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 has been considering how to streamline its climate reporting regime. It published proposed rule changes in July 2026.

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 proposals

The FCA’s proposed rule changes to streamline its climate-related reporting regime focus on product-level reporting only. There are different proposals for products aimed at retail clients and products aimed at institutional clients. The FCA is not currently proposing to change entity-level reports.

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 proposing to replace product-level TCFD-aligned reporting with a new rule for communications with retail clients which would require in-scope firms to:

consider periodically whether climate risks and/or opportunities could be materially relevant to the financial performance or return of the product; and
disclose such risks and/or opportunities in communications that are intended for retail clients and that provide general information on risk and financial returns.

The materiality lens applied to this rule would require firms to disclose climate-related information only if materially relevant to the financial performance or returns of the product.

Communications with institutional clients

For communications with institutional clients, the FCA is proposing to replace product-level TCFD-aligned reporting with a new rule which would require in-scope firms to:

provide, at a minimum, data on Scope 1, 2 and 3 emissions when requested by clients who require such information to satisfy their climate disclosure obligations; and
note that institutional clients are only able to request such information once per calendar per product. This replicates the frequency of reporting for Scope 1, 2 and 3 emissions under the existing rules.

The FCA notes that the Scope 1, 2 and 3 requirements are a reduction in the information currently required under TCFD-aligned rules but that firms may provide additional information beyond Scope 1, 2 and 3 if reasonably required by their clients. Firms need not disclose information to their clients where data gaps or methodological challenges could lead to them supplying misleading information.

The FCA consulted on these proposals between June and July 2026 and has said that it aims to finalise and implement these rule changes in autumn 2026.

Timeline

Event	Date
FCA plans to finalise and implement the rule changes	Autumn 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