Transition plans under UK SRS

The disclose-or-explain approach

UK SRS S21 does not require an entity to have a climate-related transition plan or to set climate targets aligned with any particular goal. The standard does, however, require specific information to be disclosed where an entity has a plan.

Under FCA CP26/52, in-scope companies would be required to state whether and where a transition plan has been published, but not to publish one2. Where no plan has been published, the entity must provide reasons.

The wider question of mandatory transition plan requirements is being considered separately by the UK Government2 — a consultation is expected during 2026 on whether certain large companies should be required to produce and publish a transition plan, the minimum content requirements, and the relationship with UK SRS disclosures.

UK SRS S2 disclosure requirements

Where an entity has a transition plan, S2 requirements paragraph 14(a)(iii)1 requires disclosure of key assumptions used in developing the plan and dependencies on which the plan relies1.

This connects to the broader Strategy pillar requirements. UK SRS S2 paragraph 131 requires disclosure of current and anticipated effects of climate-related risks and opportunities on the business model and value chain — the transition plan typically informs much of this disclosure.

UK SRS S2 paragraph 221 requires scenario analysis to support a resilience disclosure — scenario assumptions and transition plan assumptions must be consistent.

The Metrics & Targets pillar paragraphs 33-361 require disclosure of climate-related targets including GHG emissions targets — these are typically the quantitative anchors of TPT framework. Disclosure must include metric and scope, time frame, baseline, milestones and interim targets, and methodology including whether the target is informed by the latest international agreement on climate change1.

The TPT Framework

The UK Transition Plan Taskforce (TPT) was established by HM Treasury in April 2022 to develop a UK gold-standard framework for credible corporate transition plans. The TPT published its final Disclosure Framework in October 20233.

The TPT was wound up in 20244 after handing over its materials to the IFRS Foundation, which now maintains transition plan disclosure guidance globally. The Framework itself remains the most widely referenced transition plan reference in the UK market and is expected to inform both corporate practice and regulatory expectations under any future mandatory regime.

The TPT Framework is not legally mandated under UK SRS1 or CP26/52. It is a voluntary best-practice reference.

The IFRS Foundation educational materials on transition plan disclosure4, which now carry forward the TPT work internationally, are similarly non-mandatory but widely used.

The five TPT elements

The TPT Disclosure Framework3 organises a credible transition plan around five elements. Each element has specific sub-components and disclosure expectations.

Companies producing transition plans typically structure disclosure around these five elements. Whether the plan is published as a standalone document or integrated within annual reporting, the five-element structure provides a comparable reference for investors and regulators.

The separate Government consultation

The UK Government is separately consulting on potential mandatory transition plan requirements that would go beyond the current UK SRS S2 disclose-or-explain approach2. This consultation is expected to consider:

• Whether certain large companies should be required to produce and publish a transition plan (not just disclose its existence)
• Minimum content requirements (likely informed by the TPT Framework [3] and IFRS Foundation guidance [4])
• The relationship with UK SRS disclosures (avoiding duplicative reporting)
• Which entities would be in scope (listed only, or extending to large private entities through the Modernising Corporate Reporting programme)
• Timing and transition arrangements

The timeline for this consultation has not been confirmed at the date of this guide but is expected during 20262. Companies should prepare on the assumption that transition plan obligations will increase over time — voluntary high-quality plans now provide both stakeholder credibility and capability ahead of any mandatory regime.

Related frameworks — GFANZ, SBTi, IFRS

Three further frameworks inform UK transition plan practice alongside the TPT Framework.

GFANZ (Glasgow Financial Alliance for Net Zero)

GFANZ5 publishes transition plan guidance specifically for financial institutions. Its recommendations cover financed emissions reduction, real-economy transition financing, and engagement strategies for asset managers, banks, and insurers.

Particularly relevant for in-scope financial institutions whose financed emissions under UK SRS S2 paragraph B591 are the dominant emissions exposure.

SBTi (Science Based Targets initiative)

SBTi6 validates corporate net-zero targets against science-based criteria. SBTi validation is not required under UK SRS1 but is widely cited in transition plan disclosures as external validation of target ambition.

UK SRS S2 paragraph 331 requires disclosure of methodology used in target setting — SBTi validation provides one defensible methodology citation.

IFRS Foundation transition plan materials

The IFRS Foundation4 took over the TPT materials in 2024 and continues to publish educational guidance on transition plan disclosure under IFRS S27. Since UK SRS S21 mirrors IFRS S2 with limited UK amendments, IFRS Foundation transition plan guidance applies substantially to UK SRS as well.

Connection to scenario analysis (paragraph 22)

UK SRS S2 paragraph 221 scenario analysis is explicitly interconnected with transition plan disclosures. The transition plan is, in effect, the entity's response to scenarios analysed under paragraph 221 — particularly under 1.5°C-aligned pathways.

Scenario assumptions and transition plan assumptions must be consistent. If the entity's transition plan assumes a particular technology curve, energy price path, or policy pathway, those assumptions should align with the scenarios used in the resilience assessment.

Where they differ, the entity should explain why.

The resilience disclosure under paragraph 22(a)1 should address the implications of scenario analysis for planned transition activity. Where a transition plan exists, paragraph 22 disclosures and transition plan disclosures function as complementary parts of the strategy pillar narrative.

Assurance considerations

Transition plan disclosures made within the Strategic Report under UK SRS S21 will be subject to the same assurance framework as other UK SRS disclosures. ISSA (UK) 50008 — the UK sustainability assurance standard published by the FRC on 12 November 20258 and effective 15 December 20268 — provides the assurance methodology.

The FCA does not propose to require third-party assurance over UK SRS disclosures at this stage2. Where companies obtain assurance voluntarily, they must disclose the assurance level obtained, the assurance standard used, and the identity of the assurance provider2.

The FRC is establishing an interim register of sustainability assurance practitioners during 20269 ahead of the ISSA (UK) 5000 effective date. Audit committees should consider whether voluntary assurance over the transition plan disclosure would strengthen its credibility — particularly for the forward-looking elements that depend on quantitative assumptions.

Frequently asked questions