UK Climate-Related Financial Disclosure Regulations (TCFD-aligned Disclosures)

Executive Summary

The UK Financial Conduct Authority (FCA) finalised its climate-related financial disclosure requirements in 2021, with the rules applying to the largest firms from 2022 and to smaller firms from 2023. The rules were based on recommendations from the Task Force on Climate-related Financial Disclosure and split between entity-level and product-level requirements.

In 2025, the FCA published the results from its review of its climate-related financial disclosure rules. It acknowledged that the rules generally increased firms’ consideration of climate risks and integration of climate considerations into decision-making. It added, however, that firms had encountered challenges with data availability in seeking to comply with the FCA’s climate reporting rules and that reporting was considered by some firms to be too granular and complex for investors to engage with.

In light of these considerations and of separate regulatory developments in the UK (the introduction of the UK Sustainability Disclosure Requirements and investment labels regime, the decision to introduce UK-endorsed ISSB standards and the UK Government’s proposals on transition plans), the FCA consulted on and then published new rules which streamline its climate reporting regime. These new rules apply were published in September 2026 and apply to communications with retail clients and to communications with institutional clients. The rules relating to communications with institutional clients start on 30 June 2027.

Please contact Adam Jacobs-Dean or Thomas Sharpe with any questions regarding these proposals.

Adam Jacobs-Dean

Managing Director, Global Head of Markets, Governance and Innovation
Thomas Sharpe

Associate Director, Markets, Governance and Innovation

The rules

The FCA’s rule changes focus on product-level reporting only. There are different rules for communications with retail clients and for communications with institutional clients. The FCA has not changed its entity-level rules but it has said that it will consider how it can streamline and enhance them. No timetable has been published for potential entity-level changes.

Scope

The scope of the new product-level reporting regime is unchanged from the scope of the existing TCFD-aligned product-level reporting regime.

Communications with retail clients

The FCA is replacing product-level TCFD-aligned reporting with new rules for communications with retail clients. These require in-scope firms to:

Consider periodically whether climate-related risks could be materially relevant to the financial performance or return of the product. This is to be done in a manner and frequency appropriate for the product and may be done as part of the firm’s usual risk assessment procedures.
Where a firm produces communications which provide information on the risk and financial returns of the product, include such climate-related risks in those communications. A firm may choose to disclose these risks as part of the risk and return information in a product summary.

Communications with institutional clients

For communications with institutional clients, the FCA is introducing the following changes to replace product-level TCFD-aligned reporting:

Firms are required to provide Scope 1, 2 and 3 GHG emissions data to clients if requested to meet their own climate-related financial disclosure obligations. This is a minimum baseline.
Firms should also provide the following information if reasonably practicable and permitted under contractual agreements on the firm’s use of data: (a) climate or carbon-related data which is reasonably required by the client’s climate-related financial disclosure obligations; and/or (b) an explanation of the proportion of each product for which data is verified, reported, estimated or unavailable.
Firms should provide the minimum baseline data to clients in response to requests made once per product per calendar year. Clients may continue to ask for information from firms outside of these rules.
Firms should provide information to clients within a reasonable period of time and in a format which the firm “acting reasonably, considers appropriate”.
Firms should provide contextual information where relevant, such as to how certain data and information should be interpreted and any associated limitations.
The FCA has made clear that firms should refrain from providing information, which in the reasonable opinion of the firm, is misleading because of data gaps or methodological challenges which cannot be addressed with proxy data or assumptions.

The Scope 1, 2 and 3 requirements are a reduction in the information required under the TCFD-aligned rules but clients may continue to request additional information outside of these rules.

Timeline

Event	Date
Rules for communications with institutional clients take effect	30 June 2027
FCA publishes the final rules	25 September 2026
AIMA responds to the consultation	10 July 2026
FCA publishes consultation on simplifying climate-related disclosure requirements for investment products	5 June 2026
FCA publishes findings from a review into its climate-related disclosure rules	6 August 2025
FCA’s climate-related disclosure rules (TCFD-aligned reporting) come into force	1 January 2022