TCFD → UK SRS S2 — the migration story
The Task Force on Climate-related Financial Disclosures shaped a decade of corporate climate reporting before being succeeded by UK SRS S2. What changed, what carried over, and what the FCA’s transition from TCFD-aligned rules means for UK listed companies preparing for 1 January 2027.
What replaced TCFD
UK SRS S2 inherits the architecture and tightens almost every requirement. For UK listed companies, the migration is mechanical — same four pillars, same 11 disclosures, more depth.
UK SRS S2: The New Standard
The Task Force on Climate-related Financial Disclosures was established by the FSB in December 2015 and published its Final Report in June 2017.
It was disbanded on 12 October 2023, and from 2024 a monitoring duty over climate-related disclosure adoption transferred — the FSB names the ISSB, the IFRS Foundation's own release uses both nouns, and neither should be asserted against the other.
UK SRS S2, built on the ISSB's IFRS S2, is the successor standard.
For UK listed companies the FCA has proposed replacing its TCFD-aligned listing rules with mandatory UK SRS S2 for accounting periods beginning on or after 1 January 2027; the consultation closed on 20 March 2026 and no Policy Statement has been published.
The framework that shaped a decade of climate reporting
From 2015 to 2023, TCFD was the voluntary baseline that every climate-reporting standard converged on. The four-pillar architecture is its lasting legacy.
What TCFD was
The TCFD was created by the Financial Stability Board in 2015 to give companies a consistent way to disclose climate-related risks and opportunities to investors 36.
Its lasting contribution is a four-pillar structure — governance, strategy, risk management, and metrics and targets — that nearly every climate-reporting framework now uses 36. The pillar-by-pillar walkthrough of that architecture, and the eleven recommended disclosures beneath it, sit on the cluster’s TCFD framework reference; this page keeps the migration question — what changes when S2 replaces it.
In the UK it underpinned the climate-disclosure rules the FCA applied to listed companies, and similar requirements under the Companies Act 22.
The TCFD’s culmination — and what actually transferred
By 2023 the FSB judged the framework's job done. IFRS S2 is consistent with the four recommendations and the eleven recommended disclosures, and adds industry-based metrics, carbon credits and financed emissions; a monitoring duty transferred from 2024.
Why it ended
Having established a global baseline, the TCFD’s job was judged done: it was disbanded on 12 October 2023, and from 2024 the monitoring of climate-related disclosure adoption transferred. Be careful with the recipient: the FSB’s own announcement names the ISSB, while the IFRS Foundation’s press release uses both “ISSB” and “IFRS Foundation” in one document. What is not in doubt is that a monitoring duty moved, not “the work” 12.
The ISSB’s IFRS S2 carries the TCFD’s four pillars and eleven recommended disclosures — the IFRS Foundation’s own word is “consistent with” — and then asks for more: industry-based metrics, information about planned use of carbon credits, and additional information about financed emissions. So the framework lives on inside the new standards, but “fully incorporates” should never be read as “and therefore S2 asks nothing further” 36.
This is why companies already reporting under TCFD find the move to UK SRS S2 an evolution rather than a fresh start 37.
The four pillars themselves now sit in the general standard rather than the climate one: UK SRS S1 defines governance, strategy, risk management and metrics and targets for every material sustainability topic, and S2 applies that architecture to climate.
What CP26/5 means for in-scope issuers
The FCA proposes to delete the TCFD-aligned Listing Rules and replace them with mandatory UK SRS S2 from 1 January 2027 — an evolution, not a fresh start.
What it means for listed companies
In consultation paper CP26/5, the FCA proposes to delete its TCFD-aligned climate-disclosure rules and replace them with rules requiring in-scope listed companies to report against UK SRS S2, on a mandatory basis, for accounting periods beginning on or after 1 January 2027 22.
Because so much TCFD architecture carries over, the FCA judged climate disclosure mature enough to mandate — while treating the genuinely new elements, like Scope 3 and wider sustainability, more cautiously 226. *(For a practical TCFD-to-UK-SRS migration checklist, see the dedicated TCFD reporting guide.)*
TCFD → UK SRS — frequently asked
Is TCFD still required, what replaced it, the four pillars, how UK SRS S2 differs, and when the FCA rules change.
Is TCFD still required?
The TCFD was disbanded on 12 October 2023.
What transferred from 2024 was a monitoring duty over climate-related disclosure adoption, not "its work": the FSB names the ISSB, the IFRS Foundation's own release uses both nouns in one document, and neither should be asserted against the other.
The FCA proposes to delete its existing TCFD-aligned listing rules and replace them with mandatory UK SRS S2 for accounting periods beginning on or after 1 January 2027 — but that consultation closed on 20 March 2026 and no Policy Statement has been published, so the TCFD-aligned rules in UKLR 6.6.6R(8) are still the ones in force today.
What replaced TCFD?
Not yet, in law.
UK SRS S2 is built on the ISSB's IFRS S2, which carries the TCFD's four recommendations and eleven recommended disclosures — the IFRS Foundation's own word is "consistent with" — and then asks for more: industry-based metrics, information about planned use of carbon credits, and additional information about financed emissions.
Two things often said here are wrong.
Scenario analysis need not be quantified: UK SRS S2 paragraph 22 requires an approach "commensurate with the entity's circumstances", and paragraph B15 says qualitative information including scenario narratives can alone provide a reasonable and supportable basis.
And Scope 3 is not unconditionally required: paragraph C4 disapplies it with no time limit at all.
What are the TCFD four pillars?
The TCFD four pillars are governance, strategy, risk management, and metrics and targets.
This structure was TCFD's lasting contribution and is now used by nearly every climate-reporting framework including UK SRS S2, IFRS S2, and the EU's ESRS.
How is UK SRS S2 different from TCFD?
UK SRS S2 keeps the TCFD's four pillars and adds industry-based metrics, disclosure of planned use of carbon credits, and financed emissions.
It also links the disclosures explicitly to the financial statements, at paragraphs 9(d) and 15 to 21.
What it does not do is require quantified scenario analysis — paragraph 22 asks for an approach commensurate with the entity's circumstances and paragraph B15 permits scenario narratives alone — or require Scope 3 unconditionally, since paragraph C4 disapplies it with no time limit.
When do the new FCA rules start?
The FCA proposes mandatory UK SRS S2 for in-scope listed companies for accounting periods beginning on or after 1 January 2027, subject to Policy Statement confirmation expected autumn 2026.
This replaces the existing TCFD-aligned climate disclosure rules.
Continue across the TCFD guide set
Five dedicated TCFD pages plus this migration story cover the full picture — from definitional pillar to UK applicability to the UK SRS S2 transition.
TCFD — the UK guide
Cluster anchor: history, four pillars, UK applicability and the path to UK SRS S2.
RequirementsTCFD reporting requirements
Who must report, where, and when — the legal framework around TCFD in the UK.
FrameworkTCFD framework — 4 pillars + 11 disclosures
Detailed breakdown with mapping to IFRS S2 and UK SRS S2.
PracticalTCFD disclosures — practical drafting guide
How to draft each of the 11 disclosures with examples and pitfalls.
UK-specificTCFD UK requirements
FCA Listing Rules, SI 2022/31, threshold tests and the UK SRS S2 transition.
SuccessorUK SRS S1 and S2
The UK adoption of IFRS S1 and S2 that will replace the TCFD-aligned regime for listed companies.
Related guides & references
UK SRS S2: Climate-Related Disclosures
Comprehensive coverage of UK SRS S2 climate reporting requirements that succeed TCFD.
FCA Authority & CP26/5
FCA regulatory framework proposing to replace TCFD rules with UK SRS — mandatory application proposed from 1 January 2027 under CP26/5.
TCFD to UK SRS migration checklist
Practical step-by-step checklist for transitioning from TCFD to UK SRS S2 reporting.
Global Sustainability Standards
How UK SRS fits within the global ISSB framework and international standards landscape.