TCFD reporting requirements

TCFD reporting requirements in the UK are not one rule but five, each written into a different rulebook and each with its own test.

Listed companies answer to the UK Listing Rules, larger companies and LLPs to the Companies Act 2006, asset managers to the FCA’s ESG sourcebook and pension trustees to their own regulations.

On 30 September 2026 the FCA’s final rules gave the listing-rule route an end date; the others carry on.

Five groups of UK organisations must report in the shape the Task Force set out.

Listed companies — every company with equity shares, non-equity shares or depositary receipts in the five in-scope listing categories — make a TCFD statement under UKLR 6.6.6R(8) and its equivalents.

Companies with more than 500 employees that are traded, banking, insurance or AIM companies, or have turnover of more than £500 million, give eight climate-related financial disclosures under section 414CA.

LLPs with more than 500 employees give the same eight if they are traded or banking LLPs, or if their turnover is also over £500 million, under the LLP regulations.

Asset managers and asset owners regulated by the FCA publish a TCFD entity report once £5 billion or more sits in their in-scope business, under ESG 2.2.

Occupational pension schemes with £1 billion or more of relevant assets, and every authorised master trust and CDC scheme, report under SI 2021/839.

Central government departments are a sixth group, but their route is HM Treasury guidance applied on a comply-or-explain basis, not law.

The checker beside this text reads each route’s own test and names the provision that decides it.

“Mandatory TCFD” is the phrase most often used, and it is accurate for some routes and wrong for others.

The listing rule never required a company to make the eleven disclosures: it required a statement saying whether it had, and an explanation where it had not.

What was mandatory was the statement; what it said was the company’s choice, provided it explained any gap.

The Companies Act is stricter: section 414CB(A1) says the statement “must contain” the climate-related financial disclosures.

Only four of the eight — the impacts on the business model, the scenario analysis, the targets and the KPIs, limbs (e) to (h) — can be left out, and only where the directors reasonably believe they are not necessary for an understanding of the business and give a clear and reasoned explanation.

Governance, risk identification, risk integration and the principal risks themselves, limbs (a) to (d), cannot be omitted.

The FCA entity report and the pension scheme regulations are plain requirements, and the pension regime carries penalties: up to £5,000 for an individual and £50,000 for a body corporate, and a penalty of at least £2,500 that The Pensions Regulator must issue where a scheme fails to publish its report.

Whether sustainability reporting in general is mandatory in the UK is a wider question, covered on UK sustainability disclosure requirements.

The 2022 regulations amended the Companies Act for financial years beginning on or after 6 April 2022.

Section 414CA first names the classes: traded companies, banking companies, authorised insurance companies, companies carrying on insurance market activity, AIM companies, and “high turnover” companies with turnover of more than £500 million.

It then applies one floor to every class: a company with no more than 500 employees, or a parent whose group has no more than 500, is out.

So a bank with 400 staff is not caught, and neither is a private company with 5,000 staff and turnover of £300 million.

A company that qualifies as small or medium-sized is out, and so is a subsidiary covered by its parent’s group statement.

For LLPs the LLP regulations split the test in two: traded and banking LLPs need only more than 500 employees, while every other LLP needs more than 500 employees and turnover over £500 million.

Traded and banking LLPs put the disclosures in their strategic report; other large LLPs put them in their energy and carbon report.

The government’s non-binding guidance, published on 21 February 2022, has not been revised, and the government has said it intends to update it now that UK SRS S2 can discharge the disclosures.

The regulations also require a review, with the first report due before 6 April 2027, and the government has said it will consider the future of the disclosures when it considers reporting against UK SRS S2.

HM Treasury published TCFD-aligned disclosure guidance for public sector annual reports on 20 July 2023 and last updated it on 17 July 2025.

It applies to every ministerial and non-ministerial department, and to larger arm’s-length bodies and wider public sector bodies that meet its criteria or are directed to follow it.

It is guidance, applied on a comply-or-explain basis, and it builds the eleven disclosures up over three years rather than all at once.

Each relevant authority sets the requirement for its own bodies: HM Treasury for central government, the Department of Health and Social Care for NHS bodies, and CIPFA-LASAAC for local government.

Scope 3 is asked for only where it is material, and the guidance adds no new mandatory Scope 3 reporting.

The UK brought TCFD reporting in over two years, one population at a time, and is now taking the listing-rule route out again.

The first requirement bit on accounting periods beginning on or after 1 January 2021, for premium-listed commercial companies.

The largest occupational pension schemes followed from 1 October 2021.

Standard listed issuers and the largest asset managers and asset owners came in from 1 January 2022.

Companies and LLPs under the 2022 regulations followed for financial years beginning on or after 6 April 2022.

The Task Force itself disbanded on 12 October 2023, having fulfilled its remit; UK rules kept referring to its recommendations.

On 25 February 2026 the Department for Business and Trade published UK SRS S1 and S2, the UK-endorsed ISSB standards.

On 30 September 2026 the FCA published PS26/19: UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reports in 2028.

The full sequence for UK SRS, from the standards to first reports, is on the UK SRS timeline.

For an accounting period beginning before 1 January 2027 nothing changes: the TCFD statement is made as before.

A company with such a period may instead adopt UK SRS early and, unlike under the consultation’s proposal, keep the transitional reliefs.

From the first period beginning on or after 1 January 2027, the company reports against UK SRS S2 and the climate-related parts of S1, or explains what it has not disclosed, why, and the steps it plans.

In that first year it may leave out Scope 3 and, for two years, non-climate S1 matters, stating only that it is using the relief.

It must also say whether it has obtained third-party assurance, and whether it has published a climate transition plan and where, or why not; neither assurance nor a plan is required.

The four pillars carry over, so a TCFD reporter starts from its existing structure; what S2 adds is set out on UK SRS vs TCFD, and the dates by category on the UK SRS deadline.

A fictional listed bank maps its issuer, company-law and regulated-firm climate requirements before combining evidence.

An editorial route record prevents one framework statement from being mistaken for every climate reporting duty.