TCFD in the UK
The UK made TCFD-aligned disclosure mandatory through two parallel routes: FCA rules for listed companies and certain financial firms, and Companies Act and LLP regulations for large companies and partnerships.
Together these made the UK one of the first economies to require economy-wide climate disclosure, ahead of the global ISSB standards.
The broader framework is explained in what is TCFD.
FCA listing rules
The FCA required UK premium-listed commercial companies to state whether they have made disclosures consistent with the TCFD framework, on a comply-or-explain basis, for accounting periods beginning on or after 1 January 2021.
The requirement was extended to standard-listed issuers for periods beginning on or after 1 January 2022.
Following the FCA's 2024 restructuring of the listing regime, these requirements now sit within the UK Listing Rules for the equivalent categories.
FCA rules for asset managers and owners
Separately, the FCA introduced TCFD-aligned disclosure rules in its ESG Sourcebook for asset managers and certain asset owners, beginning with the largest firms from 1 January 2022 and extending to smaller firms a year later.
These client- and product-level disclosures are distinct from the listing rules, which concern a company's own annual report.
Companies Act & LLP regulations
The regulations amend sections 414C, 414CA and 414CB of the Companies Act 2006, requiring in-scope organisations to disclose climate information in a non-financial and sustainability information statement within the strategic report.
The disclosures cover all four TCFD categories — Governance, Strategy, Risk Management, and Metrics & Targets — as set out in the 2022 regulations.
How the two regimes interact
A UK listed company can be subject to both sets of rules.
The listing rules reference the TCFD recommendations directly; the regulations set out disclosures broadly aligned with TCFD but written into legislation.
In practice, a company that complies with the FCA listing-rule requirement is generally taken to be meeting the regulations as well, and information can be cross-referenced rather than duplicated.
UK timeline
The UK phased its TCFD-aligned rules in by entity type, then set a path to UK SRS.
Transition to UK SRS S2
The UK's TCFD-aligned rules are a stepping stone to the UK Sustainability Reporting Standards (UK SRS S1 and S2, published 25 February 2026), the UK endorsement of IFRS S1 and S2.
The FCA's CP26/5 proposes mandatory UK SRS S2 from 1 January 2027.
Existing TCFD reporters are well positioned — see UK SRS vs TCFD and UK SRS S2.
Frequently asked questions
Is TCFD mandatory in the UK?
Yes — TCFD-aligned disclosure has been mandatory for UK listed companies under FCA rules since 2021, and for large companies and LLPs under the Companies Act and LLP regulations since 6 April 2022. These rules remain in force pending the move to UK SRS.
Which companies must report TCFD in the UK?
UK listed commercial companies (premium from 2021, standard from 2022), plus large companies and LLPs — broadly those with more than 500 employees and turnover above £500 million — for financial years beginning on or after 6 April 2022.
What is the difference between the FCA rules and the Companies Act regulations?
The FCA listing rules reference the TCFD recommendations directly on a comply-or-explain basis; the Companies Act and LLP regulations set out disclosures broadly aligned with TCFD but written into legislation. A listed company complying with the listing rules is generally treated as meeting the regulations too.
Will TCFD be replaced in the UK?
Yes. The FCA consulted (CP26/5) on requiring UK SRS S2 — the UK endorsement of IFRS S2 — proposed from 1 January 2027, which would supersede the TCFD-aligned listing rules.
