Climate Planning
Climate transition plans and UK SRS
What it is. A climate transition plan sets out how a company will adapt its business model as the economy moves toward net zero.
Voluntary today. UK SRS S2 — published 25 February 2026 — requires disclosure of an entity’s plans where they exist, but the standard itself is not yet mandatory.
Mandatory? Still being decided. Whether transition plans are required for UK-listed companies depends on the FCA’s CP26/5 Policy Statement, expected autumn 2026.
Required If You Have One
A climate transition plan sets out how a company intends to adapt its business model and strategy as the economy moves toward net zero.
Under UK SRS S2, a company that has a transition plan must disclose it.
Whether transition plans become mandatory for all is a separate, open question: the Department for Energy Security and Net Zero (DESNZ) consulted on this in 2025 and the Government has so far kept its options open.
What a transition plan is
A transition plan is broader than a net-zero target. It articulates a company's strategic ambition for the low-carbon transition and how it will pursue that ambition — through its strategy, governance, and financial planning 19. The reference framework in the UK is the Transition Plan Taskforce (TPT) Disclosure Framework, built around three principles: Ambition, Action and Accountability 19. Responsibility for the TPT's materials passed to the IFRS Foundation in 2024, and the ISSB published its own transition-plan guidance, building on the TPT's work, in June 2025 19.
What the FCA proposes
The FCA has taken a deliberately light touch, because mandating transition plans is a matter for Government rather than the regulator 45. Under CP26/5, in-scope listed companies would be required to state whether and where they have published a transition plan, or explain why they have not — and may refer to the IFRS Educational Material to support international comparability 45.
What to do now
Are transition plans mandatory in the UK?
Not yet.
Under UK SRS S2, companies that have a transition plan must disclose it, but there's no requirement to have one.
DESNZ consulted on making transition plans mandatory in 2025 and the Government has kept its options open on whether to mandate them.
What does UK SRS S2 say about transition plans?
UK SRS S2 requires companies to disclose their transition plan where one exists, along with related metrics and targets, key assumptions, and dependencies.
Preparers are encouraged to use the ISSB's TPT-based guidance when shaping these disclosures.
What is the TPT framework?
The Transition Plan Taskforce (TPT) Disclosure Framework is built around three principles: Ambition, Action and Accountability.
The IFRS Foundation took over TPT materials in 2024, and the ISSB published transition-plan guidance building on TPT's work in June 2025.
What does the FCA require on transition plans?
The FCA proposes a light touch: in-scope listed companies would state whether and where they have published a transition plan, or explain why not.
The FCA sees mandating transition plans as a Government matter, not a regulatory one.
Will the UK make transition plans compulsory?
This is the live debate.
DESNZ has consulted on a spectrum of options from disclosure-focused to requiring companies to develop, disclose and implement 1.5°C-aligned plans.
The Government frames transition planning as central to its green finance ambitions but hasn't decided yet.
Related guides & references
UK SRS S2: Climate-Related Disclosures
Complete guide to UK SRS S2 climate reporting including transition plan requirements.
FCA Authority & CP26/5
FCA regulatory framework including light-touch transition plan disclosure proposals.
UK Sustainability Reporting Guide
Complete overview of UK sustainability reporting landscape including transition planning.
SECR: UK Energy and Carbon Reporting
Overview of existing UK energy and carbon reporting regime and relationship to UK SRS.