Climate disclosure · Independent reference · Updated 21 August 2026

TCFD — Task Force on Climate-related Financial Disclosures

The Task Force on Climate-related Financial Disclosures was an industry-led body set up by the Financial Stability Board in December 2015. It published four pillars and eleven recommended disclosures in June 2017, and disbanded on 12 October 2023 FSB, Oct 2023.

The task force is gone. In the UK, four separate rulebooks still run on its architecture — and the earliest of them is proposed for deletion from 1 January 2027.

Disbanded in 2023 — and still the shape of every UK climate rule

TCFD stands for the Task Force on Climate-related Financial Disclosures. It was a thirty-odd-member industry body, chaired by Michael R. Bloomberg, asked to write a voluntary framework for reporting climate risk in mainstream financial filings — and it did that once, in 2017, and then stopped.

TCFD status — the Task Force on Climate-related Financial Disclosures was disbanded in 2023 and its monitoring work passed to the ISSB
Wound up in 2023; the monitoring went to the ISSB. Source: FSB, October 2023.

Its recommendations are structured around four pillars — governance, strategy, risk management, and metrics and targets — carrying eleven recommended disclosures between them.

Those eleven are now embedded in IFRS S2, in UK SRS S2, in the EU’s ESRS E1, and in the UK’s own statutory climate-reporting duty.

So the honest answer to is TCFD still required is not yes and not no.

The body that wrote the framework no longer exists. The obligations built on top of it are still law.

12 Oct 2023
The Task Force publishes its last report and disbands
Today
FCA listing rules and the Companies Act still require TCFD-aligned reporting
1 Jan 2027
The FCA proposes to delete its TCFD rule and require UK SRS S2 instead

Everything below is the detail behind those three dates, with the primary source under every figure.

One architecture, three owners
June 2017
TCFD
Four pillars, eleven recommended disclosures. Voluntary, and never anything else. Disbanded October 2023.
June 2023
IFRS S2
The ISSB turns the recommendations into a global baseline standard — IFRS S2.
25 Feb 2026
UK SRS S2
The UK adoption, published by the Department for Business and Trade — UK SRS S1 and S2.

The task force ends here.

The architecture does not.

Descend — the pillars, the rules, the numbers

Governance, strategy, risk management, metrics and targets

The four pillars are the Task Force’s durable contribution, and the reason a framework whose author disbanded three years ago still decides the shape of a UK annual report.

Each pillar carries one recommendation, stated in a single sentence, and two or three recommended disclosures under it.

The TCFD framework — four pillars, governance, strategy, risk management and metrics and targets, with eleven recommended disclosures
Four pillars, eleven recommended disclosures. Source: TCFD, Final Report.

The wording below is the Task Force’s own, from the June 2017 Final Report — American spelling and all, because it is a quotation.

The four recommendations, verbatim

Governance

“Disclose the organization’s governance around climate-related risks and opportunities.” Two recommended disclosures: the board’s oversight, and management’s role. The Task Force treated both as core for mainstream filings, regardless of a materiality assessment.

Strategy

“Disclose the actual and potential impacts of climate-related risks and opportunities on the organization’s businesses, strategy, and financial planning where such information is material.” Three disclosures, including resilience under a 2°C or lower scenario.

Risk management

“Disclose how the organization identifies, assesses, and manages climate-related risks.” Three disclosures: identification, management, and integration into overall enterprise risk management. Also treated as core, not materiality-gated.

Metrics and targets

“Disclose the metrics and targets used to assess and manage relevant climate-related risks and opportunities where such information is material.” Three disclosures, including Scope 1, Scope 2 and — if appropriate — Scope 3 emissions.

The split matters more than it looks.

Governance and risk management were never subject to materiality under TCFD: the Task Force expected them in the filing whether or not climate was judged financially material, because the point was to show how the question had been asked.

Strategy and metrics were.

That asymmetry is the single most misread thing about the framework, and it survives into IFRS S2 and UK SRS S2 in modified form.

The clause-level breakdown, with the successor mapping, is on the TCFD framework page.

The seven principles almost nobody quotes

Alongside the four recommendations, the Final Report set out seven principles for effective disclosure — the quality bar the eleven were meant to be judged against.

They are the part of the framework that assurance providers and regulators actually reach for when they are deciding whether a disclosure is any good, and the part almost every summary omits.

01 · Relevant
Disclosures should represent relevant information — about the organisation’s own exposure, not climate change in general. This is the principle most commonly failed, by pages of context about the Paris Agreement and none about the business.
02 · Specific and complete
Disclosures should be specific and complete — enough detail for a reader to assess exposure, and no material omission left unexplained.
03 · Clear and balanced
Disclosures should be clear, balanced and understandable. Balanced is the operative word: opportunities without risks, or targets without performance against them, fails here.
04 · Consistent over time
Disclosures should be consistent over time, so a reader can see a trend. A methodology change is permitted; an unexplained one is not.
05 · Comparable
Disclosures should be comparable among organisations within a sector, industry or portfolio. This is the principle IFRS S2 pursues through SASB-based industry metrics.
06 · Reliable and verifiable
Disclosures should be reliable, verifiable and objective — which in practice means a number an assurer can trace to a source, not a number a team agreed on.
07 · Timely
Disclosures should be provided on a timely basis. IFRS S2 hardens this into a rule: the same reporting period, published at the same time as the financial statements.

Read against those seven, the weakness in most UK climate reporting is not effort.

It is principle one and principle six: a great deal of relevant-sounding narrative, and very few numbers anyone outside the company could check.

Principles five, six and seven are the three the ISSB turned from guidance into requirement — which is exactly why the migration to UK SRS S2 is harder than a reformatting job.

The full text is in the Task Force’s own recommendations page, preserved as a 2023 snapshot.

The eleven recommended disclosures, and what each became

Two under governance, three under strategy, three under risk management, three under metrics and targets. Eleven in total — the number people quote and rarely enumerate.

Select any one below to read the Task Force’s exact wording, whether it was gated on materiality, and what replaced it under IFRS S2 and UK SRS S2.

Governance a)
Describe the board’s oversight of climate-related risks and opportunities.
Core — not gated on materiality
SuccessorIFRS S2 paragraph 6(a) — carried over, with the governance body or individual named and its competencies described.

Read straight through, the eleven are less a checklist than a single argument: who is accountable, what could happen, how you find it, and what you measure.

The practical drafting guidance for each — what a weak answer looks like and what an assurer asks next — is on TCFD disclosures, disclosure by disclosure.

One correction worth making early, because it is repeated everywhere.

The Task Force did not require Scope 3 of everyone: its October 2021 guidance said all organisations should disclose absolute Scope 1 and Scope 2 emissions independent of a materiality assessment, while Scope 3 remained subject to materiality and was merely encouraged.

That is the position IFRS S2 changed, and the change is the reason most migration projects are longer than expected.

What a disclosure that passes actually contains

The most common failure in a TCFD or CFD section is not a missing disclosure. It is a disclosure that answers the heading rather than the question underneath it.

Here is what a reviewer looks for under each pillar, and the weak answer that usually appears instead.

G
Governance. Name the committee, say how often it took a climate item, and say what it decided. The weak answer: “the Board has oversight of climate-related matters” — a sentence that would be true of a company that had never discussed climate at all.
S
Strategy. Name the specific risks, give the horizons in years and say why those horizons, then state which of them changed a decision. The weak answer: a table of generic transition and physical risks with no horizon and no consequence.
S
Scenario analysis. Name the scenarios, the provider, the warming levels and reference periods, and what the analysis found — including where it found the business resilient. The weak answer: “we have considered a range of climate scenarios”, with no scenario named.
R
Risk management. Show climate risks sitting in the same register, with the same scoring, as every other principal risk. The weak answer: a parallel climate risk process that never meets the enterprise risk framework.
M
Metrics and targets. Give the base year, the boundary, the methodology, performance against the target, and the calculation behind each KPI — the Companies Act duty asks for the calculation explicitly. The weak answer: a target with no base year and a percentage with no denominator.

Two structural mistakes are worth naming separately, because both are compliance failures rather than quality ones.

Putting the disclosures outside the annual report. Under the Companies Act duty the information must be in the strategic report, and the FRC has said cross-referring to a standalone sustainability report does not comply.

Explaining without explaining. Under the listing rule, a company that does not comply must say why and set out any steps it is taking — a bare statement of non-compliance is not the explain half of comply-or-explain.

HM Treasury’s public-sector guidance publishes a full worked compliance statement, and although it binds only government bodies, it is the clearest published model of the shape a complete statement takes.

From a G20 request to a closed website, in eight years

The Task Force existed for seven years and ten months. It published one set of recommendations, updated its guidance once, and issued six annual status reports.

April 2015
The G20 asks the question
G20 Finance Ministers and Central Bank Governors ask the Financial Stability Board to convene public and private participants to review how the financial sector can take account of climate-related issues.
4 December 2015
The FSB establishes the Task Force
Announced at COP21 in Paris, under the chairmanship of Michael R. Bloomberg, to develop voluntary, consistent climate-related financial risk disclosures — FSB press release.
21 January 2016
Membership announced
Four vice chairs and an initial membership drawn from preparers, users and assurers of disclosure — FSB.
29 June 2017
The final recommendations
Four pillars, eleven recommended disclosures, seven principles for effective disclosure, and a technical supplement on scenario analysis — Final Report (PDF).
1 January 2021
The UK makes it a listing rule
Premium-listed commercial companies must make TCFD-aligned disclosures on a comply-or-explain basis for accounting periods beginning on or after this date — FCA PS20/17.
14 October 2021
The guidance is updated, the recommendations are not
A new annex plus guidance on metrics, targets and transition plans: seven cross-industry metric categories, interim targets, and Scope 1 and 2 disclosure independent of materiality. The four recommendations and eleven disclosures are unchanged — Metrics, Targets and Transition Plans (PDF).
6 April 2022
The UK makes it a statutory duty
The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 come into force, catching large private companies the listing rules never touched — SI 2022/31.
13 July 2023
The FSB hands monitoring to the IFRS Foundation
Following the ISSB’s publication of IFRS S1 and S2, the FSB asks the ISSB to take over monitoring of firms’ climate-related disclosures, and states that the 2023 status report will be the Task Force’s final task — FSB.
12 October 2023
The last report, and the end
The 2023 Status Report is published and the Task Force disbands the same day — FSB.
12 November 2024
The IFRS Foundation reports in its place
The first Progress on Corporate Climate-related Disclosures report, on a 3,814-company sample — IFRS Foundation (PDF).
25 February 2026
UK SRS S1 and S2 are published
The Department for Business and Trade publishes the UK adoption of the ISSB standards, for voluntary use — GOV.UK.
1 January 2027
The listing rule is proposed to go
Under FCA CP26/5, the TCFD-aligned requirement is deleted and UK SRS S2 takes its place for accounting periods beginning on or after this date. Proposed, not yet made.

The Task Force’s own website, fsb-tcfd.org, is still online in 2026 and still serves the original documents.

It carries a notice saying it has not been updated or monitored since November 2023, which is worth knowing before you cite anything from it as current.

Who was actually on the Task Force

A recurring search that almost nothing answers properly: the TCFD was not a regulator and not a standard-setter, and its membership is the reason its output reads the way it does.

It was chaired by Michael R. Bloomberg, and the FSB announced four vice chairs on 21 January 2016 FSB.

Chair
Michael R. Bloomberg
Bloomberg L.P.
Vice Chair
Denise Pavarina
Banco Bradesco
Vice Chair
Graeme Pitkethly
Unilever — then Chief Financial Officer
Vice Chair
Christian Thimann
AXA
Vice Chair
Yeo Lian Sim
Singapore Exchange
Special Adviser
Russell Picot
HSBC

The full membership ran to roughly thirty people and changed over the Task Force’s life — the FSB recorded 32 members around publication in June 2017 and 30 at the end.

The names are in the FSB’s own membership list (PDF).

What matters about that composition is the balance: preparers, users and assurers of disclosure in one room, deliberately, rather than an accounting body writing for accountants.

It is why the recommendations read as management questions rather than as line-item requirements — and also why they were never enforceable on their own.

On the TCFD secretariat: the Task Force operated with a secretariat and published a press contact under that name, but we have not found a primary source that states who hosted or staffed it, so this page does not assert one.

The FSB’s own secretariat — a different body — is hosted by the Bank for International Settlements in Basel.

What happened on 12 October 2023

The Task Force was not wound up in a dispute and it did not fail. It was retired because the thing it was created to prototype had been turned into a standard by somebody with the authority to maintain one.

The sequence has two dates, and most write-ups collapse them into one.

On 13 July 2023, after the ISSB issued IFRS S1 and IFRS S2, the FSB asked the ISSB to take over monitoring the adoption of climate-related disclosures, and said in the accompanying roadmap that the 2023 status report would be the Task Force’s final task FSB roadmap (PDF).

On 12 October 2023, that report was published and the Task Force disbanded.

Concurrent with the release of its 2023 status report on October 12, 2023, the TCFD has fulfilled its remit and disbanded. The Task Force’s own closing notice — fsb-tcfd.org

The IFRS Foundation took the monitoring role from 2024, and states plainly that “IFRS S1 and IFRS S2 fully incorporate the recommendations of the TCFD” IFRS Foundation.

Two consequences follow, and both catch people out.

The supporters list is closed. The register of organisations declaring support for the recommendations is no longer maintained, so there is no current, official list of TCFD-reporting companies to consult — the IFRS Foundation says so on the same page.

Nothing was repealed. A disbanded task force cannot withdraw a UK statutory instrument or an FCA listing rule, and neither has been withdrawn.

If your obligation came from UK law, it is still there, and it is still described in the Task Force’s vocabulary.

How many companies actually disclosed against all eleven

Very few, and the honest number is smaller than the headline that usually travels with it.

Two datasets exist, they were built on different samples, and they are routinely quoted as if they were one trend.

They are not, so this page shows them separately and says which is which.

Fiscal year 2022 · more than 1,350 large companies
Source: TCFD 2023 Status Report, 12 October 2023.

Do not read across the two panels. The Task Force reviewed a three-year panel of more than 1,350 large companies; the IFRS Foundation reviewed 3,814 public companies.

A larger sample reaches further down the size distribution, where disclosure is thinner, so the same underlying reality produces a lower percentage.

The one number both agree on is the tail: somewhere between two and four per cent of companies disclosed against all eleven.

On supporters, the Task Force recorded over 4,800 organisations declaring support as of September 2023 2023 Status Report (PDF).

Its own timeline records “4,000+ supporters from 100+ countries” in November 2022; the widely repeated figure of 102 jurisdictions does not appear in any TCFD or FSB source we can find, so this page does not use it.

There is also no 2025 successor report: the FSB folded the standalone annual disclosure-progress report into its Climate Roadmap 2025 update, so the November 2024 report remains the most recent dedicated dataset.

Is there a list of TCFD reporting companies?

Not an official, current one — and the reason is worth understanding before you go looking, because several sites still imply otherwise.

The Task Force maintained a voluntary register of supporters: organisations that publicly declared their backing for the recommendations.

That register passed 4,800 organisations by September 2023, and it was never a list of reporters — declaring support and publishing a TCFD-aligned report were always two different things.

Since the Task Force disbanded, the register has not been maintained, and the IFRS Foundation states plainly that the list of supporters is no longer active.

So the honest substitutes are these, and each answers a slightly different question.

Who is legally required
In the UK, every issuer in UKLR categories 6, 14, 15, 16 and 22, and every company or LLP in scope of SI 2022/31 or SI 2022/46. That is a defined perimeter, and it is the closest thing to a list of UK TCFD reporters that exists.
Who actually reported
The IFRS Foundation’s 2024 progress report analyses a 3,814-company sample and publishes the distribution, though not the company names.
Who is moving to the successor
The IFRS Foundation publishes jurisdictional profiles; as of June 2025, 36 jurisdictions had adopted or were finalising steps towards the ISSB Standards.
The archived register
The supporters pages remain on fsb-tcfd.org as a 2023 snapshot. Usable as history, not as evidence that an organisation still reports.

If what you actually need is peer disclosures to benchmark against, the practical route is the annual reports themselves.

Every UK listed company in scope has published its TCFD-aligned section in its annual financial report since 2021 or 2022, and those are public documents.

The FCA listing rule — UKLR 6.6.6R(8), comply or explain

If you are a UK-listed commercial company, your TCFD obligation is a listing rule, and it is the one with a deletion date attached to it.

The rule is UKLR 6.6.6R(8) in the FCA’s UK Listing Rules sourcebook, which has applied since 29 July 2024.

It binds issuers of equity shares in commercial companies — the category the old premium and standard listing segments were merged into — and reaches four further categories through parallel rules.

UKLR 6.6.6R(8)
Equity shares (commercial companies), UK-incorporated. UKLR 6.6.17R applies the same duty to overseas companies in the category.
UKLR 14.3.24R
International secondary listings. Proposed to lose the TCFD duty entirely under CP26/5, replaced by a signposting statement.
UKLR 15.3.1R(3)
Certificates representing certain securities — depositary receipts. Same proposed treatment as UKLR 14.
UKLR 16.3.23R
Non-equity shares and non-voting equity shares. Proposed to move to UK SRS S2.
UKLR 22.2.24R
The transition category. Proposed to move to UK SRS S2.
LR 9.8.6R(8)
Deleted. The old premium-listing rule, and LR 14.3.27R with it, ceased to exist on 29 July 2024 — a live citation to either is out of date.

The duty is comply or explain: state whether the disclosures are consistent with the TCFD recommendations, and if not, explain why.

The FCA narrows that in guidance at UKLR 6.6.11G, saying it would ordinarily expect a listed company to be able to disclose rather than explain, except where it faces genuine transitional data or modelling difficulties.

The commencement dates came in two waves: accounting periods beginning on or after 1 January 2021 for premium-listed companies PS20/17, and 1 January 2022 for standard-listed issuers PS21/23.

The FCA’s current interpretation sits in Technical Note 802.3, January 2026 TN 802.3 (PDF), finalised through Primary Market Bulletin 61 and effective 19 January 2026.

If your adviser’s note cites TN 802.2, it predates that update.

The full threshold and scope breakdown is on TCFD UK requirements.

The Companies Act duty — eight disclosures, and no comply-or-explain

The second UK rulebook is statutory, it catches companies no listing rule ever touched, and it is stricter than the listing rule in the way that actually matters.

The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 SI 2022/31 were made on 17 January 2022 and came into force on 6 April 2022, applying to financial years commencing on or after that date.

A parallel instrument, SI 2022/46, does the same for limited liability partnerships.

They insert the duty into the Non-Financial and Sustainability Information Statement inside the strategic report, via sections 414C, 414CA and 414CB of the Companies Act 2006.

Five categories of entity are caught, and every one of them requires more than 500 employees — measured as an average monthly headcount across the financial year.

01
Relevant public interest entities already producing a non-financial information statement — UK companies with transferable securities on a UK regulated market, banking companies and insurance companies — with more than 500 employees.
02
AIM companies with more than 500 employees.
03
Other UK companies with more than 500 employees and turnover above £500m — aggregate group turnover above £500m net, for a parent.
04
Large LLPs that are neither traded nor banking, with more than 500 employees and turnover above £500m.
05
Traded or banking LLPs with more than 500 employees.

Note what categories 1, 2 and 5 do not say: no turnover test.

The “500 employees and £500m turnover” shorthand you will see quoted everywhere is only categories 3 and 4, and using it as the whole test under-scopes the regime.

The duty itself is eight disclosures, set out at section 414CB(2A): governance arrangements; how risks and opportunities are identified, assessed and managed; how those processes integrate into overall risk management; the principal risks and opportunities and the time periods over which they are assessed; the actual and potential impacts on business model and strategy; a resilience analysis under different climate scenarios; the targets used; and the key performance indicators and the calculations behind them.

Directors may omit items five to eight only, under section 414CB(4A), where they reasonably believe the disclosure is not necessary for an understanding of the business — and they must give a clear and reasoned explanation for doing so.

Items one to four carry no such exemption.

And unlike the listing rule, this is not comply or explain: the information must be in the annual report, and the Financial Reporting Council has said that putting it in a separate sustainability report and cross-referring does not comply FRC thematic review, 21 January 2025.

That review looked at twenty AIM and large private companies and found resilience analysis and targets the weakest areas, with only around half providing full target and KPI information.

One date to diarise: regulation 5 of SI 2022/31 requires the Secretary of State to publish a statutory review of the regulations before 6 April 2027.

The two UK regimes nobody writes about

Beyond listed companies and large companies, TCFD-aligned reporting is also a duty for asset managers, for pension scheme trustees, and for central government — each under a different instrument, on a different clock.

Asset managers, life insurers and FCA-regulated pension providers report under the FCA’s ESG sourcebook, created by PS21/24 in December 2021.

Entity-level reports sit at ESG 2.2 and product-level reports at ESG 2.3, published annually by 30 June.

The largest firms came in from 1 January 2022, filing first by 30 June 2023; firms above the £5bn assets-under-management threshold followed a year later.

That regime is now changing: the FCA’s CP26/17, published 5 June 2026 and closed 13 July 2026, proposes to remove product-level TCFD reporting entirely and replace it with a materiality-based retail rule, keeping entity-level reporting for now.

Occupational pension scheme trustees have their own regime under the Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021.

Schemes with £5bn or more in relevant assets came into scope from 1 October 2021 and those with £1bn or more from 1 October 2022, with authorised master trusts brought in from 1 October 2021 or the date of authorisation.

Trustees must publish a TCFD report within seven months of the scheme year end, and a scheme leaves the regime only once relevant assets fall below £500m.

Central government departments and arm’s-length bodies report under HM Treasury’s TCFD-aligned disclosure application guidance, which is the most detailed TCFD scenario-analysis guidance the UK government publishes.

It is also, in our reading, the page most often mistaken for corporate guidance — it is written for the public sector and its scoping rules are not the Companies Act ones.

None of these three regimes is touched by the FCA’s listing-rule proposal, so “TCFD ends in 2027” is wrong for most of the organisations that report under it.

Which rulebook binds you, and what changes in 2027

Four regimes, four scope tests, four different answers to “is TCFD mandatory”. Answer three questions and this works out which one is yours.

Nothing is stored and nothing is sent anywhere — the logic runs in your browser against the scope tests cited above.

This is a scope indicator built from the published tests, not a legal opinion, and the Companies Act employee test in particular is an average monthly headcount that only your own payroll data settles.

If it returns more than one regime, that is not a bug — a large listed company with over 500 employees is genuinely inside two of them at once.

Scenario analysis — the disclosure that fails most often

Strategy (c) is the only one of the eleven that asks an organisation to describe a future it has not had, and it is consistently the weakest disclosure in UK reporting.

The Task Force’s wording asks you to “describe the resilience of the organization’s strategy, taking into consideration different climate-related scenarios, including a 2°C or lower scenario”.

Three things about that sentence do most of the work.

It says scenarios, plural. One pathway is a forecast, and a forecast is not a resilience test.

It names a floor, not a target. The 2°C-or-lower scenario is the minimum set member, and a higher-warming physical-risk pathway is normally needed alongside it for the analysis to say anything.

It asks about the strategy, not the emissions. The output is a statement about business model resilience, not a carbon number.

Under the Companies Act duty the requirement is firmer still: section 414CB(2A) asks for “an analysis of the resilience of the company’s business model and strategy, taking into consideration different climate-related scenarios”, and the FRC’s January 2025 thematic review found this among the two weakest areas in practice.

For UK-specific physical pathways, HM Treasury’s public-sector guidance points preparers at UKCP18 and the Met Office’s headline findings, and works in global warming levels with near-term, 2050s and 2080–2100 reference periods, with a refresh at least every three years.

That is public-sector guidance and it does not bind a company — but it is the clearest published statement of what a defensible UK scenario set looks like, and it is free.

Under UK SRS S2 this becomes a structured resilience assessment with its inputs, assumptions and uncertainties disclosed, run every year — but the Standard stops short of requiring it to be quantified: an approach “commensurate with the entity’s circumstances” is expressly permitted, and qualitative scenario narratives can stand on their own as a reasonable basis.

The scenario section is the single largest piece of new work in most migrations — see the TCFD to UK SRS migration guide.

Transition plans — recommended, never required

The TCFD’s October 2021 guidance introduced transition plans, the UK built a whole taskforce around them, and there is still no UK legal duty to have one.

Getting this distinction right matters, because “mandatory transition plans” is one of the most confidently repeated inaccuracies in UK climate reporting.

The Transition Plan Taskforce was launched by HM Treasury in April 2022, published its Disclosure Framework in October 2023 and seven sector guidance documents in April 2024.

In June 2024 the IFRS Foundation took responsibility for its disclosure-specific materials, and the Taskforce completed its work and disbanded in October 2024 IFRS Sustainability Knowledge Hub.

Its materials are still available, and still widely used; they are guidance, not law.

The government consulted on requirements between 25 June and 17 September 2025, on options including mandating the development and the publication of transition plans DESNZ consultation.

As of 6 August 2026 no government response has been published, and the consultation page still records that responses are being analysed.

The FCA has taken the narrower route in the meantime.

CP26/5 proposes a disclose-or-explain statement — whether a transition plan has been published and where, or why not — expressly declining to mandate the plan itself on the basis that this is a matter for government.

And UK SRS S2 does what IFRS S2 does: if you have a transition plan, you disclose it, with its key assumptions, dependencies and any planned use of carbon credits.

The obligation is conditional on having one, not an obligation to make one.

Which leaves a real strategic question rather than a compliance one: a plan published voluntarily now is disclosed on your own terms, and a plan published after a mandate is disclosed on someone else’s.

Scope 3 under TCFD, and why it got harder

Metrics and targets (b) asks for “Scope 1, Scope 2, and, if appropriate, Scope 3 greenhouse gas (GHG) emissions, and the related risks”. Those three words did a great deal of load-bearing.

The Task Force’s October 2021 guidance tightened Scopes 1 and 2 and left Scope 3 alone.

Its position, verbatim: all organisations should disclose absolute Scope 1 and Scope 2 emissions independent of a materiality assessment, while disclosure of Scope 3 remains subject to materiality, though organisations are encouraged to disclose it 2021 Annex (PDF).

So a company could comply with the TCFD recommendations while reporting no Scope 3 at all, provided it had assessed materiality and said so.

IFRS S2 removes that latitude: Scope 3 is required, across the fifteen GHG Protocol categories, with the categories disclosed and the measurement approach explained.

The ISSB then eased specific parts of the requirement in December 2025, through Amendments to Greenhouse Gas Emissions Disclosures — GICS is no longer mandatory for disaggregation, and derivatives, facilitated emissions and insurance-associated emissions are excluded from the Scope 3 measure IFRS S2, ISSB.

Those amendments are carried into UK SRS S2.

In the UK the FCA proposes a further softening at the entry point: under CP26/5 Scope 3 would be comply-or-explain with an optional one-year relief, which in practice means the first Scope 3 statements land for accounting periods beginning on or after 1 January 2028.

The relief is a year to build the value-chain pipeline, not a year in which the pipeline is not needed — the category work is on Scope 3 emissions.

What replaced TCFD — IFRS S2, and what it tightened

IFRS S2 keeps the four pillars and all eleven recommended disclosures and then raises the bar on almost every one. The IFRS Foundation has published a clause-by-clause comparison saying exactly that.

Its own statement is unambiguous: “IFRS S1 and IFRS S2 fully incorporate the recommendations of the TCFD” IFRS S2 ↔ TCFD comparison (PDF).

The uplift concentrates in six places.

Emissions
Scope 1, 2 and 3 required, measured under the GHG Protocol Corporate Standard, with Scope 2 disclosed on a location basis and the fifteen Scope 3 categories identified. TCFD left Scope 3 to materiality.
Scenario analysis
A quantified resilience assessment run every reporting period, with inputs, assumptions, analytical choices and uncertainties disclosed. TCFD accepted a narrative.
Financial effects
Current and anticipated effects on financial position, financial performance and cash flows, connected to the financial statements. TCFD asked for impact on “businesses, strategy and financial planning”.
Industry metrics
Industry-based disclosure topics and metrics drawn from the SASB Standards. TCFD had illustrative sector guidance, which the 2021 update withdrew.
Timing
Sustainability information reported at the same time as the financial statements, for the same reporting entity and the same period.
Transition plans
Where a transition plan exists it must be disclosed, with key assumptions, dependencies, and any planned use of carbon credits. TCFD guidance recommended, but the standard requires.

What did not change is the frame: four pillars, eleven disclosures, mainstream filing.

That continuity is the practical good news for anyone with three years of TCFD reports behind them — the governance and risk-management disclosures largely carry over as written.

The side-by-side is on TCFD vs UK SRS S2.

The UK version — UK SRS S2, published 25 February 2026

The UK did not adopt IFRS S2 unchanged, and it has not yet made it mandatory for anybody. Both facts matter for planning.

The Department for Business and Trade published UK SRS S1 and UK SRS S2 on 25 February 2026, alongside its response to the 2025 exposure-draft consultation GOV.UK.

As published they are available for voluntary use — the mandate has to come from the FCA for listed issuers, or from legislation for anyone else.

The UK-specific changes to the ISSB text are worth naming individually, because the commonly quoted count of “six amendments” is an advisory-firm summary rather than a figure the government publishes.

01

No first-year timing relief

IFRS S1’s relief allowing sustainability information to be published later than the financial statements is removed.

02

Non-climate relief — proposed, then dropped

The TAC’s December 2024 recommendation, carried into the June 2025 exposure draft, extended the climate-only relief from one year to two; the final Standards published in February 2026 removed the fixed duration altogether instead (see 03).

03

Time limits removed from the reliefs

The non-climate and Scope 3 reliefs lose their fixed durations, so voluntary users may apply them indefinitely; the duration for mandatory reporters is set by the FCA or by legislation instead. The GHG Protocol first-year relief keeps its time limit.

04

Effective-date clauses removed

Effective dates are to be set by regulation, not by the standard.

05

SASB guidance becomes optional

References to industry-based guidance change from “shall” to “may”.

06

Financed emissions “explain” route

A new provision lets financial institutions explain where financed emissions cannot be estimated for the same period as the financial statements.UK only

The ISSB’s December 2025 amendments to IFRS S2 are carried across; its accompanying effective-date and transition amendments are not.

One provision quietly removes a duplication problem: UK SRS S2 is a “national reporting framework” for the purposes of section 414CB(6) of the Companies Act 2006, so a company reporting under S2 need not repeat its statutory CFD disclosures, provided the section’s conditions are met and the use of UK SRS S2 is clearly referenced.

The mandate itself is still a proposal. CP26/5, Aligning listed issuers’ sustainability disclosures with international standards, was published on 30 January 2026 and closed on 20 March 2026; the Policy Statement is expected in autumn 2026.

It proposes UK SRS S2 for UKLR categories 6, 16 and 22 from accounting periods beginning on or after 1 January 2027, Scope 3 on comply-or-explain with a one-year relief, wider S1 sustainability reporting on comply-or-explain with a two-year relief, and a disclose-or-explain statement about transition plans rather than a duty to have one.

Categories 14 and 15 — secondary listings and depositary receipts — lose the TCFD requirement and get a signposting statement instead of a UK SRS duty.

The full proposal is on the FCA and UK SRS.

Your existing TCFD reporting is the foundation, not wasted work

Whichever rulebook the checker returned, the order of work is the same, because the four gaps between a good TCFD report and a UK SRS S2 report are the same four gaps every time.

Carries over
Governance and risk management
Board oversight, management’s role, identification, management and integration — largely as written. This is roughly half the eleven and the half most companies already do well.
Gap one
Structure the scenario analysis
Narrative resilience becomes a disclosed assessment with named inputs, assumptions and uncertainties, refreshed every year — quantification itself is not required, but showing the workings is. The longest capability build on the list.
Gap two
Build the Scope 3 pipeline
Fifteen categories, supplier data you have not asked for yet, and a methodology an assurer can follow. Start before the relief year, not during it — Scope 3 emissions.
Gap three
Connect it to the financial statements
Current and anticipated effects on financial position, performance and cash flows, reported at the same time as the accounts. This is a reporting-calendar change as much as a disclosure one.
Gap four
Decide the industry metrics
SASB-based topics and metrics — required under IFRS S2, optional under UK SRS S2. Decide deliberately, and say which you applied.

Done in that order, the work compounds: the scenario capability feeds the financial-effects disclosure, and the Scope 3 pipeline feeds the targets.

Done in reverse, you build a Scope 3 dataset before you know which risks it is supposed to quantify.

If this page is more detail than you needed, the shortest route through is TCFD reporting requirements; if you already report and want the mapping, it is TCFD to UK SRS migration.

You came for a framework.

You leave knowing which rule binds you.

One sentence first

The Task Force on Climate-related Financial Disclosures disbanded on 12 October 2023, and its four pillars and eleven recommended disclosures are still the shape of every climate-reporting duty a UK organisation has.

TCFD in six facts

4 pillars, 11 disclosures
Governance 2, strategy 3, risk management 3, metrics and targets 3. Published 29 June 2017.
Disbanded 12 October 2023
The Task Force fulfilled its remit; the IFRS Foundation took over monitoring from 2024.
Four UK rulebooks still apply
FCA listing rules, the Companies Act duty, the FCA ESG sourcebook, and occupational pension schemes.
CFD is not TCFD
The statutory duty is mandatory and fixes the location; the listing rule is comply-or-explain.
2–4% did all eleven
On both published datasets, full alignment with all eleven disclosures stayed in low single figures.
1 January 2027, proposed
The FCA proposes to delete the TCFD listing rule and require UK SRS S2 instead. Policy Statement due autumn 2026.

You know what TCFD asked for. The next question is what your own first UK SRS S2 filing has to add to it.

Map your TCFD report to UK SRS S2 Or check the UK thresholds — who reports under which instrument
The sourced record
Key facts

TCFD — key figures, dated and sourced

Established
4 December 2015 — announced by the Financial Stability Board at COP21, chaired by Michael R. Bloomberg.
Recommendations
29 June 2017 — four pillars, eleven recommended disclosures, seven principles for effective disclosure.
Guidance update
14 October 2021 — seven cross-industry metric categories and transition-plan guidance; the eleven disclosures unchanged.
Disbanded
12 October 2023 — the same day its final status report was published.
Monitoring since
2024 — the IFRS Foundation, at the FSB’s request of 13 July 2023.
Supporters at close
Over 4,800 organisations as of September 2023. The list is no longer maintained.
Full alignment
4% of companies disclosed against all eleven in FY2022 (TCFD sample); 2–3% in FY2023 (IFRS Foundation sample).
UK listing rule
UKLR 6.6.6R(8), comply-or-explain, in force since 29 July 2024. Guidance: TN 802.3, January 2026.
UK statutory duty
SI 2022/31 and SI 2022/46 — eight disclosures, financial years from 6 April 2022.
Successor standard
UK SRS S2, published 25 February 2026. Voluntary today; proposed mandatory from 1 January 2027.
Why it mattered

The framework that moved climate out of the CSR report

TCFD’s durable achievement was not the eleven disclosures themselves.

It was the decision to put climate risk in the mainstream financial filing, addressed to lenders, insurers and investors, rather than in a separate sustainability publication addressed to nobody in particular.

Every regime that followed inherited that choice.

The ISSB Standards mark the culmination of the work of the TCFD. Companies applying IFRS S1 and IFRS S2 will meet the TCFD recommendations as the recommendations are fully incorporated into the ISSB Standards. IFRS Foundation, July 2023

One caution on secondary sources: the IFRS Foundation’s own July 2023 news item describes the TCFD as “established in 2017”, which is wrong — 2017 is when it published, and 2015 is when it was created.

That error is now widely copied, and it is the fastest way to spot a page that has not checked its sources.

FAQ

TCFD — frequently asked

What is TCFD?

The Task Force on Climate-related Financial Disclosures (TCFD) was an industry-led body established by the Financial Stability Board in December 2015 to develop voluntary, consistent climate-related financial risk disclosures. The TCFD published its recommendations in June 2017, structured around four pillars (governance, strategy, risk management, metrics and targets) and 11 recommended disclosures. The TCFD fulfilled its remit and disbanded on 12 October 2023; the IFRS Foundation took over monitoring of company progress from 2024.

Is TCFD still required in the UK?

Yes — for the time being, and under more than one instrument. FCA rule UKLR 6.6.6R(8) requires issuers of equity shares in commercial companies to make comply-or-explain TCFD-aligned disclosures in their annual financial report, with parallel rules for UKLR categories 14, 15, 16 and 22. Large UK companies and LLPs with more than 500 employees (and, in two of the five categories, turnover above £500m) must publish climate-related disclosures under the Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 (SI 2022/31) and SI 2022/46. Asset managers report under the FCA’s ESG sourcebook and pension scheme trustees under the Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021. The FCA proposes to replace the TCFD-aligned listing rules with mandatory UK SRS S2 for accounting periods beginning on or after 1 January 2027, subject to the Policy Statement on CP26/5 expected autumn 2026.

What are the four TCFD pillars?

Governance, Strategy, Risk Management, and Metrics & Targets. This four-pillar structure is TCFD’s lasting contribution — it has been adopted by IFRS S1 and IFRS S2, UK SRS S1 and S2, the EU’s ESRS, and most other climate-disclosure regimes.

What are the 11 TCFD recommended disclosures?

Two under Governance (board oversight, management’s role), three under Strategy (risks and opportunities by time horizon, business and financial impact, scenario analysis including a 2°C or lower scenario), three under Risk Management (identification, management, integration), and three under Metrics & Targets (metrics, Scope 1/2/3 GHG emissions, targets and performance). Governance and risk management were treated as core for mainstream filings regardless of materiality; strategy and metrics were gated on materiality. The full text of each is set out above, and the clause-level breakdown is on our TCFD framework page.

What replaced TCFD?

IFRS S2 Climate-related Disclosures, issued by the ISSB in June 2023, fully incorporates the TCFD’s four pillars and 11 recommendations. The IFRS Foundation took over monitoring company progress from the TCFD in 2024. In the UK, UK SRS S2 — the UK adoption of IFRS S2, published by the Department for Business and Trade on 25 February 2026 — would replace the TCFD-aligned FCA listing rules from 1 January 2027 if the FCA’s CP26/5 proposals are confirmed.

What is the difference between TCFD and IFRS S2?

IFRS S2 keeps TCFD’s four pillars and 11 recommendations intact but tightens almost every requirement. Key uplifts: quantified scenario analysis rather than narrative, mandatory Scope 1, 2 and 3 emissions following the GHG Protocol, industry-specific metrics drawn from SASB, explicit connectivity to the financial statements, and information provided at the same time as financial reporting.

Is TCFD disbanded, and does the website still work?

Yes. The Task Force disbanded on 12 October 2023, the same day it published its final status report, and its own site carries a notice to that effect. fsb-tcfd.org remains online in 2026 and still serves the original documents, but it states that it has not been updated or monitored since November 2023 — so treat anything on it as a 2023 snapshot rather than current guidance.

What is the difference between CFD and TCFD?

TCFD is the voluntary framework written by the Task Force. CFD — climate-related financial disclosures — is the UK statutory duty under SI 2022/31, which is mandatory, must sit in the strategic report, and specifies eight disclosures with a permit-to-omit on only four of them. A third abbreviation, CfD or Contracts for Difference, is the UK’s low-carbon electricity price support scheme and is unrelated to climate reporting.

Is there a list of TCFD reporting companies?

Not an official current one. The TCFD maintained a register of supporting organisations, which passed 4,800 by September 2023, but the IFRS Foundation confirms that the list is no longer active now that the Task Force has disbanded. The nearest substitutes are the IFRS Foundation’s Progress on Corporate Climate-related Disclosures report, which analyses a 3,814-company sample, and the UK regulatory perimeter itself — every issuer in UKLR categories 6, 14, 15, 16 and 22 and every company in scope of SI 2022/31 is a TCFD-aligned reporter by law.

Who was on the TCFD?

Michael R. Bloomberg chaired it. The FSB announced four vice chairs in January 2016: Denise Pavarina of Banco Bradesco, Graeme Pitkethly of Unilever, Christian Thimann of AXA, and Yeo Lian Sim of Singapore Exchange, with Russell Picot of HSBC as special adviser. Membership ran to roughly thirty people drawn from preparers, users and assurers of disclosure, and changed over the Task Force’s life — the FSB recorded 32 members around publication in 2017 and 30 at the end.

Authority sources

Primary references

Every figure on this page traces to one of these. Where a source is a snapshot rather than current guidance, it says so.

Last verified 6 August 2026. Where this page reports a proposal — CP26/5, CP26/17, the transition-plan consultation — it is a proposal, not law, and is marked as such in the text.

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