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UK transition plan regulation · the map

UK transition plan regulation: what binds, and what is still promised

UK transition plan regulation is a patchwork: no instrument requires a company to have a plan, but several ask what you say about one.

The government’s consultation on making plans compulsory closed on 17 September 2025 and has no published outcome.

This page maps each instrument that touches a plan today, with its owner and status.

The finder

Which rules touch your transition plan

Tick what describes you and the panel lists every instrument that reaches your plan, with the provision and whether it is a rule, an expectation or a pending proposal.

The common thread is that each instrument asks about disclosure: UK SRS S2 ¶14(a)(iv) asks about any plan you have, and the FCA asks whether one is published.

None of them requires a plan to exist.

That gap is what the government’s consultation was meant to fill.

How to write the disclosures themselves is on transition plans and UK SRS.

Which rules touch your transition plan?

  • Final ruleSay whether a transition plan is published, where — or why notFor accounting periods beginning on or after 1 January 2027. A statement, not a duty to have a plan.UKLR 6.6.6R(8)(e); PS26/19
  • UK SRS S2Describe any transition plan you haveKey assumptions and dependencies, and how you plan to achieve any climate targets. If you have no plan, this item has nothing to describe.UK SRS S2 ¶14(a)(iv), (v)
  • OpenWhether any UK entity must have a plan is undecidedThe consultation on transition-plan requirements ran from 25 June to 17 September 2025. On 1 October 2026 its page still said to visit again soon for the outcome.DESNZ, Climate-related transition plan requirements

A map of instruments, not advice.

Nothing you enter leaves your browser.

The pending decision

The 2025 consultation: a commitment, two options, no outcome

The consultation page records the government’s commitment to mandating “UK-regulated financial institutions (including banks, asset managers, pension funds and insurers) and FTSE 100 companies to develop and implement credible transition plans that align with the 1.5°C goal of the Paris Agreement”.

The implementation routes document set out two options: require entities to explain why they have not disclosed a transition plan or plan-related information, or require them to develop and disclose one.

It also stated the government’s reading that UK SRS S2 will not require an entity to have a transition plan.

The consultation was published alongside the UK SRS exposure drafts and the assurance consultation; both of those have had responses, and this one has not.

The modernising corporate reporting consultation of September 2026 does not propose transition plan requirements either.

Until a response is published, any date for compulsory plans is speculation.

Status, 1 October 2026

The consultation page still says to visit again soon to download the outcome.

It ran from 1pm on 25 June 2025 to 11:59pm on 17 September 2025.

Instrument by instrument

Every instrument that reaches a UK plan

UKLR 14 and 15 issuers report against UK SRS on a comply-or-explain basis but make no (8)(e) statement. Sources as linked.
InstrumentWhoWhat it asksKindSource
UKLR 6.6.6R(8)(e)Listed in UKLR 6, 16, 22Whether a plan is published, where, or why not — from periods beginning 1 January 2027Final rulePS26/19
UK SRS S2 ¶14(a)(iv)Anyone applying UK SRS S2Key assumptions and dependencies of any plan the entity hasStandardUK SRS S2
CA 2006 s.414CBCompanies in s.414CA scopeClimate-related financial disclosures in the strategic reportStatutes.414CB
ESG 2.2.1RAsset managers and asset owners at or above £5bnEntity-level TCFD reportFCA ruleESG 2.2
ESG 5.4.2R, 5.6Asset managers at or above £5bnSDR entity-level report on the four pillars, regardless of labellingFCA ruleESG 5
SS5/25Banks, building societies, insurersExpectations on managing climate-related risksSupervisory statementPRA
SI 2021/839Trustees of large occupational pension schemesGovernance, scenario analysis, metrics, a target and a published reportStatutory instrumentSI 2021/839

The FCA’s policy statement says that UK SRS S2 does not require entities to have a plan, and that it is not requiring listed companies to produce one (PS26/19).

For asset managers, FCA 2026/59 removed the product-level TCFD metrics rule on 25 September 2026 (Handbook Notice 144); the entity-level report survives.

The SDR regime from PS23/16 adds an entity-level report due by 2 December 2026 for managers with £5 billion or more outside the enhanced SMCR group.

The climate standard behind the UK SRS rows is on UK SRS S2.

Pension schemes

Occupational pension trustees: a separate, compulsory regime

Trustees of large occupational pension schemes are under SI 2021/839, a DWP regime overseen by the Pensions Regulator.

They must establish governance of climate-related risks and opportunities, carry out scenario analysis, select metrics — emissions and, since 2022, a portfolio-alignment metric — and set a target.

They publish a TCFD report on a free public website within seven months of the scheme year-end.

Failing to publish triggers a mandatory penalty of at least £2,500; the maximum is £5,000 for an individual and £50,000 for a body corporate (reg 9).

This is not UK SRS, and it is not a TPT transition plan: it is a trustee duty structured on the TCFD’s four pillars.

Schemes also appear in the government’s 2025 commitment, which names pension funds among the financial institutions it intends to cover.

Source: SI 2021/839, as read in the Bible (pension-scheme-climate.md).
Relevant assetsIn scope from
£5bn or more1 October 2021
£1bn or more1 October 2022
Authorised master trusts and CDC schemesRegardless of size
Below £500m after entryOngoing duties cease; one final report

Guidance, not regulation

The TPT framework and its sector guidance

The TPT Disclosure Framework, published in October 2023, organises a plan across five Elements and nineteen Sub-Elements.

The TPT’s Sector Summary covers 30 financial and real-economy sectors in its final, April 2024 version, alongside seven sector guidances.

The Taskforce disbanded in October 2024 and its disclosure materials are now hosted by the IFRS Foundation, which says it is not responsible for their accuracy.

The Foundation’s own June 2025 guidance on disclosing transition information under IFRS S2 draws on them and changes no requirement.

Sector guidance is therefore voluntary everywhere in the UK; no regulator has made any of it a rule.

The five Elements are set out on transition plans and UK SRS.

The dated record

What has happened, and when

Every date in the record is one an owner has published; none is a forecast.

The one date the market most wants — when plans become compulsory — does not exist yet.

The wider regulatory sequence, beyond transition plans, is on the UK sustainability regulation timeline.

  1. 1 Oct 2021
    Pension scheme duties begin

    Largest schemes, SI 2021/839.

  2. Oct 2023
    TPT Disclosure Framework

    Voluntary guidance.

  3. Oct 2024
    TPT disbands

    Materials to the IFRS Foundation and the ITPN.

  4. 25 Jun 2025
    Consultation opens

    Transition plan requirements.

  5. 17 Sep 2025
    Consultation closes

    No outcome since.

  6. 3 Dec 2025
    PRA SS5/25 commences

    Replaces SS3/19.

  7. 30 Sep 2026
    FCA PS26/19

    A statement, not a plan.

  8. 1 Jan 2027
    FCA rules apply

    Periods beginning on or after.

Planning

What to do while the decision is pending

  1. If you are listed in UKLR 6, 16 or 22, prepare the (8)(e) statement for your first period beginning on or after 1 January 2027.
  2. If you apply UK SRS S2, map any plan you have against ¶14(a)(iv) — its assumptions and dependencies — and ¶¶33–36 on targets.
  3. If you are a pension trustee, an asset manager or a PRA-regulated firm, work from your own regime’s rule or expectation.
  4. Watch the consultation page for the government’s response; nothing further binds until one is published and implemented.

The FCA’s wider rules are on the FCA’s UK SRS rules; financial institutions should read UK SRS for financial services.

To talk it through, book a free 15-minute call.

Frequently asked

Questions people ask

Is there a UK law requiring transition plans?

No. No UK statute or regulator’s rule requires a company to have, implement or publish a climate transition plan.

The government consulted on requirements from 25 June to 17 September 2025 and had published no outcome as at 1 October 2026.

What did the government commit to on transition plans?

Its consultation page records a commitment to mandate UK-regulated financial institutions, including banks, asset managers, pension funds and insurers, and FTSE 100 companies to develop and implement credible transition plans that align with the 1.5°C goal of the Paris Agreement.

How to take that forward is what the consultation asked.

What options did the consultation set out?

Two: requiring entities to explain why they have not disclosed a transition plan or plan-related information, or requiring them to develop and disclose a transition plan.

What changes for listed companies in 2027?

From accounting periods beginning on or after 1 January 2027, companies in UKLR 6, 16 and 22 must state in their annual financial report whether they have published a climate-related transition plan, where it is, or why they have not.

The FCA said it is not requiring plans or setting where they go.

Do pension schemes have to produce transition plans?

Trustees of large occupational pension schemes are under a separate duty in SI 2021/839: climate governance, scenario analysis, metrics including a portfolio-alignment metric, a target, and a TCFD report published within seven months of the scheme year-end.

That is a DWP regime overseen by the Pensions Regulator, not UK SRS and not the TPT framework.

Does the PRA require banks and insurers to publish transition plans?

SS5/25, which replaced SS3/19 on 3 December 2025, sets the PRA’s expectations for how banks and insurers manage climate-related risks.

It is a supervisory statement, not a rule requiring publication of a plan.

Is the TPT framework a legal requirement?

No. The Transition Plan Taskforce disbanded in October 2024.

Its Disclosure Framework is archived guidance hosted by the IFRS Foundation, which says it is not responsible for its accuracy.

Using it is voluntary.

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.

Checked against 18 sources fromDepartment for Energy Security and Net ZeroFinancial Conduct AuthorityPrudential Regulation Authoritylegislation.gov.ukDepartment for Business and TradeIFRS Foundation
  1. Department for Energy Security and Net Zero
    Climate-related transition plan requirements — consultation page

    Ran 25 June to 17 September 2025; no outcome as at 1 October 2026.

  2. Department for Energy Security and Net Zero
    Transition plan requirements: implementation routes
  3. Financial Conduct Authority
    PS26/19 — Aligning listed issuers’ sustainability disclosures with international standards (30 September 2026)

    Final rules: comply or explain against UK SRS, UKLR 6, 14, 15, 16 and 22, periods from 1 January 2027.

  4. Financial Conduct Authority
    PS26/19 PDF — ¶¶2.36–2.44 and UKLR 6.6.6R(8)(e)
  5. Financial Conduct Authority
    Handbook Notice 144 — FCA 2026/59 in force 25 September 2026
  6. Financial Conduct Authority
    FCA Handbook, ESG 2.2 — TCFD entity report
  7. Financial Conduct Authority
    FCA Handbook, ESG 5 — SDR entity-level report (ESG 5.4.2R, 5.6.1R)
  8. Financial Conduct Authority
    PS23/16 — Sustainability Disclosure Requirements and investment labels
  9. Prudential Regulation Authority
    SS5/25 — Enhancing banks’ and insurers’ approaches to managing climate-related risks

    Commenced 3 December 2025.

  10. legislation.gov.uk
    The Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021 (SI 2021/839)

    Trustee duty; report within seven months of the scheme year-end.

  11. Department for Business and Trade
    UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 (25 February 2026)

    The publication page for both standards; voluntary for any entity.

  12. Department for Business and Trade
    UK SRS S2 — ¶14(a)(iv) and Appendix A
  13. legislation.gov.uk
    Companies Act 2006, s.414CB — (A1) the duty, (2A) the eight disclosures, (6) national frameworks
  14. Department for Business and Trade
    Modernising corporate reporting — consultation, 7 September to 30 November 2026

    ¶¶147–161 and ¶178: CFD review, s.414CB(6), s.463 and no assurance plans “at this stage”.

  15. IFRS Foundation
    Transition Plan Taskforce resources
  16. Transition Plan Taskforce (archived)
    TPT Disclosure Framework (October 2023)
  17. Transition Plan Taskforce (archived)
    TPT Sector Summary (April 2024)

    30 financial and real-economy sectors, final version.

  18. IFRS Foundation
    Guidance on disclosing transition information under IFRS S2 (June 2025)
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