- Governance
- Strategy
- Risk management
- Metrics and targets
Climate disclosure
How ready are you for climate disclosure?
Twelve short questions across the four areas in the TCFD recommendations: governance, strategy, risk management, and metrics and targets. This is an indicative check of how ready you are to describe the work. It does not decide whether a legal duty applies.
An indicative check, not advice. Your answers are not stored.
TCFD and what comes next
The four areas
The Task Force on Climate-related Financial Disclosures asked organisations to set out climate-related financial information in four areas: governance, strategy, risk management, and metrics and targets.
The Task Force disbanded in October 2023, having completed its work. The Financial Stability Board asked the IFRS Foundation to take over monitoring of companies’ climate-related disclosures. The IFRS Foundation described this as a transfer of those monitoring responsibilities to the International Sustainability Standards Board from 2024.
IFRS S2
IFRS S2 Climate-related Disclosures was issued by the International Sustainability Standards Board in June 2023. It integrates and builds on the TCFD recommendations.
The requirements in IFRS S2 are consistent with the TCFD’s four recommendations and eleven recommended disclosures. An organisation applying IFRS S2 provides the information covered by the TCFD recommendations. IFRS S2 also asks for more, including industry-based metrics, information about the planned use of carbon credits to achieve any net emissions targets, and further information about financed emissions.
Companies and limited liability partnerships
The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 require certain companies to include climate-related financial disclosures in the strategic report. They apply for financial years beginning on or after 6 April 2022.
The duty can apply where, at any time in the financial year, the company was a traded company, a banking company, an authorised insurance company, a company carrying on insurance market activity, or a company with securities admitted to trading on AIM, and it has more than 500 employees. It can also apply to a company with turnover of more than £500 million and more than 500 employees. A parent company is judged on the group: aggregate turnover of more than £500 million net, after the adjustments that remove transactions within the group, and an aggregate of more than 500 employees.
The number of employees is a monthly average. Add the number of persons employed under contracts of service in each month, then divide by the number of months in the financial year. Where the financial year is not actually a year, the £500 million turnover figure is adjusted in proportion.
The duty does not apply if the company is in the small companies regime, or qualifies as medium-sized, for that financial year. It does not apply if the company had no more than 500 employees or, for a parent, if the group’s aggregate was no more than 500. A subsidiary does not repeat the disclosure when it is included in a parent’s group strategic report that meets the conditions in the Act. The current wording is in section 414CA and section 414CB of the Companies Act 2006.
The disclosures cover:
- governance arrangements for assessing and managing climate-related risks and opportunities
- how those risks and opportunities are identified, assessed and managed
- how that process is integrated into overall risk management
- the principal climate-related risks and opportunities, and the time periods used to assess them
- the actual and potential impacts on the business model and strategy
- the resilience of the business model and strategy under different climate-related scenarios
- the targets used to manage climate-related risks and realise climate-related opportunities, and performance against those targets
- the indicators used to assess progress, and the calculations on which they are based
Directors may omit the whole or a part of the disclosures on impacts, resilience, targets and indicators where they reasonably believe, given the nature of the business and the way it is carried on, that the information is not necessary for an understanding of the business. The statement then explains that belief. This check does not decide that question.
The Limited Liability Partnerships (Climate-related Financial Disclosure) Regulations 2022 apply an equivalent disclosure to certain LLPs, for financial years beginning on or after 6 April 2022. A traded LLP or a banking LLP with more than 500 employees includes it in the strategic report. Any other LLP includes it in the energy and carbon report where it has more than 500 employees and turnover of more than £500 million. A parent LLP is judged on the figures for the group. Members have a similar route to omit part of the later disclosures where they reasonably believe the information is not necessary for an understanding of the business, and to explain that belief.
Listed companies
The Financial Conduct Authority’s UK Listing Rules currently ask in-scope listed companies to state, in their annual financial report, whether they have made disclosures consistent with the TCFD recommendations, or to explain why not. The FCA’s sustainability reporting requirements name the categories: equity shares (commercial companies), equity shares (international commercial companies secondary listing), certificates representing certain securities, non-equity shares and non-voting equity shares, and equity shares (transition).
From accounting periods beginning on or after 1 January 2027, that TCFD regime is replaced by a comply or explain approach against the UK Sustainability Reporting Standards. The same listing categories are in scope. Companies disclose in line with UK SRS S2, or explain. They also disclose in line with UK SRS S1, or explain, or state that they have not identified sustainability-related risks. Issuers may opt out of the comply or explain requirements for Scope 3 emissions disclosures for one year, and for disclosures under UK SRS S1 for two years.
From the same date, companies with a primary UK listing must also state whether, and if so where, they have published a climate-related transition plan, or state why they have not.
UK Sustainability Reporting Standards
The UK government published UK SRS S1 and UK SRS S2 on 25 February 2026. They are based on IFRS S1 and IFRS S2. The government issued them for voluntary use, and any entity may use them in whole or in part. For organisations reporting voluntarily, they are available to use now. The standards do not themselves set a date on which reporting becomes a legal requirement. The government has said that date would be set out in regulation or legislation if and when a reporting requirement is introduced.
How UK SRS should be reflected in the Companies Act 2006 is still under consideration. It is part of the Modernising Corporate Reporting consultation, published on 7 September 2026 and open until 30 November 2026. That consultation has not made UK SRS mandatory for companies. The government has said it has no plans, at this stage, to require companies to obtain assurance over UK SRS reporting.
What this check is
The questions follow the four TCFD areas. A result does not decide whether any of these duties applies. A result does not state that the organisation complies with IFRS S2 or with UK SRS. An indicative check, not advice. Your answers are not stored.
The pages behind these paragraphs:
- IFRS Foundation: ISSB and the TCFD
- IFRS Foundation, July 2023 news summary
- IFRS S2 Climate-related Disclosures
- SI 2022/31 and its explanatory note
- Companies Act 2006, section 414CA and section 414CB
- SI 2022/46
- FCA sustainability reporting requirements
- UK SRS S1 and UK SRS S2 and the government response of 25 February 2026
- Modernising Corporate Reporting consultation
- UK Government greenhouse gas conversion factors 2026
