Transition plans · UK SRS S2 · UKLR 6.6.6R(8)(e)
Transition plans under UK SRS: a statement, not a duty to have one
No UK company must have a climate transition plan.
What exists is a duty to describe a plan if you have one, in UK SRS S2 ¶14(a)(iv), and from 2027 a listing-rule statement of whether you have published a plan, where it is, or why not.
The government’s promise to mandate plans is still a promise: its consultation closed on 17 September 2025 and has not been answered.
Three instruments, three statuses
Who asks what about your transition plan
Almost every confusion about UK transition plans comes from reading one of these three as though it were another.
| Instrument | What it asks | Status | Who it reaches |
|---|---|---|---|
| UK SRS S2 ¶14(a)(iv) | Describe any transition plan the entity has, with its key assumptions and dependencies | Final standard · voluntary | Anyone applying UK SRS S2 |
| UKLR 6.6.6R(8)(e) | State whether a plan is published, where it is, or why not | Final rule · from 1 January 2027 | Listed companies in UKLR 6, 16 and 22 |
| DESNZ consultation | Option 1: explain why no plan is disclosed · Option 2: develop and disclose one | Consultation · unanswered | Proposed: regulated financial institutions and FTSE 100 companies |
| TPT Disclosure Framework | Five Elements of a transition-plan disclosure | Archived guidance · never law | Anyone who chooses to use it |
The standard and the rule are both final; only the standard is voluntary, and only the rule says anything about where a plan goes or what to say if there is none.
What UK SRS S2 asks across the rest of its strategy section is on UK SRS S2; the two standards together are on UK SRS S1 and S2.
The standard
UK SRS S2 asks about the plan you already have
The operative word is “has”: paragraph 14(a)(iv) is a conditional disclosure duty, triggered by a plan’s existence.
Appendix A defines the plan as an aspect of an entity’s overall strategy that lays out its targets, actions or resources for its transition towards a lower-carbon economy — so it need not be a separate document.
The government’s own reading is blunt: “UK SRS S2 will not require an entity to have a transition plan or to set climate targets in line with a particular climate goal”.
The standard is silent on the Transition Plan Taskforce; it neither refers to nor encourages the TPT’s material.
The same paragraph appears in the international original, IFRS S2, on the IFRS Foundation’s standards navigator.
The IFRS Foundation’s guidance of 23 June 2025 on transition-plan disclosure under IFRS S2 says it “does not add to or otherwise change the requirements in IFRS S2”, and that IFRS S2 does not require an entity to have or publish a plan.
UK SRS itself is voluntary for any entity the FCA’s rules do not reach, and the dated register of events sets out when the rules bite.
The entity shall disclose 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”.
Source: UK SRS S2
The FCA statement
From 2027, a listed company says whether, where, or why not
The consultation by the Financial Conduct Authority, CP26/5 ¶1.7, set its line: “Mandating that companies have transition plans is a matter for Government.”
The final rules kept it: “We are not requiring listed companies to produce transition plans.
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 also decided against rules on what the “why not” must contain, given “the varying maturity of transition planning across issuers and its different relevance across sectors” — a deliberate contrast with the UK SRS explanations, where content is prescribed.
The FCA sees the statement as complementary to UK SRS S2, not a duplicate of it: the statement is about the existence and location of a plan, while S2 says what to disclose where a plan exists.
Using the IFRS guidance document is optional, and the FCA recognises that issuers may use other materials, such as the TPT Disclosure Framework.
The statement appears alongside the location and assurance statements in the same rule; the FCA and UK SRS takes the rule limb by limb, and UK SRS reporting shows where each disclosure sits in the report.
The three possible statements
Published in the annual report. Say so, and point to the section.
Published elsewhere. Say where it can be found — a standalone document or a website.
Not published. Say why not.
The FCA sets no requirements for the content of that explanation.
Source: PS26/19, UKLR 6.6.6R(8)(e) and the response after ¶2.44
Draft the statement
Write your transition-plan statement
The statement is short, and the hard part is knowing which version applies to you.
The builder beside this text starts from your listing category, because the statement exists only for UKLR 6, 16 and 22.
If you have published a plan, it asks where, and writes the sentence that points a reader to it.
If you have not, it gives you a place to say why in your own words — the FCA prescribes no content for that explanation.
The output is a starting draft in plain words, not FCA model wording, and nothing you type is stored or sent.
Listing rules · transition-plan statement · draft builder
A starting draft
The Company has published a climate-related transition plan. It is available at [web address or document].
The rule asks whether a plan is published and where, or why not.
It does not require you to have a plan, and it does not prescribe where one is published.
Rule: UKLR 6.6.6R(8)(e) and its equivalents for UKLR 16 and 22, made by the FCA on 24 September 2026 (PS26/19) and in force from 1 January 2027.
A drafting aid in plain words, not FCA model wording.
Nothing is stored or sent.
Who makes the statement
Secondary listings report on UK SRS but skip this statement
The transition-plan statement reaches listed companies in the commercial companies, non-equity and non-voting equity shares, and transition categories — UKLR 6, 16 and 22.
In the FCA’s words, it has “finalised the scope of these requirements as consulted on, with the secondary listing and depositary receipts categories remaining out of scope”.
That is a narrower population than UK SRS reporting itself, which under the final rules also reaches UKLR 14 and 15 on a comply-or-explain basis.
The FCA gives its reason: transition-plan requirements can be shaped by jurisdiction-specific factors such as national net zero targets.
So a company with a secondary listing in London reports against UK SRS S2, including ¶14(a)(iv) where it has a plan, but does not make the separate listing-rule statement of whether and where.
Category by category, the scope is on who is in scope.
What a plan contains
What a plan is usually built from, and where each part is asked for
No UK rule sets a plan’s contents.
Where a company has one and reports under UK SRS S2, the standard asks about specific parts of it; the archived TPT framework is one voluntary way to organise the rest.
| Part of a plan | Asked for by UK SRS S2 | TPT Element (voluntary) |
|---|---|---|
| Ambition and key assumptions | ¶14(a)(iv): key assumptions and dependencies the plan relies on | Foundations |
| Actions and resources | ¶14(a)(iv)–(v): the plan, and how the entity plans to achieve its targets | Implementation Strategy |
| Value chain and stakeholders | ¶13(b): where in the value chain risks and opportunities are concentrated | Engagement Strategy |
| Targets and progress | ¶¶33–36 targets, gross and net; ¶14(c) progress on earlier plans | Metrics and Targets |
| Oversight | ¶6: governance, including how targets feed remuneration (¶6(a)(v), ¶29(g)) | Governance |
| Carbon credits | ¶36: planned use of carbon credits to achieve net targets | Metrics and Targets |
UK SRS S2 defines a climate-related transition plan as an aspect of an entity’s overall strategy that lays out its targets, actions or resources for the transition towards a lower-carbon economy.
So a plan can live inside the strategy section of the annual report; it need not be a separate document, and the FCA leaves the location to the company.
For a net target, UK SRS S2 asks for the gross target as well, so a plan that leans on credits shows both numbers.
A sequence that works in practice is to fix the targets first, then the actions and resources to meet them, then the governance that holds people to them — and to write the assumptions down as you go, because ¶14(a)(iv) asks for them.
Searches for “sustainability and transformation plans” usually mean NHS planning in England, a different subject from climate transition plans.
Government policy
The promise to mandate plans is still a promise
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”, as its implementation-routes document records.
The consultation on how to do it ran from 25 June to 17 September 2025.
It was still choosing between two routes: requiring entities to explain why they have not disclosed a transition plan or transition plan-related information, or requiring them to develop and disclose one.
When the page was last checked, on 28 September 2026, it still read “We are analysing your feedback”, with no outcome attached.
A manifesto commitment and an unanswered consultation are not law, and nothing in them applies to anyone today.
The separate Modernising Corporate Reporting programme, and the UK SRS legislation page, cover the other routes by which UK SRS could reach unlisted companies.
| Date | Event |
|---|---|
| 25 Jun 2025 | Consultation opens, beside the UK SRS exposure drafts |
| 17 Sep 2025 | Consultation closes |
| 28 Sep 2026 | Page re-checked: “We are analysing your feedback” |
Frameworks you may use
The TPT, the IFRS guidance and targets
The Transition Plan Taskforce completed its work and disbanded in October 2024.
Its disclosure material — thirteen resources, including the Disclosure Framework, a sector summary covering 30 sectors, seven sector guidances and three mappings — now sits on the IFRS Sustainability Knowledge Hub, which states that the IFRS Foundation is not responsible for its accuracy.
The Disclosure Framework is organised in five Elements: Foundations, Implementation Strategy, Engagement Strategy, Metrics and Targets, and Governance.
Guidance on the planning process itself — how to build a plan, rather than how to disclose one — passed to the International Transition Plan Network.
So “TPT-aligned” is a voluntary description of how a plan was drafted, not a compliance position under UK SRS or the listing rules.
The transition-plan idea began in the TCFD’s strategy recommendation, and the UK’s own statutory target — net zero by 2050, set by SI 2019/1056 — is the benchmark a UK plan is most often read against.
Targets are a separate choice: the Science Based Targets initiative validates targets voluntarily, under its Corporate Net-Zero Standard; see science-based targets.
The practical content of a plan is on climate transition plans, and the family’s editorial guide to net zero consultancy describes the specialist support that exists.
No rule requires a transition plan to be assured.
The listing rule asks whether assurance was obtained over the UK SRS disclosures; see sustainability assurance and UK SRS compliance.
Test yourself
Six claims about transition plans, checked
Each statement beside this text has appeared in guidance or commentary since the FCA’s consultation in January 2026.
The first two describe what the consultation proposed or what readers expected, not what the final rules say.
The fifth confuses a commitment with a law, which is the commonest error on this subject.
Nothing you choose is stored or sent.
Transition plans in the UK: true or false?
Listed companies must have a climate transition plan from 2027.
A company with a secondary listing in London makes the transition-plan statement.
UK SRS S2 requires information about a transition plan only if the entity has one.
A “why not” explanation for having no plan must follow content the FCA prescribes.
The government has legislated to require FTSE 100 companies to have transition plans.
The TPT Disclosure Framework is binding guidance in the UK.
0 of 6 answered.
Nothing you choose is stored or sent.
Frequently asked
Questions people ask
Are transition plans mandatory in the UK?
No. No UK entity is under a legal duty to have, implement or publish a climate transition plan.
The government has committed to mandating credible 1.5°C-aligned plans for UK-regulated financial institutions and FTSE 100 companies and consulted on how, from 25 June to 17 September 2025, but it has published no response.
The FCA’s final rules say in terms that it is not requiring listed companies to produce transition plans.
Does UK SRS S2 require a transition plan?
No. UK SRS S2 paragraph 14(a)(iv) asks an entity applying the standard to disclose information about “any climate-related transition plan the entity has”, including key assumptions and dependencies.
It is a duty to describe a plan you have, not a duty to have one, and the government’s own reading is that UK SRS S2 will not require an entity to have a transition plan.
What must a listed company say about its transition plan?
From accounting periods beginning on or after 1 January 2027, UKLR 6.6.6R(8)(e) requires a statement in the annual financial report of whether the company has published a climate-related transition plan, in the report or elsewhere; if it has, where it can be found; and if it has not, why not.
The FCA sets no requirements for the content of that explanation.
Does the transition-plan statement apply to secondary listings?
No. The FCA finalised the scope of the transition-plan statement as consulted on, “with the secondary listing and depositary receipts categories remaining out of scope”.
Companies in UKLR 14 and 15 report against UK SRS on a comply-or-explain basis like other listed companies, but do not make the separate UKLR 6.6.6R(8)(e) statement.
Is the TPT framework still in force?
It was never law.
The Transition Plan Taskforce completed its work and disbanded in October 2024.
Its disclosure material is archived on the IFRS Sustainability Knowledge Hub under a notice that the IFRS Foundation is not responsible for its accuracy, and its process guidance passed to the International Transition Plan Network.
The FCA has said companies may use the TPT Disclosure Framework or other materials; none is required.
Do I need science-based targets for a transition plan?
No UK rule requires them.
UK SRS S2 asks for the targets an entity has set and how it measures progress.
Science-based targets validated by the SBTi are a voluntary route to setting them, and the SBTi’s Corporate Net-Zero Standard V2.0, published in June 2026, is not yet the version companies set targets against.
What should a climate transition plan include?
No UK rule prescribes its contents.
Where a company has a plan and reports under UK SRS S2, the standard asks for the plan’s key assumptions and dependencies (¶14(a)(iv)), how the entity plans to achieve its climate-related targets (¶14(a)(v)), and progress on plans disclosed before (¶14(c)), alongside the targets themselves under ¶¶33–36.
The archived TPT Disclosure Framework organises a plan in five Elements: Foundations, Implementation Strategy, Engagement Strategy, Metrics and Targets, and Governance.
What is the TPT Disclosure Framework?
Voluntary guidance published by the UK’s Transition Plan Taskforce in October 2023, setting out how to disclose a transition plan in five Elements.
The Taskforce disbanded in October 2024 and its material is archived on the IFRS Sustainability Knowledge Hub.
Using it is optional; the FCA recognises that issuers may use it or other materials.
Is a transition plan the same as a net zero target?
No. A target is a number and a date; a plan, in UK SRS S2’s definition, lays out the targets, actions or resources for the transition.
UK SRS S2 asks about targets under ¶¶33–36 whether or not a plan exists, and asks how the entity plans to achieve them under ¶14(a)(v).
Where does a listed company publish its transition plan?
Wherever it chooses.
The FCA said it is not introducing requirements for the location of transition plans; the listing-rule statement says only whether a plan has been published, in the annual financial report or elsewhere, and where it can be found.
What is a climate-related transition plan?
UK SRS S2 Appendix A defines it 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.
It need not be a standalone document; the FCA leaves the location to the company.
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.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (PDF) — ¶14(a)(iv) and Appendix A
The conditional duty: “any climate-related transition plan the entity has”, and the definition of a plan.
- Department for Business and TradeUK SRS S1 and UK SRS S2 — publication page
The standards, published 25 February 2026 for voluntary use.
- Financial Conduct AuthorityPS26/19 (PDF): the response after ¶2.44, and Appendix 1 (UKLR 6.6.6R(8)(e))
“We are not requiring listed companies to produce transition plans”; secondary listings and depositary receipts remain out of scope of the statement.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
Published 30 September 2026.
- Financial Conduct AuthorityCP26/5: the consultation — ¶¶1.7, 6.9–6.11
“Mandating that companies have transition plans is a matter for Government.”
- FCA HandbookUKLR 6.6 — the annual financial report
Where the transition-plan statement sits from 1 January 2027.
- DESNZ / DBTClimate-related transition plan requirements — consultation
Ran 25 June to 17 September 2025; still “analysing your feedback” when re-checked on 28 September 2026.
- DESNZ / DBTTransition plan requirements: implementation routes
The manifesto commitment, the two options consulted on, and “UK SRS S2 will not require an entity to have a transition plan”.
- IFRS FoundationDisclosing information about an entity’s climate-related transition, including information about transition plans (PDF), 23 June 2025
Does not add to or change the requirements in IFRS S2; says where the TPT’s process guidance went.
- IFRS FoundationTransition Plan Taskforce resources (Sustainability Knowledge Hub)
The archived TPT disclosure material, hosted under an accuracy disclaimer.
- Transition Plan Taskforce (archived)TPT Disclosure Framework, October 2023 (PDF)
Five Elements; voluntary guidance, never law.
- International Transition Plan NetworkITPN
Holds the TPT’s legacy guidance on the transition-planning process.
- legislation.gov.ukThe Climate Change Act 2008 (2050 Target Amendment) Order 2019, SI 2019/1056
The UK’s statutory net zero target, which a plan may be assessed against.
- TCFD (archive)TCFD recommendations
Where transition-plan disclosure began, in the strategy recommendation.