FCA TCFD rule · the listing rule only

FCA TCFD rule: UKLR 6.6.6R(8), provision by provision

This page covers the FCA’s listing rule only; every other UK TCFD-style duty, from the Companies Act climate disclosures to pension trustees and the FCA’s ESG sourcebook, is on TCFD reporting requirements.

The TCFD requirement in the UK listing rules is a statement in the annual financial report, made under UKLR 6.6.6R(8) and its twins in four other listing categories.

It is comply-or-explain, it has applied since 2021, and the FCA’s PS26/19 replaces it with UK SRS for accounting periods beginning on or after 1 January 2027.

This page sets out what the rule asks, which provision applies to which listing, and how a company moves from one rule to the next.

Check your statement Which rule governs your period

The rule

Four things the statement must say

The rule does not require a company to make TCFD disclosures; it requires a statement about whether it has.

The FCA’s TN 802.3 sets out what the statement covers, in the words of the original policy statement.

First, “whether they have made climate-related financial disclosures consistent with the TCFD’s Recommendations and Recommended Disclosures in their annual financial report”.

Second, where they have not, “an explanation of why, and a description of any steps they are taking or plan to take to be able to make consistent disclosures in the future – including relevant timeframes for being able to make those disclosures”.

Third, where some or all of the disclosures are in a document other than the annual financial report, “an explanation of why”.

Fourth, “where in their annual financial report (or other relevant document) the various disclosures can be found”.

The benchmark is defined in the FCA’s Glossary as the four recommendations and eleven recommended disclosures in Figure 4 of the TCFD Final Report, which is set out on the TCFD framework page.

The rule sits in the UK Listing Rules, which the FCA makes under the Financial Services and Markets Act 2000.

Check

Does your statement carry every limb?

The check walks through the limbs and names the ones a statement leaves out.

The limb most often missing is the timeframe: the rule asks not only why a disclosure is missing and what is being done, but when the company expects to make it.

TN 802.3 says explanations should be “full, clear and meaningful”, written in plain language that “leaves no room for ambiguity”.

It also says that where a company states its disclosures are consistent, they should include “sufficient, company-specific information to support decision-making by investors”.

The guidance at UKLR 6.6.8G to 6.6.10G points to the TCFD documents that inform whether disclosures are consistent, and UKLR 6.6.11G sets out the limited circumstances in which the FCA expects a company to explain rather than disclose.

When it introduced the rule, the FCA noted respondents’ view that issuers should ordinarily be able to make the governance and risk management disclosures without needing to explain (PS20/17).

A draft of the explanation itself, disclosure by disclosure, can be built on TCFD disclosures.

Check a TCFD compliance statement

Tick what is true of the statement in your annual financial report.

It says whether the disclosures are consistent with the TCFD Recommendations and Recommended Disclosures.UKLR 6.6.6R(8)
Some recommended disclosures are not made, or only in part.
For each gap, it explains why.UKLR 6.6.6R(8)(b)(ii)
For each gap, it describes the steps taken or planned to make the disclosure.UKLR 6.6.6R(8)(b)(ii)
For each gap, it gives the timeframe for making the disclosure.UKLR 6.6.6R(8)(b)(ii)(C)
Some disclosures sit in a document other than the annual financial report.
It says where each disclosure can be found.UKLR 6.6.6R(8)

2 limbs missing:

For each gap, it describes the steps taken or planned to make the disclosure. (UKLR 6.6.6R(8)(b)(ii))

For each gap, it gives the timeframe for making the disclosure. (UKLR 6.6.6R(8)(b)(ii)(C))

For accounting periods beginning before 1 January 2027.

From then, UKLR 6.6.6R(7A) asks for a summary of unmet UK SRS S2 requirements, the reasons and any steps, with no timeframe.

Which provision

Five listing categories, one rule in five places

Sources: TN 802.3, scope paragraph · PS26/19 ¶¶3.6–3.7 and Appendix 1
Listing category	TCFD provision	From 1 January 2027
Equity shares (commercial companies) — UKLR 6	UKLR 6.6.6R(8); overseas companies UKLR 6.6.17R	UKLR 6.6.6R(7A), (7B), (8)
Equity shares (international commercial companies secondary listing) — UKLR 14	UKLR 14.3.24R	UKLR 14.3.24R(4)–(6) — no transition-plan statement
Certificates representing certain securities (depositary receipts) — UKLR 15	UKLR 15.3.1R(3), applying UKLR 14.3.24R	As UKLR 14 — no transition-plan statement
Non-equity shares and non-voting equity shares — UKLR 16	UKLR 16.3.23R	UKLR 16.3.23R(4)–(6)
Equity shares (transition) — UKLR 22	UKLR 22.2.24R	UKLR 22.2.24R(4)–(6)
Closed-ended funds, OEICs, shell companies, debt and other securities — UKLR 11, 12, 13, 17, 18, 19	Not covered	Excluded (PS26/19 ¶3.7)

The asset managers’ TCFD entity report under the FCA’s ESG sourcebook and the Companies Act climate disclosures are separate duties, set out on TCFD reporting requirements.

History

From LR 9.8.6R(8) to UKLR 6.6.6R(8)

The FCA introduced the rule in PS20/17 in December 2020 for commercial companies with a UK premium listing, on a comply-or-explain basis, from 1 January 2021.

At 7 December 2020, the FCA said, the rule would apply to 460 companies on the Official List.

PS21/23 extended it through LR 14.3.27R to standard listed shares and GDRs, excluding investment entities and shell companies, for accounting periods beginning on or after 1 January 2022.

The FCA said that brought “more than 200 additional listed companies” into TCFD-aligned disclosure, and the same policy statement added guidance on transition plans to both rules.

On 29 July 2024 the premium and standard segments were abolished and the rule was carried into the new UK Listing Rules, where it became UKLR 6.6.6R(8) and its twins; the old LR 9.8 now shows as deleted.

The FCA refreshed its guidance in January 2026 as TN 802.3, finalised through Primary Market Bulletin 61.

The Task Force whose recommendations the rule names had already disbanded, in October 2023, with its final status report; the FSB keeps its Task Force page.

Dec 2020
PS20/17
LR 9.8.6R(8) for premium listed commercial companies, from 1 January 2021.
Dec 2021
PS21/23
LR 14.3.27R for standard listed shares and GDRs, periods from 1 January 2022.
29 Jul 2024
UK Listing Rules
Premium and standard segments abolished; the rule carried into UKLR by PS24/6.
Jan 2026
TN 802.3
Finalised through PMB 61.
30 Sep 2026
PS26/19
UK SRS replaces the TCFD statement from 2027.

The replacement

PS26/19: what takes the TCFD statement’s place

The final rules came on 30 September 2026, and ¶1.10 of PS26/19 is direct: “These rules will replace the existing TCFD aligned disclosures.

TCFD was set up in 2015 but disbanded in 2023.”

They were made by the UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026 on 24 September 2026, in force on 1 January 2027.

New UKLR 6.6.6R(7A) asks for climate-related disclosures in accordance with UK SRS S2 or a statement of the requirements not met, the reasons and any steps planned — with no timeframe.

New (7B) does the same for UK SRS S1, but by the risks and opportunities not disclosed rather than requirement by requirement.

UKLR 6.6.6R(8) is rewritten rather than deleted: it now carries the location of the disclosures, whether assurance was obtained and from whom, and the transition-plan statement for UKLR 6, 16 and 22.

The consultation that led here, CP26/5, proposed mandatory S2 for some categories; the final rules are comply-or-explain across all of UK SRS.

The new rule is set out limb by limb on UK SRS and the FCA, the consultation’s path on the CP26/5 tracker, and the succession from one framework to the other on TCFD and UK SRS.

The standards themselves are on the government’s UK SRS publication page.

Your period

Which rule governs which accounting period

The test is the start of the accounting period, not the date the report is published.

A company with a calendar year reports its 2026 year under the TCFD statement in 2027, and its 2027 year under UK SRS in 2028.

A company whose year begins on 1 April reports its year beginning 1 April 2026 under the TCFD statement, and first applies UK SRS to the year beginning 1 April 2027.

Under ¶3.19, a company with a period beginning before 1 January 2027 may instead adopt UK SRS early and keep the same transitional reliefs — a reversal of the consultation’s position.

The resolver works out the provision and relief for your period and listing category, citing the transitional provisions in UKLR TP 16.

The FCA is consulting on deleting TN 802.3 in Primary Market Bulletin 66, with comments due by 28 October 2026; until it is deleted, it remains the guidance for TCFD-statement periods.

Your accounting periods

Period starts

Year

Listing category

1 January 2027 – 31 December 2027
UKLR TP 16.4R
UK SRS on a comply-or-explain basis. Scope 3 may be omitted under UK SRS S2 ¶C4, and reporting may be climate-first under UK SRS S1 ¶E3 — each only if the report says it is relying on the transitional provision and the relief.
1 January 2028 – 31 December 2028
UKLR TP 16.5R
UK SRS on a comply-or-explain basis, Scope 3 included. The climate-first relief under UK SRS S1 ¶E3 is still available, stated in the same way.
1 January 2029 – 31 December 2029
No FCA relief
Comply or explain across UK SRS S1 and S2. The reporting obligation continues; the transitional reliefs have ended.
1 January 2030 – 31 December 2030
No FCA relief
Comply or explain across UK SRS S1 and S2. The reporting obligation continues; the transitional reliefs have ended.

The limbs: UKLR 6.6.6R(7A), (7B) and (8).

Location, assurance and transition-plan statements all apply.

Assumes twelve-month periods.

Source: FCA PS26/19 Appendix 1, UKLR TP 16.

The other duty

Is the FCA TCFD rule the same test as the Companies Act duty?

Sources: UKLR 6.6.6R(8) · CA 2006 s.414CA · s.414CB · SI 2022/31
	FCA listing rule (TCFD statement)	Companies Act climate disclosures
Who	Listed companies in five categories	Companies and LLPs with more than 500 employees that are traded, banking, insurance, AIM, or over £500m turnover
What	A statement of consistency with eleven recommended disclosures	Eight statutory disclosures
Flexibility	Comply or explain across all eleven	(a)–(d) required; (e)–(h) omissible with a reasoned explanation
Where	Annual financial report	Non-financial and sustainability information statement in the strategic report
After 1 January 2027	Replaced by UK SRS, comply or explain	Continues; UK SRS S2 can discharge it

A company can satisfy the listing rule by explaining a gap and still fail the Companies Act, where (a) to (d) allow no explanation; that duty is set out on climate-related financial disclosures.

The two run side by side: the government’s 2022 guidance says disclosures under the listing rules should also comply with the Regulations, and the size tests often confused with UK SRS scope are on UK SRS thresholds.

The energy and carbon figures that sit beside both are on the SECR reporting guide.

What to do

The last TCFD statements and the first UK SRS reports

For a period that began before 1 January 2027, make the TCFD statement as before, against the eleven recommended disclosures, or decide now to adopt UK SRS early.

For the first period on or after that date, plan a UK SRS S2 report or explanation, and decide whether to use the Scope 3 and S1 reliefs, which are stated rather than explained.

The gap between the two is mostly scenario analysis and Scope 3 data, and the UK SRS readiness assessment finds it fastest.

The deadlines for every TCFD-shaped duty, from one year end, are on TCFD reporting requirements, and the framework’s status on TCFD.

Frequently asked

The FCA TCFD rule, answered

What is the FCA’s TCFD rule?

UKLR 6.6.6R(8) requires a company with a commercial companies listing to include in its annual financial report a statement of whether it has made climate-related financial disclosures consistent with the TCFD Recommendations and Recommended Disclosures, an explanation and the steps and timeframe where it has not, an explanation where any disclosure sits in another document, and where the disclosures can be found.

Parallel rules apply to the other listing categories.

Which listed companies are covered by the TCFD rule?

Companies listed in the equity shares (commercial companies), equity shares (international commercial companies secondary listing), depositary receipts, non-equity shares and non-voting equity shares, and equity shares (transition) categories, through UKLR 6.6.6R(8), 6.6.17R, 14.3.24R, 15.3.1R(3), 16.3.23R and 22.2.24R.

Is the TCFD listing rule mandatory?

It is a mandatory rule with a comply-or-explain basis: the statement itself must be made, but a company may explain why it has not made some or all of the TCFD-consistent disclosures, with the steps it is taking and a timeframe.

When does the FCA TCFD rule stop applying?

PS26/19 replaces it with UK SRS reporting on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

The TCFD statement continues to govern every accounting period that begins before that date, unless the company chooses to adopt UK SRS early.

What did PS26/19 put in place of the TCFD statement?

From accounting periods beginning on or after 1 January 2027, UKLR 6.6.6R(7A) asks for climate-related disclosures in accordance with UK SRS S2 or a statement summarising the requirements not met, the reasons and any steps planned, and (7B) does the same for UK SRS S1 on a risk basis.

UKLR 6.6.6R(8) is rewritten to cover location, assurance and, for UKLR 6, 16 and 22, the transition-plan statement.

What is TN 802.3?

The FCA’s Primary Market Technical Note on TCFD-aligned climate-related disclosure requirements for listed companies, January 2026, finalised through Primary Market Bulletin 61. It is guidance, not a rule.

The FCA has proposed deleting it in Primary Market Bulletin 66, with comments due by 28 October 2026.

Does the TCFD listing rule replace the Companies Act climate disclosures?

No. They are separate duties.

A listed company with more than 500 employees is also inside sections 414CA and 414CB of the Companies Act, and that duty continues after PS26/19.

Can a company adopt UK SRS early instead of the TCFD statement?

Yes.

Under PS26/19 ¶3.19, a company with a period beginning before 1 January 2027 may continue with the TCFD-aligned rules or voluntarily comply with the UK SRS requirements, and an early adopter can use the same transitional reliefs as periods beginning on or after 1 January 2027.

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 16 sources fromFCA HandbookFinancial Conduct Authoritylegislation.gov.ukTask Force on Climate-related Financial DisclosuresFinancial Stability BoardDepartment for Business and Trade

FCA Handbook
UKLR 6.6 — annual financial report, including UKLR 6.6.6R(8)
The TCFD statement for commercial companies, live for periods beginning before 1 January 2027.
Financial Conduct Authority
Technical Note TN 802.3 — TCFD aligned climate-related disclosure requirements for listed companies, January 2026
The scope map across UKLR 6, 14, 15, 16 and 22, and the FCA’s expectations of explanations.
Financial Conduct Authority
FG26/1 — Primary Market Bulletin No. 61
Finalised TN 802.3, effective 19 January 2026.
Financial Conduct Authority
PS20/17 — climate-related disclosures by listed issuers, December 2020
The original rule for premium listed commercial companies, from 1 January 2021.
Financial Conduct Authority
PS21/23 — climate-related disclosures by standard listed companies
Extended the rule through LR 14.3.27R for periods beginning on or after 1 January 2022.
Financial Conduct Authority
PS26/19 — Aligning listed issuers’ sustainability disclosures with international standards
Published 30 September 2026: comply or explain across UK SRS.
Financial Conduct Authority
PS26/19 (PDF), ¶¶1.9, 1.10, 3.12, 3.19 and Appendix 1
“These rules will replace the existing TCFD aligned disclosures.”
Financial Conduct Authority
Primary Market Bulletin 66
Proposes deleting TN 802.3 and consults on draft TN 803.1, comments by 28 October 2026.
Financial Conduct Authority
CP26/5 — Sustainability disclosures, consultation page
The consultation PS26/19 finalises.
FCA Handbook
Glossary: TCFD Recommendations and Recommended Disclosures
Defined by reference to Figure 4 of the TCFD Final Report.
legislation.gov.uk
Financial Services and Markets Act 2000
The Act under which the FCA makes listing rules.
legislation.gov.uk
Companies Act 2006, sections 414CA and 414CB
The separate company-law climate duty.
legislation.gov.uk
SI 2022/31 — the CFD Regulations, as made
Where the Companies Act duty came from.
Task Force on Climate-related Financial Disclosures
Recommendations
The eleven the statement is measured against.
Financial Stability Board
Annual progress report on climate-related disclosures, October 2023
The Task Force’s final task and disbanding.
Department for Business and Trade
UK SRS S1 and UK SRS S2 — publication page
The standards the replacement rule refers to.