TCFD reporting requirements — UK guide 2026
Two parallel UK regimes require TCFD-aligned climate disclosure: FCA Listing Rules for ~1,200 listed issuers and SI 2022/31 for ~1,300 large UK companies and LLPs with 500+ employees. Both are proposed to be replaced or reshaped by UK SRS S2 from 1 January 2027 under FCA CP26/5.
Scale of the TCFD regime in the UK
Two regimes, two scope tests, two locations in the annual report — and one replacement coming in 2027.
FCA Listing Rules vs SI 2022/31
UK listed companies are typically subject to both. The substance is similar — both anchor on TCFD — but the legal basis, enforcement and disclosure location differ.
In-scope entities under SI 2022/31
Five categories of large UK entities with 500+ employees, anchored on the existing Non-Financial Information Statement scope. See our /tcfd-uk-requirements page for the FCA Listing Rules scope test.
- Category 1 — Relevant PIEs500+ employees
- UK companies with more than 500 employees that are PIEs — i.e., have transferable securities admitted to trading on a UK regulated market, or are banking companies, or are insurance companies 6. The largest population in scope.
- Category 2 — AIM companies500+ employees
- UK registered companies with securities admitted to trading on AIM with more than 500 employees. Captures the growth-market segment that sits outside the Main Market.
- Category 3 — Other large UK companies500+ employees + £500m turnover
- UK companies not caught by Categories 1 or 2 that have more than 500 employees and turnover above £500m. The two conditions are cumulative 3.
- Category 4 — Large LLPs500+ employees + £500m turnover
- UK limited liability partnerships (non-traded, non-banking) with more than 500 employees and turnover above £500m, in scope of the parallel LLP Regulations 2022 7.
- Category 5 — Traded or banking LLPs500+ employees
- UK LLPs that are traded LLPs or banking LLPs with more than 500 employees, regardless of turnover.
- Group aggregationBoundary rule
- For parent companies, the 500-employee test is applied to the consolidated group: parent plus subsidiaries. A small subsidiary inside a large group is in scope through its parent. Subsidiaries that are themselves consolidated into a parent's strategic report may be exempt from preparing a separate disclosure.
The 11 TCFD recommended disclosures
The four pillars plus 11 recommended disclosures form the core of any TCFD report. Governance and Risk Management disclosures are treated as core; Strategy and Metrics & Targets disclosures are subject to materiality.
- Governance (2 disclosures)Core — no materiality test
- (a) Describe the board’s oversight of climate-related risks and opportunities. (b) Describe management’s role in assessing and managing climate-related risks and opportunities. Both disclosures are core and must be made regardless of materiality assessment, per the TCFD Recommendations 8.
- Strategy (3 disclosures)Material — assessment required
- (a) Describe the climate-related risks and opportunities identified over the short, medium and long term. (b) Describe the impact of those risks and opportunities on the organisation's businesses, strategy and financial planning. (c) Describe the resilience of the organisation's strategy, considering different climate-related scenarios including a 2°C or lower scenario.
- Risk Management (3 disclosures)Core — no materiality test
- (a) Describe processes for identifying and assessing climate-related risks. (b) Describe processes for managing climate-related risks. (c) Describe how processes for identifying, assessing and managing climate-related risks are integrated into the organisation's overall risk management.
- Metrics and Targets (3 disclosures)Material — except Scope 1 + 2
- (a) Disclose the metrics used to assess climate-related risks and opportunities. (b) Disclose Scope 1, Scope 2 and, if appropriate, Scope 3 greenhouse gas emissions per GHG Protocol methodology 9. (c) Describe the targets used to manage climate-related risks and opportunities and performance against targets. The Task Force later concluded that Scope 1 and 2 GHG emissions should be disclosed independent of materiality 4.
From TCFD to UK SRS S2
The UK TCFD regime took five years to build. FCA CP26/5 proposes to replace it with UK SRS S2, with a Policy Statement expected autumn 2026 and mandatory application proposed from 1 January 2027.
- DEC 2020FCA PS20/17 — TCFD Listing Rules confirmed
- 1 JAN 2021Premium-listed TCFD reporting begins
- 1 JAN 2022Standard-listed extended into scope
- 6 APR 2022SI 2022/31 / LLP Regs effective for large companies
- JUN 2023ISSB issues IFRS S2; TCFD work culminates
- OCT 2023TCFD disbanded; IFRS Foundation monitors from 2024
- 25 FEB 2026DBT publishes UK SRS S1 and S2
- AUTUMN 2026FCA Policy Statement on CP26/5 expected
- 1 JAN 2027Proposed UK SRS S2 mandatory; TCFD LRs deleted
Building a compliant TCFD report
A typical UK TCFD report takes 6–12 months from kick-off to sign-off, longer for first-time preparers. The same governance, data and analytical foundations carry into UK SRS S2 preparation.
TCFD reporting requirements — frequently asked
Mandatory status, what a report contains, when each regime applied, disclosure location, the 2027 replacement, and enforcement.
Are TCFD reports mandatory in the UK?
Yes, in two parallel regimes.
The UK Listing Rules (UKLR 6.6.6R(8)) require companies in the equity shares (commercial companies) category to make TCFD-aligned disclosures on a comply-or-explain basis, with parallel duties at UKLR 14.3.24R, 15.3.1R(3), 16.3.23R and 22.2.24R.
Companies Act 2006 sections 414CA and 414CB — inserted by SI 2022/31 (the Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022) — impose mandatory climate-related disclosures on five categories of large UK companies and LLPs with 500+ employees.
Both regimes are based on TCFD but apply differently.
What does a TCFD report contain?
A TCFD report contains disclosures structured around the four pillars: Governance (board oversight, management's role), Strategy (risks/opportunities by time horizon, business and financial impact, scenario analysis including 2°C or lower), Risk Management (identification, management, integration), and Metrics & Targets (climate metrics, Scope 1/2/3 GHG emissions, targets and performance).
Eleven recommended disclosures in total.
When did TCFD reporting become mandatory in the UK?
For premium-listed companies, for accounting periods beginning on or after 1 January 2021.
Standard-listed companies followed for accounting periods beginning on or after 1 January 2022. (Those two listing categories were abolished on 29 July 2024, when the UK Listing Rules replaced them.) Other large UK companies and LLPs in scope of SI 2022/31 were caught for financial years starting on or after 6 April 2022.
Where does the TCFD report go?
For UK listed companies under FCA Listing Rules, the disclosure sits in the Annual Financial Report.
For companies in scope of SI 2022/31, the disclosure must be in the Non-Financial and Sustainability Information Statement (NFSIS) within the strategic report.
For LLPs under the equivalent LLP Regulations 2022, disclosures sit in the Energy and Carbon Report of the Directors' Report or in the Strategic Report where prepared.
How do TCFD reporting requirements change in 2027?
Under FCA CP26/5 (January 2026), the FCA proposes to delete the TCFD-aligned Listing Rules and replace them with mandatory UK SRS S2 for accounting periods beginning on or after 1 January 2027.
UK SRS S2 fully incorporates TCFD's four pillars and 11 recommendations but tightens almost every requirement — financially quantified scenario analysis, Scope 3 on a permanent comply-or-explain basis, industry-specific metrics, and Connected Information disclosures linking to the financial statements.
What is the penalty for non-compliance with TCFD requirements?
For listed companies, the FCA can enforce under FSMA 2000 — public censure, financial penalties up to £1 million for individuals or the greater of £5 million or 10% of turnover for entities, and listing suspension.
For SI 2022/31, enforcement runs through the Companies Act 2006's general strategic-report regime: the FRC (authorised for these purposes since 6 May 2021, replacing the former Conduct Committee) can apply to court under section 456 for an order to revise a non-compliant report, with costs potentially falling on the approving directors — though no such court application has ever been made, for any reporting matter.
The TCFD guide set
The five dedicated pages plus the UK SRS migration guide cover the full picture.
TCFD — the UK guide
Cluster anchor: history, four pillars, UK applicability and the path to UK SRS S2.
FrameworkTCFD framework — four pillars + 11 disclosures
Detailed breakdown with mapping to UK SRS S2 paragraph numbers.
PracticalTCFD disclosures — practical guidance
How to draft each of the 11 disclosures with worked examples.
UK-specificTCFD UK requirements
FCA Listing Rules, SI 2022/31, threshold tests, and the UK SRS S2 transition.
MigrationTCFD → UK SRS migration
What carries over and what UK SRS S2 demands on top.
RegulatorFCA CP26/5 — replacing TCFD LRs
The consultation that deletes the TCFD-aligned Listing Rules from 2027.
Related guides & references
UK SRS readiness assessment
The capability assessment framework for transitioning from TCFD to UK SRS S2.
SECR reporting guide
Streamlined Energy and Carbon Reporting — the parallel UK climate-reporting regime for large companies.
UK sustainability assurance
FRC framework and assurance levels for climate disclosures.
Primary references
Statute, FCA rules, DBT guidance and professional commentary underpinning every claim on this page.