Step-by-step guide · TCFD to UK SRS S2

TCFD to UK SRS migration: a step-by-step guide

This is the how-to: the overview of what changes, and which rules continue, is on TCFD and UK SRS.

UK listed companies have reported a TCFD statement since 2021, and the FCA’s final rules in PS26/19 replace it with UK SRS for accounting periods beginning on or after 1 January 2027.

The four pillars carry over; the eleven TCFD disclosures each land on a UK SRS S2 paragraph that asks for more.

The move is comply or explain, not mandatory: anything a company cannot yet meet is explained, not left as a breach.

See the mapping Read the FCA rules

In short

Same architecture, more depth

The TCFD’s June 2017 report set four recommendations — governance, strategy, risk management, and metrics and targets — with eleven recommended disclosures beneath them.

The October 2021 annex updated the guidance but left the recommendations and the eleven disclosures unchanged.

The TCFD disbanded in October 2023, and the IFRS Foundation says IFRS S2 is consistent with its four recommendations and eleven disclosures.

UK SRS S2 is the UK’s endorsed IFRS S2, and PS26/19 ¶1.10 says the new rules will replace the existing TCFD-aligned disclosures.

The history of the framework is on TCFD, and the framework-level comparison on TCFD and UK SRS; this page is about making the move.

Jun 2017
TCFD Final Report
Four recommendations, eleven disclosures.
Oct 2021
TCFD guidance updated
Recommendations and disclosures unchanged.
Oct 2023
TCFD disbanded
25 Feb 2026
UK SRS S1 and S2 published
Voluntary for any entity.
30 Sep 2026
PS26/19
TCFD listing rules replaced by UK SRS, comply or explain.
1 Jan 2027
New limbs apply
Periods beginning on or after this date.

The mapping

Each TCFD disclosure, and where it lands in UK SRS S2

Our mapping, by the paragraph headings of UK SRS S2.

Paragraph numbers in the body of UK SRS S2 match IFRS S2; only the appendices were renumbered.

Sources: TCFD Final Report, Figure 4 · UK SRS S2 ¶¶5–37 · IFRS S2 (December 2025). The TCFD pillar structure is set out in full on the TCFD framework page.
TCFD recommended disclosure	UK SRS S2	What S2 asks for	Change
Governance a — board oversight	¶6(a)	Identify the body or individual; how responsibilities appear in terms of reference; skills; how and how often it is informed; how it oversees targets.	Tightens
Governance b — management’s role	¶6(b)	Management’s role in the processes, controls and procedures used to monitor and manage climate risks and opportunities.	Tightens
Strategy a — risks and opportunities over time	¶¶10–12	Classify each risk as physical or transition; say how short, medium and long term are defined and linked to planning horizons.	Adds
Strategy b — impact on business, strategy and financial planning	¶¶13–21	Effects on business model and value chain (¶13); strategy and decision-making, including any transition plan (¶14); current and anticipated financial effects (¶¶15–21).	Adds most
Strategy c — resilience under scenarios, incl. 2°C or lower	¶22 and ¶¶B1–B18	Scenario analysis commensurate with circumstances; disclose the assessment, inputs, assumptions and when it was done.	Reframes
Risk management a — identifying and assessing	¶25(a)	Inputs, use of scenario analysis, how likelihood and magnitude are assessed, prioritisation and monitoring.	Tightens
Risk management b — managing	¶25(a)–(b)	Folded into the risk processes, with a separate limb for opportunities.	Adds opportunities
Risk management c — integration	¶25(c)	How far the processes are integrated into overall risk management.	Same
Metrics and targets a — metrics used	¶¶28–32	Seven cross-industry categories (¶29) plus industry-based metrics (¶32).	Adds
Metrics and targets b — Scope 1, 2 and, if appropriate, 3	¶29(a)	Absolute gross Scope 1, 2 and 3 under the GHG Protocol; location-based Scope 2; Scope 3 categories disclosed.	Adds most
Metrics and targets c — targets and performance	¶¶33–36	For each target: metric, objective, scope, period, base period, milestones, and performance; more for greenhouse gas targets.	Tightens

Where S2 asks for more

Four places the work actually grows

01 · Scope 3

The TCFD asked for Scope 3 “if appropriate”.

UK SRS S2 ¶29(a) asks for absolute gross Scope 3, and ¶B32 says the entity shall consider all fifteen categories and disclose which it includes.

Under the FCA rules it is comply or explain, with a one-year relief under ¶C4 for a period beginning in 2027.

02 · Financial effects

¶¶15–21 ask for current and anticipated effects on financial position, performance and cash flows, quantitative and qualitative.

¶17 allows a single amount or a range, and ¶¶19–21 set out when quantitative information need not be given and what to disclose instead.

03 · Scenario analysis

¶22 requires scenario analysis “commensurate with the entity’s circumstances”, and ¶B15 accepts scenario narratives alone as a reasonable and supportable basis.

It names no temperature pathways; scenario sets such as the NGFS scenarios and the IPCC’s physical science are tools, not requirements.

04 · Connection to the accounts

UK SRS S1 ¶¶20–24 require the same reporting entity and consistent data and assumptions as the financial statements, and ¶64 the same period, reported at the same time.

These foundations apply to climate disclosures even during the climate-first relief.

Emissions are measured under the GHG Protocol Corporate Standard, which ¶29(a) names; carbon accounting for UK SRS takes the calculation step by step.

The industry-based metrics in ¶32 are a “shall”, but UK SRS S2 softens the reference to the ISSB’s industry guidance to “may refer to and consider”.

A company that has a transition plan describes it under ¶14(a)(iv), and states under the listing rules whether and where it is published; UK SRS and transition-plan disclosure covers both.

Timing

When a listed company switches

The switch attaches to the start of an accounting period: a 31 December year end switches for its 2027 year, reported in 2028.

A company whose year began before 1 January 2027 may keep the TCFD statement for that year or adopt UK SRS early, and an early adopter keeps the reliefs (PS26/19 ¶3.19).

There are no comparatives in the first year under UK SRS S2 ¶C1, and comparative Scope 3 is needed only from the period after Scope 3 is first disclosed.

Each relief is used by saying so in the annual financial report; nothing further is explained while it runs.

The dates for a non-calendar year end are on the UK SRS deadline, and every event on the dated register of UK SRS events.

The FCA consulted on the switch in CP26/5, which had proposed that S2 be mandatory.

Source: PS26/19 Appendix 1, UKLR TP 16
Period begins	Provision (UKLR 6)	What applies
Before 1 Jan 2027	TP 16.3R	TCFD statement, or early adoption with the first-year reliefs
In 2027	TP 16.4R	UK SRS; Scope 3 and climate-first reliefs available, stated
In 2028	TP 16.5R	UK SRS; climate-first relief only
From 1 Jan 2029	—	UK SRS, comply or explain, no FCA relief

Gaps in year one

Explaining what you cannot yet disclose

Where a TCFD statement explained a gap “where it could”, the UK SRS limb asks for three things: a summary of the S2 requirements not met, the reasons, and any steps being taken or planned.

Draft TN 803.1 says the reasons can be short and proportionate but should not omit material information, and that no timeframe is required.

Explaining a requirement means the company cannot make an unreserved statement of compliance with UK SRS S2, under UK SRS S1 ¶¶72–73B.

The FCA’s current TCFD guidance, TN 802.3, stays in place for TCFD periods until it is deleted when TN 803.1 is finalised.

Where the standard itself allows an explanation — as ¶21 does for financial effects that cannot be quantified — using it is compliance with the standard, not an explanation under the listing rules.

UK SRS compliance goes further into what makes an explanation usable.

A worked shape, not a template

Not met: the industry-based metrics in UK SRS S2 ¶32 for two of the group’s segments.

Why: the data behind those metrics is not yet collected outside the main operating company.

Steps: extending collection to the two segments.

Illustrative only.

The structure follows UKLR 6.6.6R(7A)(b); see draft TN 803.1 for the FCA’s own examples.

Order of work

Six workstreams, in the order they depend on each other

01 · Scope and timing

Confirm the listing category and first period; decide on early adoption and the reliefs.

The UK SRS thresholds page settles who is in.

02 · Governance

Name the oversight body, update terms of reference, and set how and how often it is informed (¶6).

03 · Emissions

Settle the GHG Protocol boundary and Scope 2 method; consider all fifteen Scope 3 categories and choose what to include.

04 · Scenarios and financial effects

Choose a proportionate scenario approach and decide what can be quantified.

05 · Connection to the accounts

Align entity, period and assumptions with the financial statements, and the reporting timetable with the year-end close.

06 · Statements

Draft the explain, relief, location, assurance and transition-plan statements.

A UK SRS readiness assessment sorts which of these you already hold from TCFD reporting.

Assurance is not required, but if you plan to obtain it the evidence trail is easier built in than retrofitted; sustainability assurance explains what an engagement covers.

Financial firms have sector material from the industry forum the FCA convenes with the PRA, the Climate Financial Risk Forum, and the TCFD’s own metrics and transition-plan guidance still describes practice.

For the standards as documents, see UK SRS S2 and UK SRS S1 and S2; the standards were published by DBT on 25 February 2026.

Frequently asked

TCFD to UK SRS, answered

When do UK listed companies move from TCFD to UK SRS S2?

For accounting periods beginning on or after 1 January 2027, under the FCA’s final rules in PS26/19.

For a period that began before then, a company may keep the TCFD-aligned statement or adopt the UK SRS limbs early.

The new rules replace the TCFD-aligned disclosures in the listing rules.

Is UK SRS S2 mandatory for listed companies?

No. PS26/19 applies a comply-or-explain approach across all of UK SRS.

A company that cannot meet an S2 requirement summarises what it has not met, why, and any steps it is taking or plans to take.

The FCA’s consultation had proposed mandatory S2; the final rules did not adopt it.

Do existing TCFD disclosures map to UK SRS S2?

Yes at the level of structure.

UK SRS S2 keeps the four pillars, and the IFRS Foundation says the ISSB standard it is based on is consistent with the TCFD’s eleven recommended disclosures.

What changes is depth: most TCFD disclosures correspond to an S2 paragraph that asks for more specific information.

Does UK SRS S2 require quantitative scenario analysis?

No. UK SRS S2 ¶22 requires climate-related scenario analysis using an approach commensurate with the entity’s circumstances, and ¶B15 says qualitative information, including scenario narratives, can alone provide a reasonable and supportable basis for the resilience assessment.

Quantification is not required, and the standard names no particular temperature scenarios.

Does UK SRS S2 require all fifteen Scope 3 categories?

It requires Scope 3 emissions and says an entity shall consider all fifteen categories, then disclose which are included (¶B32).

Under the FCA rules Scope 3 is comply or explain, with a one-year relief under UK SRS S2 ¶C4 for a period beginning in 2027, used by stating that the company relies on it.

Do I need comparative figures in my first UK SRS report?

No. UK SRS S2 ¶C1 and UK SRS S1 ¶E1 say an entity is not required to disclose comparative information in the first annual reporting period in which it applies the standard.

Does the TCFD still exist?

No. The TCFD completed its final task with its October 2023 status report and disbanded.

Monitoring of climate-related disclosure transferred to the IFRS Foundation from 2024.

Its recommendations remain published on its frozen website.

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 15 sources fromDepartment for Business and TradeFinancial Conduct AuthorityTask Force on Climate-related Financial DisclosuresIFRS FoundationGHG ProtocolFinancial Stability Board

Department for Business and Trade
UK SRS S2 Climate-related Disclosures (PDF) — ¶¶5–37, B15, B32 and Appendix C
The paragraphs in the mapping table, the scenario-analysis test and the reliefs.
Department for Business and Trade
UK SRS S1 General Requirements (PDF) — ¶¶20–24, 64 and Appendix E
Connected information, same-period reporting and the climate-first relief.
Department for Business and Trade
UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026 for voluntary use.
Financial Conduct Authority
PS26/19: Aligning listed issuers' sustainability disclosures with international standards
The final rules: UK SRS on a comply-or-explain basis from periods beginning on or after 1 January 2027.
Financial Conduct Authority
PS26/19 (PDF) — ¶¶1.10, 3.12–3.24 and UKLR TP 16
The TCFD rules are replaced; the reliefs and the early-adoption choice.
Financial Conduct Authority
Primary Market TN 803.1 (draft, September 2026)
What an explanation of an unmet S2 requirement is expected to contain.
Financial Conduct Authority
Primary Market TN 802.3 — TCFD-aligned disclosure requirements
The guidance on today’s rule, proposed for deletion.
Task Force on Climate-related Financial Disclosures
Final Report, June 2017 — Figure 4, the eleven recommended disclosures
The TCFD side of the mapping, verbatim.
Task Force on Climate-related Financial Disclosures
Recommendations and recommended disclosures
The frozen TCFD site, no longer maintained since November 2023.
Task Force on Climate-related Financial Disclosures
Implementing the Recommendations, October 2021 Annex (PDF)
October 2021 changed the guidance, not the four recommendations or the eleven disclosures.
Task Force on Climate-related Financial Disclosures
Guidance on Metrics, Targets, and Transition Plans, October 2021 (PDF)
The TCFD’s own metrics and transition-plan guidance.
IFRS Foundation
ISSB and TCFD
IFRS S2 is consistent with the four recommendations and eleven recommended disclosures.
IFRS Foundation
IFRS S2, December 2025 text (HTML)
The ISSB text UK SRS S2 is based on.
GHG Protocol
Corporate Standard
The measurement basis UK SRS S2 ¶29(a) names.
Financial Stability Board
FSB publishes annual progress report on climate-related disclosures, 12 October 2023
The TCFD’s final task; the task force disbanded.