FCA 2026/59 simplified at product level from 25 September 2026; see SDR reporting requirements.
A sponsoring employer may have its own climate disclosures under the Companies Act, which are separate from the scheme’s; see CFD reporting requirements.
Transition plans are not required of trustees, and the wider position is on transition plan reporting requirements.
Duties that an employer and its scheme may each carry, sector by sector, are on UK sustainability reporting by sector.
What is changing
A promised review, and no outcome yet
In June 2025 the government’s UK SRS exposure draft said DWP would review the 2021 Regulations that year and consider the role of UK SRS in pension scheme climate reporting.
No outcome of that review had been published on GOV.UK when we checked on 11 October 2026, and the duties on this page are those in force on that date.
DWP’s trusteeship and governance consultation ran from 15 December 2025 to 5 March 2026 and sought views on raising standards of trusteeship, governance and administration; it is not the review of the climate Regulations.
The LGPS climate reporting consultation closed on 24 November 2022 and its page still reads “We are analysing your feedback”.
Any change to the duties themselves would need an amending instrument made by DWP.
Check yourself
Six statements about the trustee duties
Each answer names the provision it turns on.
The penalty and annual-report items are the ones most often got wrong.
The framework the duties follow is described on TCFD.
Pension scheme climate reporting: true or false?
A scheme with £800 million of relevant assets must publish a TCFD report.
Trustees must publish the report within seven months of the scheme year end.
Trustees must calculate a portfolio alignment metric.
The full TCFD report must be bound into the annual report and accounts.
The £2,500 minimum applies to every breach of the Regulations.
The Regulations require trustees to publish a transition plan.
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Frequently asked
Pension scheme climate reporting requirements, answered
What are the pension scheme climate reporting requirements in the UK?
Trustees of in-scope occupational pension schemes must run climate governance in line with the TCFD pillars — oversight, strategy, scenario analysis, risk management, metrics and a target — under the Schedule to SI 2021/839, then produce a report containing fifteen specified statements and publish it on a public website, free of charge, within seven months of the scheme year end.
The website address then goes in the annual report, members’ annual benefit statements and the scheme return.
Which pension schemes must produce a TCFD report?
Trust schemes with relevant assets of £1 billion or more at a scheme year end (the £5 billion schemes came in first, from 1 October 2021), and every authorised master trust and authorised collective money purchase (CDC) scheme regardless of size.
Smaller schemes that are neither are not in scope.
When is a pension scheme climate report due?
Within seven months of the end of each scheme year in which the governance duties applied, under regulation 6(1) of SI 2021/839.
For a 31 March year end the deadline is 31 October; for a 31 December year end it is 31 July.
Who signs the pension scheme TCFD report?
The chair of trustees signs it on behalf of the trustees, or an interim chair appointed for the purpose if there is none, under regulation 6(3).
The trustees do not have to publish the handwritten signature.
What metrics must trustees report?
At least four: an absolute emissions metric, an emissions intensity metric, a portfolio alignment metric (added by SI 2022/733 from 1 October 2022) and one additional climate change metric.
Scope 1, 2 and 3 emissions attributable to the assets must be obtained “as far as they are able”, with Scope 3 not required in the first scheme year.
What is a portfolio alignment metric?
A metric that gives the alignment of the scheme’s assets with the goal of limiting the increase in global average temperature to 1.5°C above pre-industrial levels, as defined in paragraph 26 of the Schedule after SI 2022/733.
Trustees choose which alignment metric to use.
How often is scenario analysis required?
In the first scheme year the duties apply, then a review in every later 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.
Two scenarios are needed, one between 1.5°C and 2°C.
Must the TCFD report be included in the annual report and accounts?
Not in full.
SI 2021/857 requires the website address of the report to be included in the annual report, and the location of the report to be given to members in annual benefit statements and, for defined benefit schemes, the annual funding statement.
How does the TCFD report relate to the implementation statement?
They are separate duties.
The implementation statement, under the Disclosure Regulations 2013, reports how the Statement of Investment Principles was followed, including voting and, for DC schemes, policies on financially material considerations including climate change.
The scheme return records the website address of both documents.
What is the penalty for not publishing the climate report?
The Pensions Regulator must issue a penalty notice under regulation 9(2) of SI 2021/839.
The penalty must be at least £2,500 and may not exceed £5,000 for an individual or £50,000 for a body corporate; notices go to all trustees, jointly and severally.
Other breaches carry discretionary penalties.
Has anyone been fined for a late pension climate report?
Yes.
The Pensions Regulator fined the trustees of the ExxonMobil Pension Plan £5,000 in May 2023 after a faulty URL meant the report, due by 31 July 2022, was not on a public website until 10 August 2022.
Is the pension scheme climate report subject to assurance?
No. SI 2021/839 contains no requirement for the report to be audited or assured.
The Pensions Regulator supervises compliance and penalises failure to publish, but it penalises publication, not content.
Do pension schemes need a transition plan?
No. The Regulations require a target and progress against it, but no transition plan.
The government has consulted on transition plans more widely, and none is required of pension trustees as at 11 October 2026.
Do UK SRS and the FCA’s PS26/19 apply to occupational pension schemes?
No. PS26/19 changes the listing rules for listed companies, and UK SRS is voluntary unless a regulator or law applies it.
The government said in June 2025 that DWP would review the 2021 Regulations and consider the role of UK SRS; no outcome of that review has been published on GOV.UK as at 11 October 2026.
What happens if scheme assets fall below £500 million?
The governance duties cease from that scheme year end under regulation 3(5), but the trustees must still publish a report for the scheme year that has just ended, unless an exception in regulation 6(2) applies.
The duties re-apply if the scheme later returns to £1 billion or more.
Does the regime apply to the Local Government Pension Scheme?
No. SI 2021/839 applies to trust schemes; the Local Government Pension Scheme in England and Wales was the subject of a separate consultation that closed on 24 November 2022 and still shows “We are analysing your feedback”.
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 24 sources fromlegislation.gov.ukThe Pensions RegulatorDepartment for Work and PensionsGOV.UK (MHCLG)Department for Business and TradeFinancial Conduct Authority
- legislation.gov.ukSI 2021/839 — Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021, as made
The whole regime: regs 3–6, the Schedule and the penalties.
- legislation.gov.ukSI 2021/839, regulation 3 — who is in scope by asset size
£5bn and £1bn waves, the ongoing £1bn test and the £500m exit.
- legislation.gov.ukSI 2021/839, regulation 6 — the report and its publication
Seven months; public website, free of charge; signed by the chair.
- legislation.gov.ukSI 2021/839, regulation 9 — penalty notices
“Must issue” for a publication failure; at least £2,500; caps of £5,000 and £50,000.
- legislation.gov.ukSI 2021/839, Schedule — the governance duties and the report contents
Part 1 ¶¶1–26; Part 2 ¶27(a)–(o).
- legislation.gov.ukSI 2022/733 — the portfolio alignment amendment
Inserted ¶15(ba) and ¶19A; in force 1 October 2022.
- legislation.gov.ukSI 2021/857 — Miscellaneous Provisions and Amendments Regulations 2021
Annual report, benefit statement, funding statement and scheme return links.
- legislation.gov.ukSI 2021/857 — Explanatory Memorandum
¶¶7.7–7.11: why the website address goes in the annual report and the scheme return.
- The Pensions RegulatorClimate-related governance and reporting — detailed guidance
How the regulator reads and supervises the duties.
- The Pensions RegulatorAppendix 2: when schemes are subject to the requirements
Start dates, “relevant assets” and the £500 million exit.
- The Pensions RegulatorMonetary penalties policy, Appendix 3
“We have no discretion not to issue a penalty notice.”
- The Pensions RegulatorExxonMobil Pension Plan — regulatory intervention report
The first climate reporting fine: £5,000 after a faulty URL.
- The Pensions RegulatorPenalty notices
The regulator’s published enforcement list.
- The Pensions RegulatorClimate adaptation report 2025
Around 300 schemes have had to prepare TCFD reports.
- Department for Work and PensionsStatutory guidance: governance and reporting of climate change risk
¶84 scenario analysis cycle; ¶118 the four metrics.
- Department for Work and PensionsGovernance and reporting of climate change risk: guidance for trustees
¶¶13, 18–19: the report, the website and the member disclosures.
- Department for Work and PensionsReporting on stewardship through the SIP and the implementation statement (June 2022)
¶¶67, 112: what the implementation statement must say, including on climate.
- Department for Work and PensionsTrust-based pension schemes: trustees and governance, building a stronger future (consultation)
Ran 15 December 2025 to 5 March 2026.
- GOV.UK (MHCLG)Local Government Pension Scheme (England and Wales): governance and reporting of climate change risks
Closed 24 November 2022; no response published.
- Department for Business and TradeExposure draft of UK SRS S1 and S2 (June 2025)
DWP to review the 2021 Regulations and consider the role of UK SRS.
- Financial Conduct AuthorityHandbook Notice 144 — FCA 2026/59
Product-level TCFD changes for FCA-regulated providers, not trust-based schemes.
- Financial Conduct AuthorityPS26/19 — listed issuers’ sustainability disclosures
A listing-rule change for listed companies; schemes are outside it.
- Task Force on Climate-related Financial DisclosuresRecommendations
The four pillars the Regulations follow.
- NGFSNGFS scenarios portal
A common, but not required, source of climate scenarios.
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