TCFD UK requirements — FCA Listing Rules and SI 2022/31
The UK has two parallel TCFD-aligned regimes: FCA Listing Rules (UKLR 6.6.6R(8)) for premium and standard listed companies on a comply-or-explain basis, and SI 2022/31 (the Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022) plus the parallel LLP Regulations for large UK companies and LLPs with 500+ employees. Both will be reshaped from 1 January 2027 by UK SRS S2 under FCA CP26/5.
Scale of the UK regime
Two regimes, two scope tests, two locations in the annual report — and the UK SRS S2 transition starting January 2027.
FCA Listing Rules vs SI 2022/31
Both regimes anchor on TCFD. The legal basis, scope test, location of disclosure and enforcement mechanism differ. A UK-listed company with 500+ employees is typically caught by both.
UKLR 6.6.6R(8) — the listed-issuer regime
The FCA introduced TCFD-aligned disclosure into the UK Listing Rules in December 2020 (PS20/17) for premium-listed companies, then extended to standard-listed companies from 1 January 2022. The rule sits inside UKLR 6.6.6R(8) following the listing-rules consolidation.
- The disclosure requirement UKLR 6.6.6R(8)
- Premium and standard listed companies must include in their Annual Financial Report a statement on whether their TCFD-aligned disclosures have been made consistent with the four core TCFD recommendations and the supporting 11 recommended disclosures. The wording explicitly references the TCFD recommendations and recommended disclosures.
- Comply-or-explain mechanic How the rule operates
- Where the company has not made consistent disclosures, it must identify the recommendations not met, explain why, and set out the steps and timeframe to make those disclosures in future 1. The FCA expects this to be a substantive explanation, not boilerplate.
- FCA Technical Note TN/802.2 FCA guidance
- FCA Primary Market Technical Note TN/802.2 (April 2025, successor to TN/802.19) sets out FCA expectations on: (a) the location of disclosure in the Annual Financial Report; (b) materiality assessments under Strategy and Metrics; (c) what constitutes a satisfactory explanation; (d) governance of the TCFD disclosure preparation process; and (e) cross-referencing.
- Investment entities Scope carve-out
- Listed investment entities (typically closed-ended funds and investment trusts) are not caught by the same TCFD disclosure regime in the Listing Rules. Asset managers face TCFD obligations under separate FCA SDR rules.
- FCA enforcement Sanctions
- Enforcement under FSMA 2000: public censure, financial penalties up to £1m for individuals or the greater of £5m or 10% of turnover for entities, and listing suspension. The FCA can also take action under the Listing Principles for inadequate or misleading disclosures.
SI 2022/31 + LLP Regulations 2022
The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 (SI 2022/31) and the parallel LLP Regulations 2022 impose mandatory climate-related disclosure on five categories of large UK entities. Effective for financial years starting on or after 6 April 2022.
- Category 1 — Relevant PIEs 500+ 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. The largest population in scope.
- Category 2 — AIM-listed companies 500+ 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 (and therefore outside the FCA Listing Rules regime).
- Category 3 — Other large UK companies 500+ employees + £500m turnover
- UK companies not in Categories 1 or 2 with more than 500 employees and turnover above £500m. The two conditions are cumulative 2. Captures large private companies that would otherwise fall outside the UK climate-reporting regime.
- Category 4 — Large non-traded LLPs 500+ employees + £500m turnover
- UK LLPs (non-traded, non-banking) with more than 500 employees and turnover above £500m, in scope of the parallel LLP Regulations 2022. Disclosure sits in the Energy and Carbon Report of the Directors' Report (or in the Strategic Report where prepared).
- Category 5 — Traded or banking LLPs 500+ employees
- UK LLPs that are traded LLPs or banking LLPs with more than 500 employees, regardless of turnover.
- What must be disclosed under SI 2022/31 Required content
- Eight specific climate-related disclosures aligned with the four TCFD pillars 3: (1) board oversight; (2) management role; (3) climate risks and opportunities; (4) impact on business model and strategy; (5) scenario analysis; (6) climate risk management processes; (7) integration with overall risk management; (8) metrics, targets and Scope 1/2 GHG emissions. Note: the SI does not directly cite TCFD by name.
- Disclosure location NFSIS
- For companies, the climate-related disclosures must be in the Non-Financial and Sustainability Information Statement (NFSIS), a statutory section of the strategic report. For LLPs, disclosures sit in the Energy and Carbon Report of the Directors' Report or in the Strategic Report where one is prepared.
- Enforcement Penalties
- Enforcement under the Companies Act 2006 strategic-report regime. The FRC Conduct Committee can require restatement or refer to the courts. Companies House can pursue civil penalties (£2,500 to £50,000) for non-compliant strategic reports.
From PS20/17 to UK SRS S2
Six years from FCA policy statement to the proposed deletion of the TCFD-aligned Listing Rules. The journey ends with mandatory UK SRS S2 from 1 January 2027.
- DEC 2020FCA PS20/17 — Premium-listed TCFD 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
- OCT 2023TCFD disbanded; IFRS Foundation takes over monitoring
- APR 2025FCA Primary Market Technical Note TN/802.2 issued
- 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
What CP26/5 changes for UK TCFD
The FCA proposes to delete the TCFD-aligned Listing Rules entirely and replace them with mandatory UK SRS S2 for accounting periods beginning on or after 1 January 2027. SI 2022/31 / LLP Regs are under separate review.
CP26/5 consultation closed 20 March 2026
The FCA received 73 industry consultation responses to CP26/5, which proposes to: (1) delete the TCFD-aligned Listing Rules in UKLR 6.6.6R(8); (2) introduce mandatory UK SRS S2 climate disclosure for ~500 listed companies; (3) apply S1 broader sustainability disclosures on comply-or-explain from 1 January 2029; (4) align with FRC assurance framework under development.
Policy Statement expected autumn 2026.
UK TCFD requirements — frequently asked
UKLR 6.6.6R(8) detail, SI 2022/31 scope, when each regime started, FCA TN/802.2 status, enforcement, and the 2027 replacement.
What does UKLR 6.6.6R(8) require?
UKLR 6.6.6R(8) is the FCA Listing Rule that requires premium and standard listed companies to include in their Annual Financial Report a statement on whether their TCFD-aligned disclosures have been made consistent with the four core TCFD recommendations and the supporting 11 recommended disclosures.
The regime is comply-or-explain: where a company has not made the disclosures, it must explain why and set out the steps it is taking or plans to take to make consistent disclosures in future.
Who is in scope of SI 2022/31?
Five categories of large UK entities with 500+ employees: (1) Relevant PIEs (UK regulated market, banking, insurance); (2) AIM-listed companies; (3) other UK companies with 500+ employees and turnover above £500m; (4) large non-traded LLPs with 500+ employees and turnover above £500m; (5) traded or banking LLPs with 500+ employees.
When did UK TCFD requirements start?
FCA Listing Rules applied to premium-listed companies for financial years starting on or after 1 January 2021 and to standard-listed companies for financial years starting on or after 1 January 2022.
SI 2022/31 / LLP Regulations applied for financial years starting on or after 6 April 2022.
Does FCA TN/802.2 still apply?
Yes.
Primary Market Technical Note TN/802.2 (the April 2025 successor to TN/802.19) sets out the FCA's expectations on how premium and standard listed companies should comply with UKLR 6.6.6R(8).
It remains in force until the FCA's CP26/5 Policy Statement (expected autumn 2026) confirms the deletion of the TCFD-aligned Listing Rules in favour of mandatory UK SRS S2 from 1 January 2027.
How is UK TCFD enforced?
Under the FCA Listing Rules, the FCA enforces directly using its powers under FSMA 2000 — public censure, financial penalties (up to £1m for individuals; greater of £5m or 10% of turnover for entities), and listing suspension.
Under SI 2022/31, the FRC Conduct Committee monitors compliance through its corporate-reporting review work; Companies House can pursue penalties for non-compliant strategic reports under the Companies Act 2006.
What happens to UK TCFD after 2027?
Under FCA CP26/5, the TCFD-aligned Listing Rules are proposed for deletion when UK SRS S2 becomes mandatory for accounting periods beginning on or after 1 January 2027.
SI 2022/31 / LLP Regs continue to apply but are under review through the Government's Modernising Corporate Reporting programme — possible scope expansion to include the same large companies caught by SI 2022/31.
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.
RequirementsTCFD reporting requirements
Who must report, what to disclose, and when each regime applied.
FrameworkTCFD framework — four pillars + 11 disclosures
Detailed breakdown with mapping to IFRS S2 and UK SRS S2.
PracticalTCFD disclosures — practical guidance
How to draft each of the 11 disclosures with worked examples.
MigrationTCFD → UK SRS migration
What carries over from TCFD to UK SRS S2 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
SECR reporting guide
Streamlined Energy and Carbon Reporting — the foundational UK climate-reporting regime that pre-dates TCFD.
UK SRS thresholds
Who falls into UK SRS scope when the TCFD-aligned Listing Rules are replaced from 2027.
CP26/5 consultation tracker
Analysis of the 73 industry responses to FCA CP26/5.
Primary references
FCA, DBT, statutory instruments and professional commentary on the UK TCFD regime.