The four-pillar structure of Governance, Strategy, Risk Management, and Metrics and Targets will be familiar to any company that has reported under TCFD. UK SRS retains this structure but transforms it from a set of recommendations into a set of mandatory disclosure requirements with significantly greater specificity. The difference is not in the framework but in the depth and rigour of what must be disclosed within each pillar.
Governance
How the organisation governs sustainability-related risks and opportunities.
What TCFD Required
TCFD asked companies to describe board oversight and management's role in assessing climate risks. Many companies responded with generic governance statements — identifying the relevant committee and stating that climate was on the board agenda.
What UK SRS Now Requires
UK SRS requires documented board-level accountability, not just description. Companies must disclose the specific body or individual responsible for oversight of sustainability risks and opportunities, the skills and competencies available to that body, how sustainability considerations are embedded into strategy and decision-making, and how management reports to the board on sustainability matters. The governance disclosure must demonstrate how oversight actually operates — processes, frequency, information flows — rather than simply stating that oversight exists.
Strategy
The actual and potential effects of sustainability-related risks and opportunities on the company's business model, strategy, and financial position.
What TCFD Required
TCFD recommended that companies describe climate-related risks and opportunities over short, medium, and long-term horizons, and describe the impact on strategy. Scenario analysis was recommended but not required, and qualitative narratives were common.
What UK SRS Now Requires
UK SRS requires companies to define the short, medium, and long-term horizons used in their analysis and explain how they were determined. Scenario analysis is mandatory under S2 — at least two scenarios, one consistent with a 1.5°C pathway, with financially quantified outcomes. Companies must disclose how sustainability risks and opportunities have affected or are expected to affect their business model, value chain, strategy, and financial position. The financial effects must be expressed in quantitative terms where possible, with qualitative disclosure permitted only where quantification is not practicable.
Risk Management
The processes used to identify, assess, prioritise, and monitor sustainability-related risks and opportunities.
What TCFD Required
TCFD asked companies to describe their processes for identifying and managing climate-related risks. Many companies maintained a standalone climate risk register separate from their enterprise risk management framework.
What UK SRS Now Requires
UK SRS requires integration of sustainability risk management with the enterprise risk management framework — not a standalone register. Companies must disclose the processes used to identify sustainability risks and opportunities, the criteria for prioritisation (including materiality thresholds), how these processes are integrated into the overall risk management system, and how they monitor known and emerging risks. This integration requirement means sustainability risk cannot be siloed in a separate ESG function — it must flow through the same governance and escalation structures as financial, operational, and strategic risks.
Metrics and Targets
The metrics and targets used to assess, manage, and monitor sustainability-related risks and opportunities.
What TCFD Required
TCFD recommended disclosure of metrics and targets used to assess climate-related risks and opportunities, including Scope 1 and 2 emissions, and Scope 3 where material. Target-setting was encouraged but not standardised.
What UK SRS Now Requires
UK SRS requires Scope 1, Scope 2, and Scope 3 greenhouse gas emissions disclosed using the GHG Protocol methodology. Scope 3 is on a comply-or-explain basis from January 2028 across all 15 GHG Protocol categories where material. Companies must disclose the metrics used to measure performance against targets, the targets themselves (including whether they are absolute or intensity-based), the base year, milestones, and progress. Climate scenario analysis results must be quantified. Companies must also disclose whether their targets have been validated by a third party and how they relate to the latest international agreements on climate change.
The Practical Difference
The four-pillar framework is structurally identical to TCFD. Companies with mature TCFD reporting programmes will recognise every pillar. The difference is in the standard of disclosure required within each. TCFD operated on a recommended, comply-or-explain basis. UK SRS operates as a formal reporting standard with specific, auditable disclosure requirements. Where TCFD accepted qualitative narratives, UK SRS demands quantification. Where TCFD permitted standalone sustainability reports, UK SRS requires disclosures within the statutory Strategic Report. For a detailed comparison of the two frameworks, see TCFD vs UK SRS.
Sources and References
- GOV.UK — UK SRS Guidance — DBT UK SRS hub
- IFRS S2 — S2 four-pillar structure
- FCA CP26/5 — FCA CP26/5 on S2 disclosures
- NGFS — NGFS climate scenarios referenced in scenario analysis
- IEA — IEA scenarios used for UK SRS S2 compliance