Transition plans · UK SRS S2 paragraph 14
Transition plan disclosure in the UK under UK SRS S2
There is no requirement in the UK to have a climate transition plan.
UK SRS S2 asks a company that has one to disclose information about it, and the FCA’s final rules require listed companies in scope to say whether they have one and where it can be found, as FCA CP26/5 had proposed.
The short answer
Are transition plans mandatory in the UK?
No: there is no requirement in the UK to have a climate transition plan, and transition plan disclosure in the UK is built around that fact.
UK SRS S2 requires a company that has a transition plan to disclose information about it; it does not require a company to produce one.
Under the FCA’s final rules (PS26/19 ¶2.37), in-scope listed companies disclose in their annual report whether they have a climate-related transition plan and, if so, where it can be found.
That is a disclosure about a plan, not a mandate to produce one.
The FCA’s consultation, CP26/5, had proposed a similar statement, with an explanation where no plan had been published.
CP26/5 paragraph 6.9 said in terms that the FCA was not setting requirements for listed companies to have transition plans because the Government’s own consultation was still open.
CP26/5 had proposed no UK SRS-aligned disclosures for the secondary listing and depositary receipt categories; the final rules bring those categories into UK SRS reporting.
Not required — by UK SRS S2 or by the FCA’s final rules.
Mandating that companies have transition plans is a matter for Government (CP26/5 ¶1.7).
Disclose in the annual report whether the company has a climate-related transition plan and, if so, where it can be found.
Source: FCA PS26/19 ¶2.37, from accounting periods beginning on or after 1 January 2027.
The standard
What UK SRS S2 requires
The requirement sits within the broader UK SRS S2 climate disclosure framework.
Paragraph 14(a)(iv) of UK SRS S2 requires disclosure of “any climate-related transition plan the entity has, including information about key assumptions used in developing its transition plan, and dependencies on which the entity’s transition plan relies”.
The surrounding paragraph asks for the rest of the picture: business model changes, mitigation and adaptation efforts, how targets will be met, how that work is resourced, and progress against earlier plans.
Any greenhouse gas emissions targets referred to in the plan are described under paragraphs 33 to 36, which is where the standard asks whether a target is absolute or intensity-based.
The plan must be consistent with the company’s strategy and risk management disclosures under the four-pillar framework.
Transition plan targets should also align with the Scope 3 emissions disclosures required elsewhere in UK SRS S2.
UK SRS S2 paragraph 14 — the transition picture
| Paragraph | Asks for |
|---|---|
| 14(a)(iv) | Any transition plan the entity has, including the key assumptions used in developing it and the dependencies it relies on |
| 14(a)(i)–(v) | Current and anticipated changes to the business model, including resource allocation; direct and indirect mitigation and adaptation efforts; how climate-related targets will be achieved |
| 14(b) | How the entity is resourcing those activities |
| 14(c) | Quantitative and qualitative information on progress against plans disclosed in previous periods |
| 33–36 | Any greenhouse gas targets the plan refers to, including whether absolute or intensity-based |
Guidance
The TPT Disclosure Framework
The UK Transition Plan Taskforce published its Disclosure Framework in October 2023, setting out what a credible transition plan disclosure should contain.
The TPT itself has been wound down: the IFRS Foundation assumed responsibility for its disclosure-specific materials in 2024.
The IFRS Foundation — not the ISSB, and not as an ISSB Standard — then published guidance on disclosing transition-plan information under IFRS S2 on 23 June 2025.
The TPT’s process guidance — how to build a plan, as opposed to how to disclose one — passed to the International Transition Plan Network.
The TPT Framework is not mandated under UK SRS, and UK SRS S2 itself does not mention it.
It is nonetheless the most widely referenced guidance in the UK market, and CP26/5 paragraph 6.10 proposed Handbook guidance pointing listed companies to the IFRS Educational Material that builds on it.
Where the TPT materials went
- Oct 2023TPT Disclosure Framework published
What a credible transition plan disclosure should contain.
- 2024IFRS Foundation takes the disclosure materials
Process guidance passes to the International Transition Plan Network.
- 23 Jun 2025IFRS Foundation guidance under IFRS S2
Published by the Foundation — not the ISSB, and not an ISSB Standard.
- CP26/5 ¶6.10FCA Handbook guidance, as consulted
Listed companies producing a plan “may wish to use the IFRS Educational Material”.
Five elements
What the TPT Framework covers
Foundations
Company-wide ambition and governance.
Implementation strategy
Actions and policies.
Engagement strategy
Value chain and industry collaboration.
Metrics and targets
How progress is measured.
Governance
Oversight of the plan.
For how a transition plan is actually built, pillar by pillar, see the practical guide.
Boards should understand the TPT Framework when overseeing transition plan development.
Other reference points include GFANZ transition plan guidance for financial institutions and the SBTi Corporate Net-Zero Standard.
Government
The separate Government consultation
DESNZ consulted on Climate-related transition plan requirements: implementation routes from 25 June 2025 to 17 September 2025.
It covered four dimensions: designing a plan, disclosing it, alignment with climate ambition, and implementing it.
The consultation has closed and, as at 26 September 2026, no government response has been published.
See regulatory updates for the latest position.
Private companies should monitor the response: the manifesto commitment the consultation started from named UK-regulated financial institutions and FTSE 100 companies, but no proposal, threshold or date has been published.
CP26/5 itself (¶¶6.8–6.9) records the Government’s statement that this consultation “will inform its future approach to transition plan requirements”, which is why the FCA proposed a location statement rather than a content requirement — the shape its final rules kept.
Any claim that transition plan obligations are certain to increase is commentary rather than published policy.
- 25 Jun 2025DESNZ consultation opens
Designing a plan, disclosing it, alignment with climate ambition, and implementing it.
- 17 Sep 2025Consultation closes
- 26 Sep 2026No government response
GOV.UK still invites readers to “visit this page again soon to download the outcome”.
Not whether UK companies will be required to produce a plan, what it would contain, or when any requirement would begin.
Assurance
Assurance considerations
Transition plan disclosures made under UK SRS S2 would sit within the same assurance framework as other UK SRS disclosures.
Neither CP26/5 nor the FCA’s final rules require assurance.
The FRC has been tasked by Government — in its response on assurance oversight — with establishing an interim, voluntary register of sustainability assurance practitioners.
ISSA (UK) 5000, issued by the FRC on 12 November 2025 for voluntary use, provides the assurance standard for engagements that are commissioned.
Assurance of transition plan disclosures is not mandated, but audit committees should consider whether voluntary assurance would strengthen the credibility of the disclosure.
See the UK SRS timeline for all key dates.
Under the FCA’s final rules, where assurance is obtained the company names the provider, which disclosures were assured and which assurance standards were used (PS26/19 ¶2.45).
Tasked for mid-2026 as an interim, voluntary register of sustainability assurance practitioners.
That target has passed, and no announcement that the register is open had been found as at 26 September 2026.
Consistency
Making the disclosure hold together
Companies in scope should keep their transition plan disclosures consistent with their scenario analysis outputs.
They should also align targets with the GHG Protocol methodology used for emissions reporting.
The move from TCFD to UK SRS is an opportunity to strengthen transition plan disclosures.
A gap analysis can show where existing transition plan documentation falls short of UK SRS expectations.
For the disclosure requirements paragraph by paragraph, see the IFRS Foundation’s June 2025 guidance, which maps each IFRS S2 paragraph to the TPT recommendations.
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.
- Financial Conduct AuthorityCP26/5: Sustainability disclosures
Chapter 6, transition plan disclosures as consulted on (¶¶6.1–6.11).
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
First published 30 September 2026. ¶2.37: issuers disclose in the annual report whether they have a climate-related transition plan and, if so, where it can be found. ¶2.45: assurance, where obtained.
- Financial Conduct AuthorityCP26/5: Aligning listed issuers' sustainability disclosures with international standards (PDF)
¶¶1.7, 6.8–6.10 — why the FCA proposed a location statement, not a content requirement.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures — final standard (PDF)
¶14(a)(iv) and the Appendix A definition of "climate-related transition plan".
- IFRS FoundationDisclosing information about transition plans in accordance with IFRS S2 (PDF)
Published 23 June 2025 by the IFRS Foundation — guidance, not an ISSB Standard.
- IFRS FoundationTransition Plan Taskforce resources
Where the TPT’s disclosure-specific materials now sit.
- Transition Plan Taskforce (archived by the IFRS Foundation)TPT Disclosure Framework (PDF)
October 2023.
- International Transition Plan NetworkInternational Transition Plan Network
Successor for the TPT’s transition-planning process guidance.
- Department for Energy Security and Net ZeroClimate-related transition plan requirements: implementation routes
Ran 25 June to 17 September 2025. No outcome published as at 26 September 2026.
- Glasgow Financial Alliance for Net ZeroGFANZ
Transition plan guidance for financial institutions.
- Science Based Targets initiativeSBTi
Corporate Net-Zero Standard.
- Financial Reporting CouncilISSA (UK) 5000 issued (12 November 2025)
The FRC sustainability assurance standard, issued for voluntary use.
- Department for Business and TradeAssurance of sustainability reporting — consultation and government response
The FRC tasked with an interim register by mid-2026 (¶¶1.13–1.15).
- GHG ProtocolGreenhouse Gas Protocol
The emissions methodology transition plan targets should align with.
Continue reading
Read next
Climate transition planning
How a transition plan is built, pillar by pillar.
Climate scenario analysis under UK SRS
The paragraph 22 resilience disclosure a transition plan should be consistent with.
UK SRS S2 — climate-related disclosures
The full S2 requirements that paragraph 14 sits within.
UK SRS assurance
What the FCA’s final rules say on assurance, and what ISSA (UK) 5000 governs.