Climate Planning

Climate transition plans and UK SRS

A climate transition plan sets out how a company will adapt its business model as the economy moves toward net zero. UK SRS S2 requires disclosure where plans exist, but whether transition plans become mandatory is still being decided.

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

Companies with a transition plan should ensure it is disclosed in line with UK SRS S2 and shaped around the TPT/ISSB structure 19 20. Those without one should watch the DESNZ process closely, since the direction of travel is clearly toward stronger requirements over time 18.

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

Standards

UK SRS S2: Climate-Related Disclosures

Complete guide to UK SRS S2 climate reporting including transition plan requirements.

12 min readStandards

Regulation

FCA Authority & CP26/5

FCA regulatory framework including light-touch transition plan disclosure proposals.

10 min readRegulation

Overview

UK Sustainability Reporting Guide

Complete overview of UK sustainability reporting landscape including transition planning.

15 min readOverview

UK Regimes

SECR: UK Energy and Carbon Reporting

Overview of existing UK energy and carbon reporting regime and relationship to UK SRS.

8 min readUK Regimes

Last verified May 2026Reviewed by UK SRS Transition Planning Team

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