TCFD · the successor
UK SRS vs TCFD
UK SRS vs TCFD is a comparison between a framework that has stopped and a standard that has just started: the Task Force disbanded in October 2023, and UK SRS S2 was published on 25 February 2026.
The FCA’s final rules make the switch for listed companies, on a comply-or-explain basis, from accounting periods beginning on or after 1 January 2027.
What a TCFD reporter keeps, and what it has to add, is below — filter it by pillar.
The short answer
TCFD disbanded; UK SRS takes over its UK rules
Module 01 / 04
Disclosure
Module 02 / 04
Disclosure · 2
Module 03 / 04
Key point 03
Module 04 / 04
Disclosure · 3
Read the detailed guidance and evidence
The Task Force fulfilled its remit and disbanded on 12 October 2023, and monitoring of climate disclosure moved on from 2024: the FSB named the ISSB, and the IFRS Foundation’s release names both.
The ISSB’s IFRS S2 is, in the IFRS Foundation’s words, “consistent with” the four recommendations and eleven disclosures — and it asks for more.
UK SRS S2 is IFRS S2 as endorsed for the UK, with a short list of differences.
The FCA’s PS26/19 puts it plainly at ¶1.10: “These rules will replace the existing TCFD aligned disclosures.”
For accounting periods beginning before 1 January 2027 a listed company still makes its TCFD statement; from then on it reports against UK SRS or explains.
UK SRS itself is voluntary for any entity the rules do not reach, as voluntary reporting under UK SRS explains.
Pillar by pillar
What stays, what goes further, what is new
Module 01 / 04
Comparatives
Module 02 / 04
Key point 02
Module 03 / 04
Oversight
Module 04 / 04
Risk
TCFD → UK SRS S2 · filter by pillar
- Board and managementGoes further
TCFD · Describe the board’s oversight and management’s role (two disclosures).
UK SRS · The same two questions, broken out: mandates, skills, how often the body is informed, how it weighs climate in strategy and major transactions, how it oversees targets.
UK SRS S2 ¶6
- RemunerationNew in S2
TCFD · Not one of the eleven recommended disclosures.
UK SRS · Whether and how climate is factored into executive remuneration, and the percentage of pay linked to it.
UK SRS S2 ¶29(g)
- Risks and time horizonsGoes further
TCFD · Risks and opportunities over the short, medium and long term.
UK SRS · Each risk classified as physical or transition, its time horizon given, and “short”, “medium” and “long” defined against the entity’s own planning horizons.
UK SRS S2 ¶10(a)–(d)
- Financial effectsGoes further
TCFD · Impact on businesses, strategy and financial planning.
UK SRS · Current and anticipated effects on financial position, performance and cash flows. Quantitative information may be withheld only where effects are not separately identifiable or measurement uncertainty makes it not useful — and then the reason is explained.
UK SRS S2 ¶¶15–21, esp. ¶19, ¶21
- Scenario analysisGoes further
TCFD · Describe resilience under different scenarios, including a 2°C or lower scenario — where material.
UK SRS · The entity “shall use” climate-related scenario analysis to assess resilience, with an approach commensurate with its circumstances. No scenario is prescribed; the inputs, including alignment with the latest international agreement on climate change, are disclosed.
UK SRS S2 ¶22, ¶B8
- Transition planNew in S2
TCFD · Addressed in the October 2021 guidance on transition plans.
UK SRS · Information about any climate-related transition plan the entity has, with key assumptions and dependencies. There is no duty to have one.
UK SRS S2 ¶14(a)(iv)
- ProcessesGoes further
TCFD · Identify and assess; manage; integrate (three disclosures).
UK SRS · Adds prioritisation and monitoring, the inputs and parameters used, whether scenario analysis informs identification, and changes from the prior period — for opportunities as well as risks.
UK SRS S2 ¶¶24–26
- Greenhouse gas emissionsGoes further
TCFD · Scope 1, Scope 2 and, if appropriate, Scope 3.
UK SRS · Absolute gross Scope 1, 2 and 3 under the GHG Protocol, Scope 2 location-based, and the Scope 3 categories included. UK SRS S2 ¶C4 relief from Scope 3 has no time limit in the standard.
UK SRS S2 ¶29(a), ¶C4
- Cross-industry metricsNew in S2
TCFD · Metrics used; the October 2021 guidance added detail without changing the disclosure.
UK SRS · Seven categories are required: emissions, transition risk, physical risk, opportunities, capital deployment, internal carbon prices and remuneration.
UK SRS S2 ¶29(a)–(g)
- Industry metricsNew in S2
TCFD · Not part of the eleven.
UK SRS · Industry-based metrics; in the UK the industry guidance is something an entity “may” refer to, not “shall”.
UK SRS S2 ¶32; Annex A
- Financed emissionsNew in S2
TCFD · Addressed in supplemental guidance for the financial sector, not in the eleven.
UK SRS · Required for asset management, commercial banking and insurance; UK SRS S2 ¶B59A adds a duty to explain where financed emissions cannot be estimated for the same period.
UK SRS S2 ¶B59, ¶B59A
- TargetsGoes further
TCFD · Targets used and performance against them.
UK SRS · Quantitative and qualitative targets, including any required by law and any emissions targets, with how they are set, reviewed and tracked.
UK SRS S2 ¶¶33–36
- What a listed company must doGoes further
TCFD · State whether disclosures are consistent with TCFD, and explain gaps with steps and a timeframe (UKLR 6.6.6R(8)).
UK SRS · Report against UK SRS S2 and S1, or say what is missing, why, and the steps planned — comply or explain — for periods beginning on or after 1 January 2027.
FCA PS26/19 ¶¶1.10, 3.12
- ReliefsNew in S2
TCFD · None in the rule.
UK SRS · One year’s Scope 3 non-disclosure and two years’ S1 non-climate non-disclosure, stated but not explained.
FCA PS26/19 ¶¶3.14, 3.20
- Assurance and transition plansNew in S2
TCFD · No statement required.
UK SRS · Say whether third-party assurance was obtained and, if so, from whom, over what and to which standard; say whether a transition plan is published and where, or why not. Neither is required to exist.
UKLR 6.6.6R(8)(d)–(e) from 1 Jan 2027
UK SRS S2 paragraph numbers follow IFRS S2 in the body; the UK differences are in Annex A to the government response.
Summaries, not quotations, except where marked.
Read the detailed guidance and evidence
The comparison beside this text runs row by row, and each row is tagged: goes further, or new in S2.
Nothing in the TCFD’s ground is dropped by UK SRS S2; the eleven all have a home in its paragraphs.
Governance deepens from two disclosures to the structured questions of paragraph 6: mandates, skills, how often the body is informed, how it weighs climate in strategy and major transactions, and how it oversees targets.
Strategy gains the most, from a classification of each risk as physical or transition to the anticipated financial effects on position, performance and cash flows.
Risk management adds prioritisation, monitoring, inputs and parameters, and applies to opportunities as well as risks.
Metrics and targets grows from “the metrics used” to seven named cross-industry categories, including internal carbon prices and executive remuneration.
The four pillars as the UK standards use them are set out on the UK SRS four pillars.
Five substantive additions
Where UK SRS S2 asks for more than TCFD
Module 01 / 04
1 · Financial effects, linked to the financi
Module 02 / 04
2 · Connected information
Module 03 / 04
3 · Scenario analysis the entity “shall use”
Module 04 / 04
4 · Scope 3, with a relief
Read the detailed guidance and evidence
1 · Financial effects, linked to the financial statements
TCFD Strategy b) asked for the impact of climate on the business, strategy and financial planning.
UK SRS S2 paragraphs 15 to 21 ask for the current and anticipated effects on financial position, financial performance and cash flows.
Quantitative information may be withheld only where the criteria in paragraphs 19 and 20 are met, and then the entity explains why, gives qualitative information and identifies the line items affected.
2 · Connected information
TCFD disclosures were often a standalone section; IFRS S1, and so UK SRS S1, requires information that lets a reader understand the connections between sustainability disclosures and the financial statements.
The UK SRS S1 heading is “Connected information”, and it is what makes the climate section read as part of the annual report; more on UK SRS S1.
3 · Scenario analysis the entity “shall use”
TCFD Strategy c) recommended describing resilience under scenarios, including 2°C or lower, where material.
Under paragraph 22 the entity shall use climate-related scenario analysis, with an approach commensurate with its circumstances and proportionality set out at paragraph B8.
No scenario is prescribed, and paragraph B15 accepts qualitative scenario narratives as a reasonable basis; sets such as the NGFS scenarios are common choices, and the method is on climate scenario analysis under UK SRS.
4 · Scope 3, with a relief
TCFD asked for Scope 3 “if appropriate”; UK SRS S2 paragraph 29(a) requires Scope 3 and the categories included, drawing on the GHG Protocol Scope 3 Standard.
Paragraph C4 lets a voluntary user leave Scope 3 out with no time limit; the FCA’s rules give listed companies one year.
How the categories and the relief work is on Scope 3 under UK SRS.
5 · Financed emissions
The eleven did not ask for financed emissions; UK SRS S2 does, for entities in asset management, commercial banking and insurance.
Paragraph B59A, added in the UK, requires an explanation where financed emissions cannot be estimated for the same period as the financial statements; the sector view is on UK SRS for financial services.
Beyond these five, S2 asks for information about any transition plan the entity has, with its key assumptions and dependencies, at paragraph 14(a)(iv).
Status
Recommended, voluntary, comply or explain
The same climate disclosures carry a different status depending on who is asking.
The FCA’s final rules added a third column on 30 September 2026.
Module 01 / 04
Basis
Module 02 / 04
Who
Module 03 / 04
From
Module 04 / 04
Scope 3
Read the detailed guidance and evidence
| TCFD recommendations | UK SRS S2, used voluntarily | UK SRS S2 under the FCA rules | |
|---|---|---|---|
| Basis | Voluntary recommendations | Voluntary standard | Comply or explain, UKLR 6.6.6R(7A) |
| Who | Anyone | Any UK entity | Listed companies in UKLR 6, 14, 15, 16 and 22 |
| From | June 2017 | 25 February 2026 | Periods beginning on or after 1 January 2027 |
| Scope 3 | “If appropriate” | Relief with no time limit (¶C4) | One-year relief, then comply or explain |
| Assurance | Not addressed | Not required | State whether obtained, by whom, over what, to which standard |
| Transition plan | Guidance only | Disclose any plan the entity has | UKLR 6, 16 and 22: state whether one is published and where, or why not |
| Maintained? | No — frozen since November 2023 | Yes | Yes |
Consultation paper CP26/5 had proposed that UK SRS S2 be mandatory, excluding Scope 3, for three listing categories.
The final rules put all of UK SRS on comply or explain and brought the secondary-listing and depositary-receipt categories in on the same basis.
A company that does not report against UK SRS S2 in full gives a summary of the requirements not met, the reasons, and the steps it is taking or plans to take.
Assurance is not required, only a statement about it, as UK SRS assurance explains; the dates by listing category are on the UK SRS deadline.
UK SRS S2 against IFRS S2
The UK’s own changes, and the one that is stricter
Module 01 / 04
¶¶12, 23, 32
Module 02 / 04
¶B59A
Module 03 / 04
¶C4
Module 04 / 04
¶C3
| Paragraph | The UK difference |
|---|---|
| ¶¶12, 23, 32 | Industry-based guidance: “shall” becomes “may” |
| ¶B59A | New: explain where financed emissions cannot be estimated for the same period |
| ¶C4 | Scope 3 relief: the first-year limit removed, left to law or regulation |
| ¶C3 | GHG Protocol method relief: first year only, as in IFRS |
| Effective date | Removed; set by whoever requires the standard |
Read the detailed guidance and evidence
The government’s consultation response lists every difference between UK SRS S2 and IFRS S2 in its Annex A.
Almost all of them relax the international text.
The industry-based guidance is something an entity “may” refer to and consider, not something it “shall”.
The Scope 3 relief loses its one-year limit, so for a voluntary user it runs until a law or regulation closes it.
Paragraph B59A runs the other way: where IFRS S2 would let a financial institution use a different period for financed emissions without comment, UK SRS S2 requires it to explain why, a point the FRC restates.
A paragraph reference in the appendices needs its standard named, because “C4” means different things in the two texts; the UK standards compared with the IFRS originals are on UK SRS S2.
The other UK route
UK SRS S2 and the Companies Act disclosures
Module 01 / 04
Disclosure
Module 02 / 04
Oversight
Module 03 / 04
Comparatives
Module 04 / 04
Disclosure · 2
Read the detailed guidance and evidence
The Companies Act climate disclosures are not TCFD in name, and the FCA’s rules do not touch them.
The government has confirmed that UK SRS S2 is a national reporting framework for the purposes of section 414CB(6), so a company reporting in accordance with it need not duplicate its disclosures.
It has also said it will consider the future of those obligations, and the eight limbs are compared with the eleven on TCFD UK requirements.
How SECR’s energy and emissions reporting sits beside UK SRS is on SECR and UK SRS.
Transitioning from TCFD
Moving a TCFD report onto UK SRS
An order of work, not a regulator’s timetable — no UK regulator publishes one. Each step names the provision it answers to.
Module 01 / 04
1
Module 02 / 04
2
Module 03 / 04
3
Module 04 / 04
4
Read the detailed guidance and evidence
| Step | What to do | Provision |
|---|---|---|
| 1 | Confirm your first period beginning on or after 1 January 2027, or decide to adopt early and keep the reliefs | PS26/19 ¶¶3.12, 3.19 |
| 2 | Map each existing TCFD disclosure to its UK SRS S2 paragraph and list the gaps | UK SRS S2 ¶¶5–37 |
| 3 | Build the financial-effects disclosures with the finance team, tied to the financial statements | UK SRS S2 ¶¶15–21; UK SRS S1 connected information |
| 4 | Choose a scenario-analysis approach commensurate with your circumstances | UK SRS S2 ¶22, ¶B8 |
| 5 | Decide whether to use the Scope 3 relief in year one, and word the statement | PS26/19 ¶¶3.14, 3.20 |
| 6 | Draft the location, assurance and transition-plan statements | UKLR 6.6.6R(8)(c)–(e) from 1 January 2027 |
| 7 | Where anything is not disclosed, draft the explanation: what, why, and the steps planned | UKLR 6.6.6R(7A)(b) |
A sustainability manager’s question at this point is often which provider or software to use.
This site does not rank vendors; the practical test is whether a tool reports against UK SRS S2 paragraphs rather than the TCFD eleven, and sustainability reporting sets out what a report needs to contain.
Boards have their own questions, covered on UK SRS for boards, and what compliance looks like end to end is on UK SRS compliance.
The sequence from standards to first reports is on the UK SRS timeline and the S1 and S2 timeline, and who is in scope on UK SRS thresholds.
For how the UK approach differs from the EU’s, see UK SRS vs CSRD; answers to shorter questions are on the UK SRS FAQ, and transition plans on transition plans under UK SRS.
The hub for the standards is UK SRS.
Frequently asked
UK SRS vs TCFD: questions people ask
Is TCFD being replaced by UK SRS?
For UK listed companies, yes.
The FCA’s final rules, PS26/19, replace the TCFD-aligned listing-rule disclosures with reporting against UK SRS S1 and S2 on a comply-or-explain basis, for accounting periods beginning on or after 1 January 2027.
The Companies Act climate disclosures are not replaced, but UK SRS S2 can be used to meet them.
Has the TCFD been disbanded?
Yes.
The Task Force disbanded on 12 October 2023, alongside its final status report, and its website has not been updated since November 2023.
Monitoring of climate-related disclosure moved on from 2024; the FSB named the ISSB, and the IFRS Foundation’s release names both itself and the ISSB.
What is the difference between TCFD and UK SRS S2?
TCFD is a set of voluntary recommendations from 2017, frozen since 2023.
UK SRS S2 is the UK-endorsed version of IFRS S2, published on 25 February 2026, which keeps the same four pillars and asks for more: a classification of each risk, current and anticipated financial effects, scenario analysis the entity shall use, seven cross-industry metric categories, and financed emissions for some sectors.
Is scenario analysis mandatory under UK SRS S2?
The standard says the entity shall use climate-related scenario analysis to assess its resilience, using an approach commensurate with its circumstances.
No scenario is prescribed and quantification is not required: qualitative scenario narratives can be a reasonable basis.
For listed companies the whole standard sits on comply or explain, so a company that does not do it explains why and what it plans.
Is Scope 3 required under UK SRS S2?
Paragraph 29(a) requires Scope 3, and paragraph C4 lets an entity using the standard voluntarily leave it out with no time limit.
Under the FCA’s rules a listed company may use a one-year Scope 3 relief from initial application, stating that it is doing so, after which Scope 3 is on comply or explain like everything else.
Can I keep my TCFD reporting processes for UK SRS?
The structure carries over, because UK SRS S2 uses the same four pillars.
What needs building is the depth: financial effects linked to the financial statements, the scenario analysis, the seven metric categories, and connected information across the annual report under UK SRS S1.
Does UK SRS require a transition plan?
No. UK SRS S2 asks for information about any climate-related transition plan the entity has, including key assumptions and dependencies.
From 2027 the listing rules ask a company to say whether it has published a transition plan and where, or why not; there is no duty to have one.
Is UK SRS stricter than IFRS S2 anywhere?
In one place.
UK SRS S2 paragraph B59A requires an entity to explain why, if it has found it impracticable to estimate financed emissions for the same reporting period as its financial statements.
Every other UK difference is permissive, such as making the industry-based guidance something an entity may, rather than shall, refer to.
Which software supports the move from TCFD to UK SRS?
This site does not rank or recommend vendors.
The useful test is whether a tool maps its outputs to UK SRS S2 paragraphs rather than to the TCFD eleven — in particular the seven paragraph 29 categories, the Scope 3 categories included, and financed emissions if you are a bank, insurer or asset manager.
Prepare the evidence
UK SRS vs TCFD: from a requirement to a reporting pack
Use this preparation sequence alongside the detailed requirements on this page.
An editorial workflow, not a statutory schedule.
- Stage 0101
Current route
Identify the current legal or voluntary route rather than assuming the TCFD still regulates it.
- Stage 0202
Governance
Document oversight of climate-related risks and opportunities.
- Stage 0303
Strategy
Connect climate issues and resilience analysis to the organisation’s strategy.
- Stage 0404
Risk management
Explain how climate risks enter the existing risk process.
- Stage 0505
Metrics and targets
Trace emissions, targets and performance measures to their methods.
- Stage 0606
Transition mapping
Compare the disclosure with the applicable successor requirements.
Read the applicable instrument: Recommendations
A practical brief
An evidence pack, with a clear review trail
Ask for a pack that lets the next reviewer retrace the scope decision, follow the evidence and understand the limitations.
This describes a useful handover; it does not certify compliance or establish that a vendor or adviser delivers it.
Module 01 / 04
Applicability record
Write down the entity, reporting route and relevant period, including why the route applies.
Module 02 / 04
Evidence register
Attach each reported figure or statement to its source, method, version and limitations.
Module 03 / 04
Review trail
Name the preparer, reviewer, open questions and decisions taken before publication.
Module 04 / 04
Usable handover
Retain the working files and unresolved actions so the next reporting cycle can reuse the evidence.
View the preparation diagram
- Prepare01
Create the traceable pack
Keep the input records, calculation files and narrative together.
- Challenge02
Resolve questions before publication
Record the assumptions challenged and any limitations still unresolved.
- Retain03
Make the next cycle reproducible
Keep the approved version and the actions carried forward.
Continue your research
Related guides, one question at a time
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- Task Force on Climate-related Financial DisclosuresRecommendations
The four recommendations and eleven disclosures a TCFD reporter starts from.
- Task Force on Climate-related Financial DisclosuresThe disbanding notice (fsb-tcfd.org)
Disbanded 12 October 2023.
- IFRS FoundationIFRS Foundation welcomes TCFD responsibilities from 2024 (July 2023)
The monitoring role that moved when the Task Force disbanded.
- IFRS FoundationISSB and TCFD
“Consistent with” the eleven, with additional requirements.
- IFRS FoundationIFRS S1 General Requirements
Connected information and materiality across the report.
- IFRS FoundationIFRS S2 Climate-related Disclosures
The standard UK SRS S2 endorses.
- IFRS FoundationIFRS S2 (December 2025 HTML), ¶¶6, 10, 14, 15–22, 29, B8
The paragraph text behind each comparison row.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026.
- Department for Business and TradeUK SRS S2 — Climate-related Disclosures (PDF), ¶¶22, B15, B59A, C4
Scenario analysis, qualitative narratives, the UK’s financed-emissions paragraph and the untimed Scope 3 relief.
- Department for Business and TradeUK SRS exposure drafts: consultation response, Annex A
Every difference between UK SRS S2 and IFRS S2.
- Financial Conduct AuthorityPS26/19 — final rules (landing page)
UK SRS on a comply-or-explain basis for listed companies.
- Financial Conduct AuthorityPS26/19 (PDF), ¶¶1.10, 3.12, 3.14, 3.19, 3.20 and Appendix 1
The replacement of TCFD, the dates, the reliefs and the new UKLR 6.6.6R(7A) and (8).
- Financial Conduct AuthorityCP26/5 (PDF)
The consultation, which had proposed a mandatory S2 core.
- Financial Reporting CouncilSustainability reporting developments — frequently asked questions
Reliefs without time limits for voluntary users; B59A explained.
- legislation.gov.ukCompanies Act 2006, section 414CB(6)
The route by which UK SRS S2 discharges the Companies Act climate disclosures.
- GHG ProtocolCorporate Value Chain (Scope 3) Standard
The fifteen categories UK SRS S2 ¶29(a) refers to.
- Network for Greening the Financial SystemNGFS Scenarios Portal
A common scenario set; UK SRS S2 prescribes none.