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 regulations1 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 standards1.
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 20214.
This was introduced via listing rule LR 9.8.6R(8) for premium-listed commercial companies4.
The requirement was extended to standard-listed issuers for periods beginning on or after 1 January 20224.
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 later4.
These rules sit in Chapter 2 of the FCA's ESG Sourcebook4.
These client- and product-level disclosures are distinct from the listing rules, which concern a company's own annual report.
The transition to UK SRS does not immediately affect the ESG Sourcebook requirements4.
Companies Act & LLP regulations
The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 20222 (SI 2022/31) amend sections 414C, 414CA and 414CB of the Companies Act 20063, 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 regulations2.
The non-binding government guidance1 published alongside the regulations supports companies in interpreting the requirements.
How the two regimes interact
A UK listed company can be subject to both sets of rules1.
The listing rules reference the TCFD recommendations directly; the regulations2 set out disclosures broadly aligned with TCFD but written into legislation under the Companies Act 20063.
In practice, a company that complies with the FCA listing-rule requirement is generally taken to be meeting the regulations2 as well, and information can be cross-referenced rather than duplicated.
This was confirmed in the Government guidance1 accompanying the regulations.
UK timeline
The UK phased its TCFD-aligned rules in by entity type, then set a path to UK SRS4.
The FCA introduced listing rules for premium-listed companies in 20214, before the global ISSB standards existed.
Transition to UK SRS S2
The UK's TCFD-aligned rules are a stepping stone to the UK Sustainability Reporting Standards5 (UK SRS S1 and S2, published 25 February 2026), the UK endorsement of IFRS S1 and S2.
The FCA's CP26/54 proposes mandatory UK SRS S2 from 1 January 2027.
The proposed UK SRS S2 requirement would supersede the TCFD-aligned listing rules4 (paragraph 3.7).
Existing TCFD reporters are well positioned — see UK SRS vs TCFD and UK SRS S25.
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.
