Plan published
State that it has been published, in the annual financial report or elsewhere, and where it can be found.
UKLR 6.6.6R(8)(e)Transition plans · Status on 11 October 2026
Transition plan reporting requirements UK: what applies now, and what is proposed
The transition plan reporting requirements in the UK are disclosure duties about a plan you may have, not a duty to have one.
UK SRS S2 ¶14(a)(iv) asks about any plan the entity has, and from 2027 the FCA asks listed companies in three categories to say whether they have published one, where, or why not.
The government’s commitment to mandate plans rests on a consultation that closed on 17 September 2025 and is still unanswered.
In brief
Transition plan reporting requirements, in five lines
No UK law or rule requires a company to have, implement or publish a climate transition plan on 11 October 2026.
What exists is a conditional disclosure in UK SRS S2, a voluntary standard that listed companies apply on a comply-or-explain basis under the FCA’s rules from periods beginning on or after 1 January 2027.
Beside it sits a new FCA statement of whether and where a plan has been published, for UKLR 6, 16 and 22 only.
The Transition Plan Taskforce’s framework is archived guidance, and the government’s plan to mandate transition plans is a commitment with an open consultation.
What a plan is and what goes in one is on the climate transition plan guide; drafting the listing-rule statement is on UK SRS transition plans; every regime is on the UK sustainability reporting requirements hub.
The status register
Every instrument, by status
Read the status column first: only the first two rows bind anyone, and neither requires a plan.
| Instrument | Status on 11 Oct 2026 | Who | What it asks |
|---|---|---|---|
| UK SRS S2 ¶14(a)(iv) | Issued 25 Feb 2026; voluntary; comply or explain for listed companies from 1 Jan 2027 | Entities applying UK SRS S2 | Information about any climate-related transition plan the entity has |
| UKLR 6.6.6R(8)(e) and equivalents | Made in PS26/19; applies to periods beginning on or after 1 Jan 2027 | UKLR 6, 16 and 22 | Whether a plan is published, where, or why not |
| FCA Handbook guidance on the IFRS document | Made in PS26/19; optional to follow | Same listed companies | May wish to use the IFRS Foundation’s June 2025 guidance |
| IFRS Foundation guidance, June 2025 | Guidance; changes nothing in IFRS S2 | Anyone applying IFRS S2 or UK SRS S2 | How to disclose transition information |
| TPT Disclosure Framework | Archived; hosted under an IFRS Foundation disclaimer | Voluntary | Five Elements and 19 Sub-Elements |
| PRA SS5/25 | In force since 3 Dec 2025; expectations, not rules | Banks and insurers | Climate risk management; no transition-plan expectation added |
| Companies Act CFD, s.414CB(2A) | In force since 6 Apr 2022 | Large companies and LLPs | Eight disclosures; none is a transition plan |
| DESNZ consultation and manifesto commitment | Proposal; closed 17 Sep 2025; no outcome | Proposed: FTSE 100 and UK-regulated financial institutions | Options from explain-why-not to develop-and-disclose |
In force: the standard
UK SRS S2 asks about the plan you have
UK SRS S2 ¶14(a)(iv) requires information about “any climate-related transition plan the entity has, including information about key assumptions used in developing its transition plan, and dependencies on which the entity’s transition plan relies”.
Appendix A defines a climate-related transition plan as “an aspect of an entity’s overall strategy that lays out the entity’s targets, actions or resources for its transition towards a lower-carbon economy”.
The duty is conditional: an entity without a plan has nothing to describe under that paragraph, though it still reports how it is responding to climate risks under the rest of ¶14.
The FCA put the point plainly in PS26/19 ¶2.36: “UK SRS S2 does not require entities to have a climate-related transition plan.”
It went on: “However, if a company has one, it must disclose certain information about it.”
UK SRS S2 itself is voluntary, as the FRC’s FAQ records; it binds listed companies only through the FCA’s comply-or-explain rules.
The standard’s strategy paragraphs are read in full on the UK SRS S2 page, and what it requires of listed companies on the UK SRS S2 reporting requirements page.
In force from 2027: the listing rules
The FCA’s statement: whether, where, or why not
The FCA’s consultation set the line at CP26/5 ¶1.7: “Mandating that companies have transition plans is a matter for Government.”
Its final rules kept it: “We are not requiring listed companies to produce transition plans.”
And: “Nor are we introducing requirements for the location of transition plans.”
The made rule, UKLR 6.6.6R(8)(e), asks instead whether the company has published a climate-related transition plan, in its annual financial report or elsewhere, and where, or why not.
The FCA “finalised the scope of these requirements as consulted on, with the secondary listing and depositary receipts categories remaining out of scope”.
It also said it is “not placing requirements around the content of explanations”, unlike its comply-or-explain regime for UK SRS disclosures.
Its guidance says listed companies that produce a plan may wish to use the IFRS Foundation’s June 2025 guidance, and the FCA agreed that use “should remain optional”.
The rule applies to accounting periods beginning on or after 1 January 2027; the wider FCA package is on the UK SRS and the FCA page.
Listed company in UKLR 6, 16 or 22, period beginning on or after 1 January 2027
No plan published
State why the company has not published one; the FCA sets no content requirements for the reason.
PS26/19 response after ¶2.44UKLR 14 or 15
No plan statement; UK SRS still applies on a comply-or-explain basis.
Out of scope of (8)(e)Archived guidance
The TPT framework and its handover
The Transition Plan Taskforce was created by the UK government to develop a framework for transition plan disclosures, the IFRS Foundation’s guidance records.
It published its Disclosure Framework in October 2023, sector material in April 2024, and in October 2024 “completed its work and disbanded”.
The IFRS Foundation now hosts the disclosure material on its Knowledge Hub, with the notice that the content was authored by the TPT and “the IFRS Foundation is not responsible for its accuracy”.
Guidance on the planning process itself went to the International Transition Plan Network, a network of over 30 public sector organisations.
The IFRS Foundation’s own guidance of 23 June 2025 builds on the TPT material and “does not add to or otherwise change the requirements in IFRS S2”.
It also states that IFRS S2 “does not require an entity to have a transition plan nor require an entity to publish a transition plan as long as the requirements in IFRS S2 are met”.
So “TPT-aligned” describes a voluntary choice, not compliance with a standard; the framework’s Elements are explained on the climate transition plan page.
- 1
October 2023
The TPT publishes its Disclosure Framework: Ambition, Action and Accountability; five Elements; 19 Sub-Elements.
- 2
April 2024
Sector material follows, including detailed guidance for seven sectors.
- 3
October 2024
The TPT completes its work and disbands.
- 4
IFRS Foundation
Assumes responsibility for 13 disclosure-specific resources, hosted with an accuracy disclaimer.
- 5
ITPN
Assumes the legacy guidance on the transition planning process.
Proposal
The government’s consultation, still unanswered
The government has committed to mandating “UK-regulated financial institutions (including banks, asset managers, pension funds and insurers) and FTSE 100 companies to develop and implement credible transition plans that align with the 1.5°C goal of the Paris Agreement”.
The DESNZ consultation on how to do it ran from 1pm on 25 June 2025 to 11:59pm on 17 September 2025.
Its implementation-routes document set out options including requiring entities to explain why they have not disclosed a transition plan or transition plan-related information, and requiring entities to develop and disclose transition plans.
It also asked whether plans should be aligned with net zero and whether implementation should be required.
It said that once the government had decided its overall approach, it “will consult again on the detail of any future obligations”.
When this page was checked on 11 October 2026, the consultation page still read “Visit this page again soon to download the outcome to this public feedback”, with no outcome attached.
What this is, and what it is not
A manifesto commitment and a consultation that has not been answered.
Not law, not a decision, and not a date: nothing in it applies to anyone today.
Any requirement would need a further consultation on detail and then legislation or rules.
Financial sector
What the PRA and FCA expect of firms
For banks and insurers, the PRA’s SS5/25 commenced on 3 December 2025 and “replaces SS3/19 in its entirety”.
It sets supervisory expectations on governance, risk management, scenario analysis, data and disclosures; a supervisory statement sets expectations and is not a rule.
SS5/25 ¶3.2 expected firms to complete an internal review against the new expectations within six months, by 3 June 2026, and to plan how to close any gaps.
On transition plans the PRA chose not to act: in PS25/25 ¶2.69 it records requests for expectations on transition plans and says it “decided not to add expectations in response to these requests”.
Asset managers and asset owners in the FCA’s ESG sourcebook keep their entity-level TCFD report under ESG 2.2, a separate regime from the listing rules and not a duty to have a plan.
Occupational pension schemes have their own climate regime under DWP regulations, set out on the pension scheme climate reporting requirements page.
Fund-level and firm-level FCA disclosures are on the SDR reporting requirements page.
What is not required
Myths about UK transition plan reporting
“The FCA requires listed companies to have a transition plan” is wrong: PS26/19 says the opposite.
“The plan must be in the annual report” is wrong: the FCA set no location requirement, and a plan may be standalone.
“UKLR 14 and 15 issuers make the plan statement” is wrong: they are out of scope of it.
“The TPT is the UK standard” is wrong: it is archived guidance with no legal status.
“FTSE 100 companies must publish 1.5°C plans from a set date” is wrong: that is a commitment under consultation, with no date.
“The Companies Act CFD rules require a plan” is wrong: the eight items in section 414CB(2A) do not include one, as the CFD reporting requirements page sets out.
How it fits
Transition plans beside other UK and EU regimes
| Regime | Plan required? | What it does ask | Read more |
|---|---|---|---|
| UK SRS S2 | No | Disclose any plan the entity has; targets under ¶¶33–36 | UK SRS S2 requirements |
| FCA listing rules | No | Whether and where a plan is published, or why not | UK SRS requirements |
| Companies Act CFD | No | Eight climate disclosures, including targets and KPIs | CFD requirements |
| PPN 006 | A carbon reduction plan, for in-scope bidders | A procurement requirement, not a disclosure duty | Carbon reduction plan requirements |
| ISSB / IFRS S2 | No | Disclose any plan the entity has | ISSB requirements |
| EU CSRD / ESRS | Set by EU rules, not UK rules | Reaches UK companies only where they fall within EU scope | CSRD requirements |
Science-based targets are a separate voluntary scheme, covered on the SBTi page.
What remains a proposal
What could change, and what has not
Proposal: the government’s commitment to mandate credible 1.5°C-aligned plans for UK-regulated financial institutions and FTSE 100 companies.
Proposal: the options in the 2025 consultation, from explaining why no plan is disclosed to developing and disclosing one, with a promise to consult again on detail.
Not a proposal: the FCA’s statement, which is final and applies from 2027, and which the FCA says it will keep under review while it engages with the government.
The Modernising corporate reporting consultation, open until 30 November 2026, is a separate exercise on company reporting; its proposals are proposals and are covered on the Modernising corporate reporting page.
Status on 11 October 2026
In force or made: UK SRS S2 ¶14(a)(iv) for those applying it; UKLR 6.6.6R(8)(e) from 1 January 2027.
Guidance: the IFRS Foundation’s June 2025 document; the archived TPT framework.
Proposed: any duty to have or publish a plan.
Check yourself
Six statements about transition plan rules
Each answer names the provision or document it turns on.
The listed-company rules sit in the FCA’s PS26/19; the standard is on GOV.UK with the UK SRS publication.
How these rules fit into wider climate reporting is on the TCFD reporting requirements and carbon reporting requirements pages.
Transition plan reporting: true or false?
UK SRS S2 requires every entity applying it to have a transition plan.
A UKLR 6 listed company with no plan must say why it has not published one.
A secondary-listed company in UKLR 14 makes the transition plan statement.
The FCA requires transition plans to be published in the annual report.
The TPT still maintains its Disclosure Framework.
The government has published its response to the 2025 transition plan consultation.
0 of 6 answered.
Nothing you choose is stored or sent.
Frequently asked
Transition plan reporting requirements, answered
Are transition plans mandatory in the UK?
No. On 11 October 2026 no UK law or rule requires a company to have, implement or publish a climate transition plan.
The government has a manifesto commitment to mandate credible 1.5°C-aligned plans for UK-regulated financial institutions and FTSE 100 companies, and it consulted on how from 25 June to 17 September 2025, but it has published no outcome.
What are the transition plan reporting requirements in the UK today?
Two disclosure duties, neither of which requires a plan.
UK SRS S2 ¶14(a)(iv) asks an entity applying the standard to disclose information about any climate-related transition plan it has.
From accounting periods beginning on or after 1 January 2027, the FCA’s UKLR 6.6.6R(8)(e) requires listed companies in UKLR 6, 16 and 22 to state whether they have published a plan and where, or why not.
Does UK SRS S2 require a transition plan?
No. Paragraph 14(a)(iv) requires information about “any climate-related transition plan the entity has”, including key assumptions and dependencies.
The FCA’s PS26/19 says in terms that UK SRS S2 does not require entities to have a climate-related transition plan.
What does the FCA require listed companies to say about transition plans?
A statement in the annual financial report of whether the company has published a climate-related transition plan, in that report or elsewhere; if so, where it can be found; and if not, why not.
The FCA sets no requirements for the content of the explanation and none for where a plan is located.
Which listed companies make the transition plan statement?
Companies in the commercial companies, non-equity shares and non-voting equity shares, and transition categories — UKLR 6, 16 and 22.
The FCA kept secondary listings (UKLR 14) and depositary receipts (UKLR 15) out of scope of this statement, although those issuers report against UK SRS on a comply-or-explain basis.
When does the FCA’s transition plan statement apply?
For accounting periods beginning on or after 1 January 2027, under the rules made in PS26/19.
For a calendar-year company the first statement will appear in the annual report for 2027, published in 2028.
Is the TPT Disclosure Framework a legal requirement?
No. The Transition Plan Taskforce completed its work and disbanded in October 2024.
Its disclosure material is hosted by the IFRS Foundation, which says it is not responsible for its accuracy, and its guidance on the planning process passed to the International Transition Plan Network. It is guidance an entity may choose to use.
What happened to the Transition Plan Taskforce?
The TPT published its Disclosure Framework in October 2023 and sector material in April 2024, then completed its work and disbanded in October 2024.
The IFRS Foundation assumed responsibility for 13 disclosure-specific resources, and the ITPN for the legacy guidance on the transition planning process.
What is the IFRS guidance on transition plans?
A June 2025 IFRS Foundation document, Disclosing information about an entity’s climate-related transition, including information about transition plans, in accordance with IFRS S2.
It builds on the TPT material, says it does not add to or otherwise change the requirements in IFRS S2, and says IFRS S2 does not require an entity to have or publish a transition plan.
The FCA’s guidance says listed companies may wish to use it; using it is optional.
What did the government consult on for transition plans?
The DESNZ consultation, Climate-related transition plan requirements, asked how to take forward the manifesto commitment.
Its options included requiring entities to explain why they have not disclosed a transition plan or transition plan-related information, and requiring entities to develop and disclose transition plans. It also asked about implementation and alignment.
Has the government responded to the transition plan consultation?
Not as at 11 October 2026.
The GOV.UK page still says “Visit this page again soon to download the outcome to this public feedback”.
The implementation-routes document said the government would consult again on the detail of any future obligations once it had decided its overall approach.
Do banks and insurers have to publish transition plans?
No rule requires it.
The PRA’s SS5/25, which replaced SS3/19 on 3 December 2025, sets supervisory expectations for managing climate-related risks, and in PS25/25 the PRA said it decided not to add expectations on transition plans in response to requests for them.
Any future requirement would come from the government’s policy, which is still open.
Does the Companies Act CFD duty require a transition plan?
No. The eight climate-related financial disclosures in section 414CB(2A) cover governance, risk processes, principal risks, impacts, scenario resilience, targets and indicators, but none requires a transition plan.
Is a carbon reduction plan the same as a transition plan?
No. A carbon reduction plan under PPN 006 is a public procurement requirement for bidders on certain central government contracts.
It is not a transition plan disclosure under UK SRS or the listing rules, though the content can overlap.
Can a company say it has a TPT-aligned transition plan?
It can describe its plan that way voluntarily, since the framework is guidance anyone may use.
What it cannot do is present that as compliance with a legal standard, and any claims in the plan remain subject to the general law on misleading statements.
What changes are proposed for UK transition plan reporting?
Only proposals: the government’s commitment and its unanswered 2025 consultation.
The FCA says it will keep its requirements under review and continue to engage with the government.
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 19 sources fromDepartment for Business and TradeFinancial Conduct AuthorityDepartment for Energy Security and Net ZeroIFRS FoundationTransition Plan Taskforce (hosted by the IFRS Foundation)International Transition Plan Network
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (PDF), ¶14(a)(iv) and Appendix A
The conditional disclosure about any transition plan the entity has, and the definition of a climate-related transition plan.
- Department for Business and TradeUK Sustainability Reporting Standards S1 and S2
Published 25 February 2026 for voluntary use.
- Financial Conduct AuthorityPS26/19: aligning listed issuers’ sustainability disclosures with international standards
The final rules, 30 September 2026.
- Financial Conduct AuthorityPS26/19 (PDF), ¶¶2.36–2.44, the response on transition plans, and Appendix 1
“We are not requiring listed companies to produce transition plans”; UKLR 6.6.6R(8)(e).
- Financial Conduct AuthorityCP26/5 (PDF), ¶¶1.7 and 6.4–6.11
“Mandating that companies have transition plans is a matter for Government.”
- Financial Conduct AuthorityFCA Handbook, UKLR 6.6 — annual financial report
Where the listing-rule statement sits.
- Department for Energy Security and Net ZeroClimate-related transition plan requirements — consultation
Ran 25 June to 17 September 2025; no outcome published on 11 October 2026.
- Department for Energy Security and Net ZeroTransition plan requirements: implementation routes
The manifesto commitment, Options 1 and 2, and the promise to consult again on detail.
- IFRS FoundationTransition Plan Taskforce resources — IFRS Sustainability Knowledge Hub
The TPT’s disclosure material, now the IFRS Foundation’s responsibility.
- Transition Plan Taskforce (hosted by the IFRS Foundation)TPT Disclosure Framework, October 2023 (PDF)
Three principles, five Elements and 19 Sub-Elements; archived guidance.
- IFRS FoundationDisclosing information about an entity’s climate-related transition, including information about transition plans, in accordance with IFRS S2 (PDF)
June 2025; does not add to or change IFRS S2.
- IFRS FoundationIFRS Foundation publishes guidance on disclosures about transition plans, 23 June 2025
The publication announcement.
- International Transition Plan NetworkITPN
Holds the TPT’s legacy guidance on the transition planning process.
- Prudential Regulation AuthoritySS5/25 — Enhancing banks’ and insurers’ approaches to managing climate-related risks
Commenced 3 December 2025 and replaced SS3/19 in its entirety.
- Prudential Regulation AuthorityPS25/25 — policy statement on SS5/25, ¶2.69
The PRA decided not to add expectations on transition plans.
- Financial Conduct AuthorityFCA Handbook, ESG 2.2 — entity-level TCFD reporting for asset managers and asset owners
The separate ESG sourcebook regime.
- legislation.gov.ukCompanies Act 2006, section 414CB
The CFD duty: eight disclosures, none of them a transition plan.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation document (PDF)
Open until 30 November 2026; proposals, not law.
- Financial Reporting CouncilSustainability Reporting Developments: Frequently Asked Questions
UK SRS is not currently mandatory; last updated 26 February 2026.