Key Takeaways
- The FCA proposed replacing existing TCFD-aligned listed-company disclosure rules with UK Sustainability Reporting Standards.
- The consultation closed on March 20, 2026, with the FCA planning a Policy Statement in autumn 2026.
- The proposed new rules are expected to come into force from January 1, 2027, subject to final UK SRS.
FCA Replaces TCFD-Based Rules With UK SRS
The FCA's final rules require in-scope listed companies to prepare disclosures in accordance with UK SRS S1 and UK SRS S2, or explain why specified disclosures have not been made.
The regulator says high-quality and comparable sustainability disclosures help financial markets inform asset pricing and capital allocation. It also says financial institutions need reliable sustainability data for products, investment decisions and risk management.
The framework applies to companies listed in several categories: equity shares in commercial companies; equity shares in international commercial companies secondary listings; certificates representing certain securities, including depositary receipts; non-equity and non-voting equity shares; and equity shares in the transition category.
Rules Focus on Investor Information
Under the new regime, companies must include climate-related disclosures prepared in accordance with UK SRS S2 in their annual financial reports, or explain unmet requirements, the reasons for them and steps to make the disclosures in future.
They must also provide sustainability-related disclosures under UK SRS S1, explain sustainability risks and opportunities that have not been disclosed and why, or state that they have not identified sustainability risks.
The rules include optional transitional reliefs. Issuers may opt out of comply-or-explain requirements for Scope 3 emissions disclosures for one year and for UK SRS S1 sustainability disclosures for two years.
What Happens to Existing TCFD Rules?
The FCA currently requires listed companies to state in their annual financial reports whether they have made disclosures consistent with the Task Force on Climate-related Financial Disclosures recommendations, or explain why not.
The International Sustainability Standards Board issued IFRS S1 and IFRS S2 in June 2023, incorporating the TCFD recommendations. The TCFD was disbanded in October 2023 after fulfilling its remit.
From accounting periods beginning on or after 1 January 2027, the FCA's TCFD-based regime for listed companies will be replaced by the UK SRS rules. This is not an end to climate-related reporting: UK SRS S2 covers climate-related disclosures, subject to the new comply-or-explain approach.
Why the Regulatory Change Matters
Moving from TCFD-based requirements to UK SRS changes the disclosure structure that in-scope listed companies must use in their annual financial reports.
For companies, the transition includes new UK SRS S1 and S2 reporting requirements and specified explanations where disclosures are not made. For investors, the FCA's objective is to support high-quality and comparable sustainability information used in asset pricing and capital allocation.
The final rules also require all in-scope issuers to disclose information about any third-party sustainability assurance they obtain voluntarily. That includes the assurance provider's name, the disclosures or explanations assured, the assurance level and standards used, and where to find an assurance report if it has been published.
TwikUp's Perspective
The important distinction is between replacing the TCFD-based disclosure framework and withdrawing climate reporting altogether. The FCA's final rules establish a transition to UK SRS reporting rather than a confirmed end to climate-related disclosure obligations for listed companies.
The change reflects the FCA's move toward reporting based on the UK SRS. Listed companies in scope will continue to provide climate-related information under UK SRS S2, while broader sustainability disclosures will be addressed under UK SRS S1.
What Happens Next
The FCA has published final listed-company rules in PS26/19. It is also consulting on Technical Note 803.1, consequential amendments to Technical Note 801.4 and the deletion of Technical Note 802.3.
The FCA has published suggested preparation steps for issuers and Primary Market Bulletin 66 to help companies prepare for the new regime. Companies and investors can now assess the final requirements, transitional reliefs and implementation timetable ahead of accounting periods beginning on or after 1 January 2027.