TCFD status today

The Task Force on Climate-related Financial Disclosures (TCFD) was established in December 2015 by the Financial Stability Board.

Final recommendations were published on 29 June 2017.

The TCFD was formally disbanded in October 2023 following the IFRS Foundation's establishment of the International Sustainability Standards Board and publication of IFRS S1 and IFRS S2 in June 2023.

Responsibility for monitoring TCFD-aligned disclosure passed to the IFRS Foundation from January 2024.

In the UK, TCFD-aligned disclosure is currently required for commercial companies category issuers under UKLR 6.6.6R(8), in force since 29 July 2024 (FCA CP26/5).

UK SRS S2 (UK SRS S1 and S2) is the proposed regulatory successor — proposed mandatory from 1 January 2027 under FCA CP26/5 for listed companies population.

For comprehensive guidance, see our UK sustainability reporting standards reference guide.

What survives: the four pillars

TCFD established a four pillars: Governance, Strategy, Risk Management, and Metrics & Targets.

This structure is preserved in IFRS S2 and consequently in S2 climate standard (UK SRS S1 and S2).

For companies that have built TCFD reporting capability, the structural continuity is meaningful — board oversight, scenario analysis processes, risk identification frameworks, and GHG metrics infrastructure all carry over.

The pillars are not new.

What changes is the depth and rigour required within each pillar.

climate-related disclosures doesn't reorganise climate disclosure; it substantially raises the bar within the existing organisation.

Five substantive enhancements

UK SRS substantially enhances TCFD-aligned reporting in five specific areas.

Each is a step-change in disclosure expectations, not an incremental adjustment.

The signature visual above shows the five at a glance; this section examines each in detail.

UK SRS enhancements over TCFD

Quantitative financial effects

Required disclosure of financial impacts, not just encouraged

Financial-statement connected information

Must be read with financial statements, not standalone

Mandatory scenario analysis

Paragraph 22 hard requirement, not recommendation

Comprehensive Scope 3

All 15 GHG Protocol categories required (with reliefs)

Financed emissions

Detailed requirements for financial institutions

TCFD to UK SRS migration roadmap

1

Gap assessment

Deliverable: Review existing TCFD disclosures against UK SRS S2 requirements
2

Data architecture

Deliverable: Enhance systems for quantitative financial effects
3

Scenario development

Deliverable: Build climate scenarios for mandatory analysis
4

Scope 3 methodology

Deliverable: Implement enhanced Scope 3 and financed emissions
5

Connected information mapping

Deliverable: Link sustainability metrics to financial statements
6

Internal review

Deliverable: Board sign-off on enhanced disclosures
7

External assurance

Deliverable: Independent verification of UK SRS compliance

1 — Quantitative financial effects

TCFD described quantitative disclosure of climate-related financial effects as desirable but did not mandate it.

Most TCFD-aligned disclosures under the previous UK regime contained qualitative narrative about climate impacts on strategy, with limited quantification.

SRS S2 paragraphs 18-21 require disclosure of current and anticipated effects of climate-related risks and opportunities on financial position, financial performance, and cash flows for the reporting period and short, medium, and long term.

Quantitative disclosure is required (UK SRS S1 and S2), with qualitative-only relief available only where measurement uncertainty is genuinely high.

The practical effect: where a TCFD disclosure might have said "physical climate risks could affect coastal operations," UK SRS S2 expects quantified disclosure of the asset values exposed, the time horizons over which effects could materialise, and the financial impact under specified scenarios.

2 — Financial-statement connected information

TCFD treated climate disclosures and financial statements as separate documents.

There was no requirement to explain how climate-related risks and opportunities connected to the recognition and measurement of assets, liabilities, provisions, and forward-looking estimates in the financial statements.

UK SRS S1 establishes the Connected information principle as a core requirement.

Companies must explain how sustainability-related risks and opportunities relate to information in their financial statements — carrying amounts of assets and liabilities, recognition and measurement of provisions, and assumptions used in forward-looking estimates (UK SRS S1 and S2).

This applies under UK SRS S2 climate disclosures through the foundational Connected information principle in S1 — S2 cannot be applied without S1's foundational elements (DBT).

3 — Scenario analysis required, not recommended

TCFD recommended scenario analysis (TCFD Final Recommendations) with rigour appropriate to circumstances.

Many TCFD-aligned disclosures under the previous UK regime relied on narrative scenarios — describing potential climate futures without quantified analysis of business model resilience.

UK SRS S2 paragraph 22 makes scenario analysis a hard requirement.

The standard requires rigour commensurate with entity exposure — entities with greater climate exposure must use more technically sophisticated approaches.

The standard does not prescribe a scenario.

Paragraph 22(b)(i) requires an entity to disclose, among the inputs to its analysis, whether the scenarios it used align with the latest international agreement on climate change (UK SRS S1 and S2).

Common frameworks supporting paragraph 22 compliance include NGFS climate scenarios and IEA Net Zero by 2050 (UK SRS S1 and S2).

Entities with high climate exposure can no longer rely on qualitative narrative scenarios — quantified analysis with explicit assumptions about climate policy, macroeconomic trends, energy use and mix, and technology developments is expected (UK SRS S1 and S2).

4 — Scope 3 emissions required across all 15 categories

TCFD treated Scope 3 emissions as a material-based recommendation.

Most TCFD-aligned disclosures focused on Scope 1 and Scope 2, with Scope 3 reporting concentrated on the most material categories for the industry concerned.

UK SRS S2 paragraph 29(a) requires Scope 3 emissions across the 15 categories of the GHG Protocol Corporate Value Chain Standard, with the entity disclosing which categories are included in its measure (UK SRS S1 and S2).

Materiality drives which categories require detailed disclosure, but the default expectation is comprehensive consideration of all 15.

The first-year transition relief (UK SRS S1 and S2) defers Scope 3 disclosure to year two, and FCA CP26/5 adds an optional additional one-year deferral on top.

The practical effect: Scope 3 becomes comply-or-explain across all 15 categories from accounting periods beginning 1 January 2028 (FCA CP26/5).

5 — Financed emissions for financial institutions

TCFD did not specify financed emissions disclosure requirements for financial institutions.

Most TCFD-aligned disclosures from banks, asset managers, and insurers focused on operational emissions (Scope 1 and 2) with limited disclosure of portfolio climate impacts.

UK SRS S2 imposes detailed financed emissions requirements on financial institutions (UK SRS S1 and S2).

Paragraph B59 applies to asset management, commercial banking, and insurance activities (UK SRS S1 and S2).

UK paragraph B59A allows a different reporting period from the financial statements where alignment is impracticable, with disclosure of the reasons.

The practical effect: UK financial institutions must disclose absolute gross financed emissions disaggregated by Scope 1, 2, and 3 (UK SRS S1 and S2).

This represents a step-change in portfolio climate risk transparency compared to TCFD-aligned disclosure.

Transition plans: where UK SRS lands

UK SRS S2 paragraph 14(a)(iii) requires disclosure of any climate-related transition plan, including key assumptions used and dependencies on which the plan relies.

The "any" qualifier is significant — transition plans are not mandated by UK SRS S2.

FCA CP26/5 does not propose to mandate transition plans separately.

The approach differs from the European Corporate Sustainability Reporting Directive, which includes specific transition plan requirements.

Under UK SRS, companies must disclose transition plans if they exist, but are not required to have one.

For TCFD-aligned companies that have developed transition plans, the disclosure requirements under paragraph 14(a)(iii) provide clear guidance on what to include.

For those that haven't, UK SRS does not compel transition plan development.

Migration guidance for TCFD reporters

Companies with established TCFD reporting should focus enhancement efforts on the five areas where UK SRS S2 raises the bar substantially.

The four-pillar structure provides continuity; the challenge is depth, not reorganisation.

Priority areas for TCFD reporters preparing for UK SRS compliance: quantify climate-related financial effects per paragraphs 18-21, establish financial statement connected information per S1 requirements, upgrade scenario analysis to meet paragraph 22 hard requirements, prepare for comprehensive Scope 3 disclosure across all 15 categories, and for financial institutions, develop financed emissions measurement and disclosure capability.

The FRC Sustainability Reporting FAQ provides additional implementation guidance for UK companies preparing for UK SRS disclosure requirements.

Companies can also refer to existing IFRS S1 and S2 implementation materials while noting UK-specific modifications.

UK SRS vs TCFD: key takeaways

TCFD disbanded

TCFD framework disbanded October 2023; UK SRS S2 is proposed as its regulatory successor from 2027 (FCA CP26/5, no Policy Statement yet)

Four pillars preserved

Governance, Strategy, Risk Management, Metrics & Targets framework continues

Five enhancements

Quantification, connected information, scenarios, Scope 3, financed emissions

Mandatory scenarios

Scenario analysis now required, not just recommended as under TCFD

Financial connected information

Financial statement connected information required through UK SRS S1 foundational elements

Transition plans

Must be disclosed if they exist, but not mandated to have one

UK SRS vs TCFD migration in practice

Frequently asked questions

Does UK SRS replace TCFD completely?
Not yet, and not entirely. The FCA has proposed, via CP26/5, to make UK SRS S2 the successor to TCFD-aligned disclosure under UKLR 6.6.6R(8), but that Listing Rule remains in force and no Policy Statement has been published. The Task Force itself was formally disbanded in October 2023, with the IFRS Foundation, not the ISSB, taking over responsibility for monitoring TCFD-aligned disclosure from January 2024. UK SRS preserves the four-pillar structure but substantially raises disclosure expectations.
Can I still use my existing TCFD reporting processes?
The four-pillar foundation (Governance, Strategy, Risk Management, Metrics & Targets) is preserved, so existing TCFD infrastructure carries over. However, UK SRS S2 requires substantial enhancements in five areas: quantitative financial effects, financial-statement connected information, mandatory scenario analysis, comprehensive Scope 3 emissions, and financed emissions for financial institutions.
When do the enhanced requirements take effect?
FCA CP26/5 proposes mandatory UK SRS S2 disclosure from 1 January 2027 for UKLR categories 6, 16 and 22; UKLR 14 and 15 are in scope of CP26/5 but would instead signpost the overseas or voluntary standards they follow, not report under UK SRS. Scope 3 emissions have transition reliefs: first-year relief plus optional one-year additional deferral means comply-or-explain from 2028 accounting periods.
What about transition plans under UK SRS?
UK SRS S2 paragraph 14(a)(iii) requires disclosure of any climate-related transition plan, including key assumptions and dependencies. However, transition plans are not mandated by the FCA — the "any" qualifier means disclosure is required only where a plan exists. See Transition Plans under UK SRS for detailed coverage.
Is scenario analysis really mandatory under UK SRS?
Yes. UK SRS S2 paragraph 22 makes scenario analysis a hard requirement, not a recommendation. Rigour must be commensurate with entity exposure. The standard prescribes no particular scenario: paragraph 22(b)(i) requires disclosure of whether the scenarios used align with the latest international agreement on climate change, not that such a scenario be used. This is a significant upgrade from TCFD's recommendation.