Trustees · metrics · fund manager data
Pension scheme climate reporting software: most of the data is someone else’s
Pension scheme climate reporting software helps trustees meet the TCFD-aligned governance and reporting duty in SI 2021/839.
Almost all the data comes from fund managers, so the software is judged on how it collects, checks and dates third-party data.
The duty is explained on the pension scheme climate reporting guide.
Who reports
Which trustees need climate reporting software?
The duty phased in by size: schemes with £5 billion or more in relevant assets from 1 October 2021, £1 billion or more from 1 October 2022, plus all authorised master trusts and authorised CDC schemes (SI 2021/839).
Trustees must publish the report within seven months of each scheme year-end.
Company climate disclosures under the Companies Act or UK SRS are separate duties for the sponsoring employer.
Metrics
What must the software calculate?
DWP’s statutory guidance asks for at least four metrics, and for scenario analysis in the first scheme year and at least every three scheme years after that (DWP).
| Metric type | Example |
|---|---|
| Absolute emissions | Total financed emissions of the portfolio |
| Emissions intensity | Emissions per £ million invested |
| Portfolio alignment | Share of the portfolio with a science-based target |
| Additional climate metric | A metric chosen by the trustees |
Enforcement
What is the risk of a missed report?
The penalty for failing to publish the report on a publicly available website is mandatory, with a floor of £2,500.
The trigger is publication, not report quality, so the software should track the publication deadline as closely as the content.
For the calculation method see financed emissions software; for corporate climate rules see climate disclosure software.
The demonstration
What should you test before buying?
Load holdings and manager data for two of your funds.
Software demo · evidence check
Trustee climate reporting demo coverage
Tick a test only when the vendor has demonstrated it with a representative record and shown the evidence or export.
0 of 5 tests demonstrated (0%). This is a checklist result, not a score for the vendor.
Still to test: Show each manager’s data, its date and how much is estimated; Calculate the four required metrics; Record scenario analysis and the year it is next due; Track the seven-month publication deadline; Export a draft report for the trustees.
Frequently asked
Pension scheme climate reporting software, answered
What is pension scheme climate reporting software?
Software that collects climate data from fund managers, calculates the scheme’s climate metrics and scenario analysis, and helps trustees publish the report SI 2021/839 requires.
Which pension schemes must publish a climate report?
Schemes with £1 billion or more in relevant assets, and all authorised master trusts and authorised collective defined contribution schemes.
Which metrics do trustees have to report?
At least four: an absolute emissions metric, an emissions intensity metric, a portfolio alignment metric and one additional climate metric.
What happens if trustees do not publish?
The penalty for failing to publish the report on a publicly available website is mandatory, with a floor of £2,500.
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.
- LegislationSI 2021/839, Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021
- DWPStatutory guidance for trustees on climate change risk
- The Pensions RegulatorClimate-related governance and reporting
- FSBAnnual progress report on climate-related disclosures, October 2023
- PCAFThe Global GHG Accounting and Reporting Standard
- GHG ProtocolScope 3 Standard (category 15)
- DBTUK SRS S2 Climate-related Disclosures
- LegislationCompanies Act 2006, section 414CB