TCFD reporting requirements UK: four duties, four deadlines

Four groups.

Listed companies in UKLR 6, 14, 15, 16 and 22 make a TCFD statement under the listing rules for periods beginning before 1 January 2027.

Companies and LLPs with more than 500 employees that are traded, banking, insurance or AIM companies, or have turnover above £500 million, make the Companies Act climate disclosures.

FCA-regulated asset managers and asset owners above £5 billion publish a TCFD entity report.

Trustees of pension schemes with £1 billion or more, and of authorised master trusts and CDC schemes, publish a climate report.

The duties that adopt the TCFD framework are mandatory for those in scope, but on different bases.

The listing rule is comply-or-explain; the Companies Act duty requires four disclosures outright and allows the other four to be omitted with a reasoned explanation; the asset manager and pension rules are mandatory reports.

The TCFD recommendations themselves have no legal force.

A listed company publishes its annual financial report, containing the statement, within four months of its year end.

The Companies Act disclosures are filed with the accounts, nine months after the year end for a private company and six for a public one.

FCA asset managers publish their TCFD entity report by 30 June each year.

Pension trustees publish within seven months of the scheme year end.

There is no single threshold.

The Companies Act duty needs more than 500 employees and, for an unlisted company that is not a bank, insurer or AIM company, more than £500 million turnover.

The FCA asset manager rule exempts firms below £5 billion in TCFD in-scope business.

The pension rule starts at £1 billion of relevant assets.

The listing rule has no size test: it follows the listing category.

For listed companies, PS26/19 replaces the TCFD statement with UK SRS reporting on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

The Companies Act duty, the FCA asset manager rule and the pension trustee rule all continue unchanged by PS26/19.

A bank with more than 500 employees is inside the Companies Act climate disclosures, and a listed bank makes the listing-rule statement.

The PRA’s Supervisory Statement SS5/25 sets separate supervisory expectations on managing climate-related risks, including disclosures, but it is not a reporting rule.

Central government bodies apply TCFD-aligned disclosure in their annual reports and accounts under HM Treasury’s application guidance.

HM Treasury’s March 2026 good practice guide describes 2025-26 annual reports as the final stage of the comply-or-explain requirements.

Establish which of the four duties applies and for which period, map your existing disclosures to the eleven recommended disclosures or the eight statutory ones, close the gaps in scenario analysis and emissions data first, and write the comply-or-explain statement with reasons, steps and a timeframe for anything not yet disclosed.

A statement in the annual financial report setting out whether the listed company has made disclosures consistent with the TCFD recommendations and recommended disclosures, and, where it has not, which disclosures were not made, why, and the steps and timeframe to make them.

It applies to accounting periods beginning before 1 January 2027; the same rule is applied to UKLR 14, 15, 16 and 22 issuers by their own provisions.

Section 414CB(2A) lists governance arrangements; how climate risks and opportunities are identified, assessed and managed; how that is integrated into overall risk management; the principal risks and opportunities and the time periods used; their actual and potential impacts on the business model and strategy; resilience analysis under different climate scenarios; targets and performance against them; and the KPIs used and how they are calculated.

Directors may omit (e) to (h), in whole or part, with a clear and reasoned explanation.

Yes.

In its February 2026 consultation response, the Department for Business and Trade confirmed that UK SRS S2 is a national reporting framework for the purposes of section 414CB(6), so companies reporting in accordance with UK SRS S2 need not duplicate their disclosures to meet section 414CB(2A).

The government said it will consider the future of the section 414CB(2A) obligations.

FCA 2026/59, in force on 25 September 2026, simplified product-level reporting: the public product reports were replaced by a duty to consider climate risks to each product and include any identified in retail communications, and to provide Scope 1, 2 and 3 data on request.

The TCFD entity report, due by 30 June each year, remains.

No TCFD-shaped UK rule requires third-party assurance.

From accounting periods beginning on or after 1 January 2027, the rewritten UKLR 6.6.6R(8) asks listed companies to state whether they have obtained assurance and, if so, from whom, over what, to what level and under which standard.

The Pensions Regulator must issue a penalty notice under regulation 9(2) of SI 2021/839, of at least £2,500 and up to £50,000 for a body corporate or £5,000 for an individual.

It is the only TCFD-aligned UK duty with a mandatory penalty, and it bites on publication rather than the quality of the report.

Only if they meet the Companies Act test: more than 500 employees and turnover above £500 million, or more than 500 employees and one of the traded, banking, insurance or AIM categories.

LLPs have equivalent tests under SI 2022/46.

A private company outside those tests has no TCFD reporting duty, though a buyer or lender may ask for one.

No. UK SRS S2 is built on IFRS S2, which incorporates the four TCFD pillars but asks for more, including industry-based metrics and Scope 3 emissions.

A good TCFD report is a starting point, not a UK SRS S2 report; the mapping is on the TCFD and UK SRS page.